Report on the skin only shooting of kangaroos in NSW and Queensland

In late 2005, the NSW National Parks and Wildlife Service was besieged by demands from rural lobby groups to re-allow the skin-only shooting of kangaroos in NSW, which was banned in 1996. NSW NPWS then contracted a consulting company to review whether skin only shooting should be re-introduced. Amongst other reasons, the consultants recommended no skin-only shooting, stating amongst other reasons, that skin-only shooting was impossible to police. Rural lobby groups did not accept this report, and still demanded that skin-only shooting should be allowed. The consultants then produced another Report, an ADDENDUM, reinforcing their recommendations, a summary of which is featured below.

This report contains significant and relevant information that will be of interest to those who oppose the commercial kangaroo industry, and the skin only shooting Industry in particular. At this point of time, Feb 2007, the NSW Government does not intend to re-introduce skin only shooting. Interestingly the report reiterates many of the issues of concern we have raised for decades.

The full reports can be found on the NSW NPWS website here.

Table of Contents, Introduction 1, The ‘fors’. 1, The ‘againsts’ 2, Discussion 3

Issue 1. Quota utilisation 3

Issue 2. Declining carcass condition in times of drought 4

Issue 3. Full utilisation of the animal 4

Issue 4. Protection for landholders when trying to recover post drought 5

Issue 5. Kangaroos as pests 5

Issue 6. Management of carcass waste 5

Issue 7. Limited carcass take and inaccessibility 6

Issue 8. Review of the outcome of this debate 6

Issue 9. Income for landholders and issues of ‘fairness’ 7

Issue 10. Skin-only harvest may assist in reducing total grazing pressure 7

Issue 11. Animals dying in droughts 8

Issue 12. Tags for trappers and landholders 8

Issue 13. How much quota for skin 8

Issue 14. Professional attitudes 8

Issue 15. Industry destabilisation 9

Issue 16. Skin Quality 10

Issue 17. Skin size 10

Issue 18. Remoteness 10

Issue 19. Placement of chillers 10

Issue 20. High cost of transport 10

Issue 21. High costs of industry entry prohibitive 11

Issue 22. Issues of supply 11

Issue 23. Flexible Management 11

Issue 24. Conservation benefits from skin-only harvest 11

Issue 25. Poor service in western areas. 12

Issue 26. Infrastructure 12

Issue 27. A strong stable industry 12

Issue 28. Compliance 12

Issue 29. A benefit to a few 12

Issue 30. Decreases in skin markets 13

Issue 31. Current program 13

Conclusions

Introduction

A report into the feasibility of re-introducing skin-only shooting in NSW was prepared by the consultants and submitted to the NSW Kangaroo Management Advisory Panel on 16/12/2005. A presentation regarding the findings of the report was made to the Panel by Ms Sally Egan on 02/03/2006. As a result of the presentation and some points of contention within the findings of the report, the Panel requested a final round of consultation. DEC suggested they submit their concerns in writing and that an opportunity would be provided for Sally Egan (from the consultants) to have the right of reply. This report acts as an addendum to the first report (22247.6087) and should be read after reading the original report and the submissions. It outlines the content of the submissions made by the groups who have representation on the Panel, and also includes discussions by Sally Egan addressing the submissions and any subsequent changes to the recommendations resulting from the submissions.

For ease of reading, the report has been structured into a list of themes presented by those submissions that can be considered to be ‘for’ the reintroduction of skin-only shooting and another list for those that are ‘against’. The actual submissions received by DEC are provided in Attachment A. Please note that the responses to the submissions are not referenced although the list of references used is supplied in the document. The decision not to reference was made as no new information has been supplied, rather information originally presented in the full feasibility study has been reiterated. If the reader wishes to follow up a line of argument presented here, it will either be referenced in the original feasibility document, or it is the opinion of the authors.

The ‘fors’.

Submissions that maintain or express a new support for the re-introduction of skin-only harvest into NSW were received from:

• The New South Wales Farmers Association (NSW FA);

• The State Council of the Rural Land Protection Board (RLPB); and

• The Pastoralist Association of the West Darling (PAWD).

Issues submitted by these groups can be loosely clumped into themes and these are presented in Table 1 below.

Table 1. Themes submitted by groups for the reintroduction of skin-only harvesting Number Theme Organisation

1 Carcass industry has not taken full quota historically, reintroduction will move industry closer to full utilisation of the quota. RLPB, PAWD, NSW FA

2 Shooters have to take more carcass to achieve an economical weight when condition of animals is poor; skin only harvest would provide opportunity when climatic conditions mean carcass condition is too poor for meat harvest RLPB, PAWD, NSW FA

3 Kangaroos should be harvested to their full potential including meat and skin RLPB 4 Skin only harvest would provide protection for landholders also trying to recover when seasonal conditions improve RLPB, PAWD, NSW FA

5 Kangaroos as pests, skin-only harvesting would allow landholders to recoup costs. RLPB

6 Concerns over pest animal access to carcasses can be addressed by management of the carcass RLPB, PAWD, NSW FA

7 Skin-only shooting will allow shooting to continue where carcass take is limited or where it is difficult to take the required numbers of carcasses because of inaccessibility RLPB

8 The issue of skin-only harvest should remain open for discussion in future review processes despite the recommendation of the report. RLPB

9 Landholders do not receive income from kangaroo harvest on their land and skin-only harvest may be one way this can occur. The industry is well provided for by landholders; it is the infrastructure and maintenance of watering points by landholders that support the kangaroo population and consequently the industry, it is only fair that landholder be given reasonable opportunity to access economic return from the industry they provide for. RLPB

10 Skin-only harvest may assist in reducing total grazing pressure. RLPB, PAWD, NSW FA

11 Skin-only harvest is a better option than large numbers of animals dying in the field during drought situations. PAWD, NSW FA

12 Should reintroduction occur, tags would be available to trappers and landholders. PAWD,

NSW FA

13 Should reintroduction occur, the skin-only allocation within the quota should match the average difference between quota and take for the previous 5 years. This could be monitored quarterly and adjusted as market forces and quota utilisation require. PAWD, NSW FA

14 It is difficult to ascertain that a less professional attitude will prevail in skin only harvesting; Trappers who carry out skin-only harvesting could be required to complete current Game Meat Handling courses and undergo Firearms competency and Accuracy tests; checks and measures in place within the industry should be effective in ensuring the industries high standards are maintained; compliance can be sought from Fauna Dealers to ensure illegal sale and trade in skins doesn’t occur. PAWD, NSW FA

15 The issue that skin shooting has the potential to destabilise the industry is difficult to substantiate, there is no basis for arguing that the re-introduction of skin only harvesting would have an adverse impact on the market or industry. PAWD, NSW FA

16 In relation to issues of poor quality skins, a code of practice for preparation and storage could be prepared. PAWD, NSW FA

17 The issue of smaller animals being taken is easily overcome by the establishment of a minimum accepted skin size. PAWD, NSW FA

18 The remoteness of western NSW is an issue PAWD, NSW FA,

19 The placement of chillers is an issue. PAWD, NSW FA

20 The high cost of transport is an issue, skin only shooting will help to reduce transport costs and improve quota utilisation in isolated zones. PAWD, NSW FA

21 High establishment costs of trays, chillers, and fuel are a major barrier for landholders accessing the industry. PAWD, NSW FA

The ‘againsts’.

Submissions that maintain or express a new support for not re-introducing a skin-only harvest into NSW were received from:

• The New South Wales Division of the Australian Veterinary Association (NSW AVA);

• The Australian Game Meat Producers Association (AGMPA);

• The Kangaroo Industries Association of Australia Inc. (KIAA); and

• The NSW Department of Primary Industries (DPI).

Issues submitted by these groups can also be loosely clumped into themes and these are presented in Table 2 below.

Table 2.

Themes submitted by groups against the reintroduction of skin-only harvesting Number Theme Organisation

3 Ethically the carcass should be used whenever it is feasible. Industry should be moving away from shooting to waste. NSW AVA, KIAA

22 There are insufficient kangaroos available in NSW at present to sustain the needs of the carcass industry and this may not change for some years to come. AGMPA

23 DEC must maintain flexibility in management according to the conditions at the time. If in future years, if markets provided under full utilisation scenarios can not control numbers and assuming welfare consideration can be addressed, the inherent flexibility of the management guidelines should be maintained as to allow skin-only shooting. AGMPA

24 There is no conservation benefit to kangaroo populations in allowing the reintroduction of skin-only harvesting KIAA

6 The increase in feral animal numbers which would feed on discarded carcasses whether buried, burnt or otherwise would be detrimental to other native species. KIAA

25 KIAA refutes arguments that there are areas of Western NSW that are poorly serviced by the carcass industry. KIAA

26 A re-introduction of skin-only harvesting would cause continued investment of infrastructure by carcass processors to be questioned as short term speculative skin only operations become possible. This could result in less quota utilisation than is presently the case. KIAA

21 Arguments regarding the prohibitive costs of entering the carcass shooting industry for landholders are a wild exaggeration. KIAA

8 KIAA does not agree with the recommendation in the initial report that the proposal should not be considered ever again. KIAA

27 It is important that the kangaroo industry remains strong and does not open itself up to destabilisation and further criticism. A risk is that the re-introduction of skin-only shooting would detract from the image of the industry.DPI

28 Skin-only harvests would increase the level of compliance necessary and reduce the current level of control over animal welfare. DPI

29 Skin-only shooting benefits few people (landholders) and these landholders can with some investment participate in carcass harvest. The report demonstrates that the skin industry prefers to obtain skins from carcass processors and that overall, benefits to landholders would be small and not worth the damage to industry that might occur from opponents emphasising the negative aspects. DPI

30 The report identifies the declining role of skin-only shooting in Queensland where skin only shooting has decreased to low levels in comparison to carcass shooting. DPI

1 In NSW there is a high utilisation rate of the kangaroo quota without skin-only shooting. DPI

31 The current Kangaroo Management Program offers opportunity to minimise kangaroo damage to crops and pastures while maintaining the best opportunities for the long term future for the kangaroo industry.

Discussion.

Issue 1. Quota utilisation

The RLPB, PAWD and NSW FA all submitted that the level of quota utilisation in NSW has been historically unacceptable and proposed that allowing skin-only harvest would improve the levels of quota utilisation experienced across the State.

NSW DPI conversely, agreed with the original feasibility report’s assessment that the levels of quota utilisation in NSW are comparatively high. E.A. Systems reiterates the position it took in the initial report as NSW quota utilisation rates are comparatively high when compared to those occurring in the same period in Queensland. We direct attention to the graph on page 24 of the feasibility assessment (Figure 25) which clearly shows the higher percentage taken in NSW. On average 20% more of the NSW quota was taken from 1997 to 2002, than over the same period in QLD. The second part of this issue concerns the potential to improve the rate of quota utilisation in NSW with the introduction of skin-only harvest.

We would like to repeat our previously stated judgement that the rate of quota utilisation will not improve following the re-introduction of skin-only harvests unless there is an established and stablemarket for the resulting skins. This is not the case as the market for skins direct from the harvester is now below 10% in Queensland and processors from both Queensland and NSW have stated clearly that they prefer to source skins from meat processors for both quality and ease of access reasons.

So, there is no established market for the product. The second point we wish to make is that skin-only harvest can only improve quota utilisation in the long term if it remains stable. We believe this is not a likely or possible outcome of reintroducing skin-only into NSW as we established in the feasibility report that the skin-only harvest did not remain stable in Queensland, despite having a long history, a massive market share of product and established trade connections. We believe a new skin trade in NSW after years of no activity, will have no possibility at all of providing stability.

Issue 2. Declining carcass condition in times of drought

The RLPB, NSW FA and PAWD are concerned that trappers have to take more carcass to achieve an economical weight when the condition of animals is poor. They suggest that skin only harvest would provide opportunity when climatic conditions mean carcass condition is too poor for meat harvest. We agree that skin-only harvest may provide an opportunity to continue to harvest kangaroos when carcass condition is insufficient to allow skin/carcass harvest. However as we have previously stated on page 32 of the feasibility report, as carcass declines, skin quality may also decline and there is a limited window between when an animal becomes unsuitable for carcass harvesting and an associated possible decline in skin quality which could result from physical trauma to the skin from changed behaviour, poor body condition and an increased susceptibility to parasites and disease. As animals start to die, it becomes increasingly uneconomical to shoot them for skin-only or carcass as there are not enough left in the landscape to justify the costs of attempting to harvest them.

The RLPB has suggested that currently shooters have to take more carcasses to achieve an economic weight. This is possible in the light of high fuel prices, however as a result of shortened supply and increasing demand, we find it difficult to understand why shooters would be unable to recoup costs of skin/carcass harvesting at present. Processors are desperate for supply and as such have been paying very high prices for some months now.

Issue 3. Full utilisation of the animal The RLPB State Council submits that the kangaroo should be harvested to its full potential including meat and skin. Similarly the NSW AVA and DPI support full utilisation of the animal. We think the submissions are slightly different and that the RLPB State Council is supporting the notion that the full potential of harvest options should be supported in regard to kangaroos, rather than the animal is fully utilised. The only other interpretation of their submission would be that they were unaware that when the term ‘carcass harvest’ is used, it actually refers to the harvesting for the meat and the skin of the animal.

It is our view that the increase in the general public’s demands for ethical and environmentally sound management of most industries, let alone wildlife harvesting ones, will ensure that full utilisation of the animal is provided for in the Kangaroo Industry. Whilst we have some empathy with RLPB’s submitted position it may not be reflected by the greater body of the community.

Issue 4. Protection for landholders when trying to recover post drought The RLPB, NSW FA and PAWD have suggested that skin only harvest would provide protection for landholders also trying to recover when seasonal conditions improve. This would only be the case under a particular set of circumstances including:

• Kangaroos are providing a threat to a landholders recovery post drought

• There are enough kangaroos in the landscape to make it feasible for a person to harvest for either skin/carcass or skin-only

• There is a market or economic driver for the take of skin-only

• If the opportunity for recovery for the landholder is related to money they may make, the landholder will have to harvest the kangaroos themselves.

It is our view that in most cases these conditions will not apply. Following significant periods of climatic stress, kangaroo numbers are likely to be at their very lowest and consequently will not provide a threat to landholders or landscapes recovering from drought. It is estimated by kangaroo ecologists that a period of at least 4 years is required for kangaroos to reach pre-drought levels (Cairns S. pers comm.). The low levels of animals in the landscape will mean that harvest effort for an economic return will increase as animals are further apart and harder to find.

Therefore it might not be economically feasible for a harvest to operate in that area for either carcass/skin or skin-only purposes. Most importantly, for anyone to invest time and energy into shooting kangaroos for skin-only purposes, there must be a market for the product. The QLD case study suggests that the remaining skin-only market may well be on the way out, with levels of harvest down to 8% of the total take. Skin processors have declared a clear preference for buying skins from carcass processors. Any opportunistic market that does grow up around a decision to re-introduce skin-only harvest is likely to be short-term and highly unstable.

Issue 5. Kangaroos as pests

The RLPB has submitted that kangaroos are pests and as such skin-only harvesting would allow landholders to recoup costs of necessary control. We were pleased to see this point come out in the submissions as we suspect that this is the real reason that landholder orientated groups are calling for reintroducing skin-only harvest. However, this does not change our original view presented in the feasibility report for the following reasons:

• The State and Federal governments of Australia do not agree that kangaroos are pests, instead have declared them wildlife and therefore the property of the Crown. As such labelling kangaroos as pests and seeking recompense for their control is not relevant to discussions regarding the sustainable management of the commercial harvest.

• It is important for the defence of the commercial harvest, that the harvest is not supported on the grounds of pest management and that damage mitigation activities and commercial activities are not intermingled on any level. This is because damage mitigation activity is not managed rigorously enough for it be defended at the AAT. If damage mitigation and commercial activity are not kept clearly separated, there is a risk that the whole program will be overturned.

Issue 6. Management of carcass waste The RLPB, NSW FA and PAWD believe that concerns over pest animal access to carcasses can be addressed by management of the carcass waste such as burying, burning or using carcasses as bait for feral animals. The KIAA has submitted that there is potential for negative impact on native species, despite the management activity used. We stand by our original submission in the feasibility report that the empirical evidence that would prove that carcass waste has a positive impact on feral animal populations is not available. Furthermore, we find it hard to conceive of how potentially large numbers of carcasses every night, can be effectively managed from an economic point of view.

If a skin-only harvester takes between 50-100 animals a night as used to be the case in Queensland, this represents far too much meat to be used in baiting programs. Burning and burying this number of animals will very quickly become an economic impost that will not be sustainable for either the landholder or the trapper. Lastly, Department of Environment and Conservation is advised that this type of condition on a licence is, in our view, largely unenforceable and the reality is that carcasses would remain in the landscape to potentially favour feral animal populations.

Issue 7. Limited carcass take and inaccessibility

The RLPB has submitted that skin-only shooting will allow shooting to continue where carcass take is limited or where it is difficult to take the required numbers of carcasses because of inaccessibility. This will in turn increase landholder or trapper viability. We refer to the feasibility report page 32, where we have outlined the views of the kangaroo industry. They have claimed that they can get trappers to anywhere there is a problem with kangaroo numbers, negating the need for this option. We wondered what the RLPB was actually referring to when they are referring to carcass take being limited.

Apart from quota, climatic conditions and market demand, there are no other limiting factors that we can record. If the limiting factor is quota, skin-only harvest will not provide an increase in landholder or trapper viability as skin-only harvest would also be limited. If the limiting factor is the climatic condition, then we refer the reader to Issue 1 above where we have discussed this point. If the issue relates to market demand, it is more likely that market demand will support skin/carcass harvest than skin-only harvest. If kangaroos are inaccessible for skin/carcass harvest then presumably they would be inaccessible for skin-only harvest. Finally, permitting skin-only shooting will not improve landholder or trapper viability if there is no market for the product being harvested.

Issue 8. Review of the outcome of this debate

Both the RLPB and KIAA have objected to the recommendation in the initial feasibility report that suggested that a decision should be made regarding the re-introduction of skin-only harvest and then the debate should be set aside. KIAA have requested that the statement be ‘watered down’. E.A. Systems is an independent private company who was asked to look at a specific set of data, assess the feasibility of re-introducing the skin-only harvest and advise the NSW Kangaroo Management Advisory Panel of the result.

Whilst the company is truly independent of government, it cannot claim impartiality as the principal investigator in this case has a long association with the Queensland Macropod Management Program at a senior level. It is this experience that supports the recommendation that a decision be made and then adhered to with no further discussion at least until there is some change in the status quo. Large amounts of public money, Panel member time and government resources have been expended on this issue to no effect.

The reality is that the argument comes down to landholders and their associated organisations wanting less kangaroos in the landscape and seeing the re-introduction of skin-only harvest as a way of achieving this end, a wholly understandable position from their view point. The opposing side of the argument is supported by industry and ethical considerations of full utilisation of the animal and rational economic analysis that predicts that skin-only harvest will not solve the problem.

As such, it is our belief that consensus on this issue will not be reached unless there is some significant change in the current political, economical, social or cultural factors surrounding the commercial harvest of kangaroos in NSW and therefore we recommend strongly that no further resources are spent endlessly rehashing the same points of view. As such we stand by our original recommendation and refuse to water it down.

Issue 9. Income for landholders and issues of ‘fairness’

RLPB, NSW FA and PAWD all seem to agree that landholders do not receive income from kangaroo harvests on their land and skin-only harvest may be one way this can occur. PAWD suggests that the kangaroo industry is well provided for by landholders. They believe that it is the infrastructure and maintenance of watering points by landholders that support the kangaroo populations and consequently the industry and it is only fair that landholder be given reasonable opportunity to access economic return from the industry they provide for.

We agree that it is the infrastructure and improved nutritional availability in the landscape provided by landholders maintained watering points, pastures and crops that provides for the overabundant kangaroo populations in Australia today. The argument of whether that entitles landholders to the ‘right’ of a return on the subsequent populations is a long and involved one ranging across ethical, social, cultural and legal frameworks and cannot be discussed in full in this document. Our personal opinion is that landholders do not have this ‘right’ at present and that is based on the purely legal interpretation of state level wildlife legislation that suggests that kangaroos belong to the state.

We must also remain mindful that some of these same activities by landholders have also cost the public purse in terms of water and land degradation and losses in biodiversity. Landholders do not currently have to pay these costs unassisted by government and the community at large. Furthermore, there are other ways that landholders can access an economic return from the industry. Landholders have just as much opportunity as any other person to access economic return from the industry at the moment, without skin-only harvest.

A landholder can become a trapper and harvest kangaroos from his own property and other properties. A landholder can if they so desire invest in the industry in other ways, including buying shares in those companies within the industry that have become public. Landholders can, with the support of the fauna dealers, also become a buyer and supplier to processors. Lastly, there is nothing in law that says a landholder cannot charge a trapper for the right to access his property or enter into a deal with a fauna dealer to provide property access fortheir trappers.

Once again, we turn the reader’s attention to the point that introducing skin-only harvest is unlikely to provide opportunities for economic gain for landholders, because there is a small and diminishing market for skin-only products. Any market that does spring up if skin-only harvest is re-introduced is likely to be opportunistic, short-term and highly unstable as stable skin processing members of the kangaroo industry have a clearly stated preference for purchasing skins from carcass processors.

Issue 10. Skin-only harvest may assist in reducing total grazing pressure.

RLPB, NSW FA and PAWD all suggest that skin-only harvest might be a method of reducing total grazing pressure whether overall or when landscapes are recovering from drought.

As we initially suggested in the feasibility study, skin-only harvest will not provide any significant relief from grazing pressure under normal circumstances. The harvest is only 15-17% of animals and is set at a level that will not impact considerably on kangaroo populations across NSW. As such, even with full utilisation of available quota, 83-85% of the population will remain in the landscape. This means that even with full utilisation of available quota, no significant reduction in grazing pressure at the landscape scale is possible through the entire commercial harvest, let alone the tiny proportion that is likely to be taken for skin only. In regards to the suggestion that skin-only harvest will permit landholders to protect themselves from the high total grazing pressure presented by kangaroo populations post drought, we refer the reader to Issue 4 above.

Issue 11. Animals dying in droughts

PAWD and the NSW FA have suggested that skin-only harvest is a better option than large numbers of animals dying in the field during drought situations. We disagree that large numbers of kangaroos dying in drought times is worse or preventable by skin – only harvesting. Climate is the primary limiting factor on kangaroo populations and as the harvest is only 15-17% of the population at best, there will always be large numbers of kangaroos dying when unfavourable climatic conditions occur. It should be noted that kangaroos have probably evolved several of their advantageous adaptations as a result of the boom/bust cycle that occurs in Australia naturally and there have probably always been large numbers of kangaroos dying when climatic conditions swing from favourable to bad.

Skin-only harvest will provide an almost negligible relief to this problem as the numbers will be so small compared to the population. It is also possibly not feasible to take enough animals in the short period of time between when animals become unsuited for carcass harvest and they start to die, to make a significant difference.

Issue 12. Tags for trappers and landholders

This issue refers to a policy decision if skin-only harvest were introduced. PAWD and NSW FA have suggested that should reintroduction occur, tags should be available to trappers and landholders. We agree that tags should be available to trappers, however for administrative and compliance reasons, the animals must be shot by licensed trappers. Therefore landholders would certainly be able to receive the tags, but to use them, they must first become licensed trappers.

Issue 13. How much quota for skin

This issue also refers to policy decisions if skin-only harvest were introduced. PAWD and NSW FA suggest that if reintroduction occurs, the skin-only allocation within the quota should match the average difference between the quota and harvest for the previous 5 years. This could be monitored quarterly and adjusted as market forces and quota utilisation require. At first glance this appears a reasonable way of approaching the issue of if there is an allocation to skin-only harvest, what should that allocation consist of. However, if we use that model in the current situation it would leave the carcass industry with a greater lack of supply than that currently experienced and leave more animals in the field which is counter to the stated interests of landholders.

This is because once the tags were allocated to skin-only, they would not be available to fix to a carcass, therefore that number of animals would become unavailable to the carcass industry despite market forces. Furthermore as there is no market for skin-only products at present, the skins would probably not be taken at all, leaving the animal in the field. The suggestion that quarterly monitoring and adjustments should be carried out will address the issues of allocated but unused tags, however there will be an appreciable delay in making those animals initially allocated to skin-only harvest available for skin/carcass harvest.

Issue 14. Professional attitudes

PAWD and NSW FA have suggested that it is difficult to ascertain that a less professional attitude will prevail in skin only harvesting; Trappers who carry out skin-only harvesting could be required to complete current Game Meat Handling courses and undergo Firearms competency and Accuracy tests; checks and measures in place within the industry should be effective in ensuring the industries high standards are maintained; compliance can be sought from Fauna Dealers to ensure illegal sale and trade in skins doesn’t occur. We agree that it is difficult to prove categorically that a less professional attitude will be displayed by skin-only harvesters in NSW.

Historically in QLD there were harvesters who were skin-only specialists with high levels of professionalism who took great pride in doing things in a law abiding and technically sound manner. Some of these people are still in the industry and still harvesting for skin-only, with skin processors treating them as the exception to their preference to buying from the carcass processing plant.However, the flip-side of the QLD experience (nb: it is the principal author’s experience as Manager of the QLD program) is that providing a skin-only harvest attracts people into the industry in the hope of making a quick dollar, often as there is the mistaken belief that it is possible to make extra money shooting kangaroos without compromising unemployment benefits. This kind of licensee has no intention of following the rules once they are licenced and generally commit offences that include:

• Failure to supply returns

• Failure to complete returns accurately

• Failure to shoot humanely (ie butt-shooting as they are not accurate enough for head-shots)

• Unlicenced shooting (ie shooting on a property not listed on the licence – poaching)

• Selling untagged skins

Harvesters in QLD are required to complete Game Meat Handling courses, firearms competency and accuracy courses and a course showing them how to comply with EPA requirements. This seems to make little difference to the levels of compliance in some sectors of the licensee group. In particular skin-only provides an opportunity for people to enter the industry with very little capital expenditure, and as such, they have no investment either intellectually or financially in supporting the good of the industry as a whole. The suggestion that industry, particularly dealers, can ensure high standards are maintained is true in so far as the dealer can control who they buy from and set the standard of what they will accept as suitable.

However, there is no guarantee that skins will be sold in NSW, as one of the intrinsic problems with having a trade in skins is that they are highly mobile, not obvious and long-lasting without refrigeration. Queensland certainly employs dealer influence to achieve harvester compliance, however it has been found that untagged skins are still bought and sold in Queensland and interstate, in sometimes very large numbers. One of the reasons this occurs is because tanneries are not familiar with the rules of all states, and some tanneries are found in states that do not have a commercial harvest at all.

Therefore they assume that the product they have received complies even though this may not be the case. This does not reflect a lack of will to support the kangaroo industry, but is simply a reflection of the distances and complexities of several states with different requirements and programs.

Issue 15. Industry destabilisation

PAWD and NSW FA believe that the issue that skin shooting has the potential to destabilise the industry is difficult to substantiate and there is no basis for arguing that the re-introduction of skin only harvesting would have an adverse impact on the market or industry. We agree that it is difficult to substantiate that the re-introduction of skin-shooting will destabilise the industry. However we stand by our original statement that it certainly has the potential to do so. We are basing this judgement on the historical case study of the skin market in Queensland destabilising itself in the mid 1990’s to the eventual benefit of the skin/carcass industry. Also personal communication with established and wise leaders of the industry in Queensland revealed concerns that the same destabilisation would be experienced again in the near future.

The reasons why skin-only harvest has the potential to destabilise the industry are: that it is subject to wild fluctuations in demand and supply; the market heats quickly and it is possible to shoot and sell large numbers relatively quickly; skins can be stored therefore processors can buy hard for short periods and then stop altogether; and finally, quality cannot be established until late in the tanning process. Therefore international markets spring up, demand is high, prices go up, animals are shot to the point of quotas closing, quotas are filled with skin-only animals, the product quality is indeterminate and the market can be lost on quality grounds and then the whole thing collapses again. In the mean time, skin/carcass markets are also shattered as the carcass processors have been unable to meet contracts due to a paucity of supply. It is this situation that leads to the massive under utilisation of quotas as experienced in QLD in the late 1990’s and undoubtedly contributed to the highest ever recorded populations in the early 2000’s.

Issue 16. Skin Quality

PAWD and NSW FA have suggested that in relation to issues of poor quality skins, a code of practice for preparation and storage could be prepared. We agree that a code of practice for preparation and storage could be prepared in an attempt to improve the quality of skins and prevent avoidable damage. It must be noted that skins that are salted have lower tear ratings than those that are frozen, even if the best job possible is done with them.

Issue 17. Skin size

PAWD and NSW FA have submitted that the issue of smaller animals being taken is easily overcome by the establishment of a minimum accepted skin size. We agree with this submission and this is certainly what has been attempted in QLD. It should be noted that it is almost impossible to match skin size and carcass weight through the range of condition, age and species size variables among kangaroo populations and there are sometimes strange side effects of setting size or weights. For example, female wallaroos in QLD are rarely shot for skin/carcass as they do not make the weight required.

They are sometimes shot as small skins however as they do meet the skin size requirements. It could be argued that the skin size is obviously too small and should be lifted, however species density interactions could be impacted on by this decision as the females of one species would be completely unharvested, possibly providing a competitive edge over red and grey kangaroos whose females are harvested. Already it is being suggested that the weight requirements for wallaroos needs to be dropped in QLD to allow harvesting of female wallaroos for skin/carcass products as the rate of skin-only harvest is now so low. Processors do not want this to happen however as they pay for the processing of the animal on a per head rather than a per kilo basis, therefore smaller animals are not economical to process.

Issue 18. Remoteness

PAWD and NSW FA have stated that the remoteness of western NSW is an issue As we are unclear on the specifics of what this submission was referring to we cannot respond. If the issue is regarding poor service by the industry because of the remoteness issue, we refer the reader to issue 25 below.

Issue 19. Placement of chillers

The placement of chillers is an issue according to PAWD and NSW FA. As we are also unclear on the specifics of this issue, we do not feel able to respond.

Issue 20. High cost of transport

PAWD and NSW FA believe that the high cost of transport is an issue and skin only shooting will help to reduce transport costs and improve quota utilisation in isolated zones. We agree that the high cost of transport is an issue in the kangaroo industry and likely to cause somerearrangement of pricing structures and operational arrangements after extended periods of high fuel prices. Whether skin only shooting would help reduce transport costs and improve quota utilisation in isolated regions would depend on the scope of the market (we think it would be disappointingly small)and the operational arrangements implemented.

Issue 21. High costs of industry entry prohibitive

PAWD and NSW FA believe that the high establishment costs of trays, chillers, and fuel are a major barrier for landholders accessing the industry. KIAA on the other hand believe that these arguments regarding the prohibitive costs of entering the carcass shooting industry for landholders are a wild exaggeration. They content that most landholders should have 4-wheel drives and rifles for other purposes, and claim that the cost of a rack is only approximately $1000 second hand or can be cheaply fabricated in most station workshops. We accept that the costs of entering the industry including licences, tags, accreditations, equipment, fuel and ammunition are expensive and possibly prohibitive for marginal landholders. However, they are no more or less prohibitive for landholders than for any other potential trapper. In fact, landholders may be perceived as having an economic advantage in that they are close to the source of supply and do not carry the risk of travelling out to a property to find they can not fill their tray on the night.

As previously referred to in Issue 20, high costs of harvest will force a rearrangement of pricing structure and operational management to reduce costs wherever possible. We find it difficult to conceive of how a landholder will defray the cost of entering the industry through shooting skin-only, even without the initial cost of a rack, given that the market for skins is small and likely to be unstable.

Issue 22. Issues of supply

There are insufficient kangaroos available in NSW at present to sustain the needs of the carcass industry and this may not change for some years to come according to the Australian Game Meat Processors Association. We agree with this statement and believe the situation is the same in Queensland. As such even if a decision is made to re-introduce skin-only harvesting, no quota should be allocated as such until the situation settles, possibly not for 4 to 5 years.

Issue 23. Flexible Management

DEC must maintain flexibility in management according to the conditions at the time. If in future years, if markets provided under full utilisation scenarios cannot control numbers and assuming welfare consideration can be addressed, the inherent flexibility of the management guidelines should be maintained to allow skin-only shooting. We agree that an approach of flexible and adaptable management is likely to improve the effectiveness of balancing an overabundant wildlife population, conservation and sustainable commercial harvest. However it must be made clear that DEC is managing kangaroo populations from a conservation perspective and this will always be the case. Also stakeholders must remain aware that to a certain degree, DEC is not in control of the decision making process regarding commercial harvest, as the conditions of the federally administered EPBC Act must be met to provide for export of kangaroo products.

Issue 24. Conservation benefits from skin-only harvest

KIAA has submitted that there is no conservation benefit to kangaroo populations in allowing the reintroduction of skin-only harvesting. We agree that there is no conservation benefit to kangaroos from the re-introduction of skin-only harvest specifically, however there is the ‘long-bow’ argument regarding commercial harvest and conservation. This argument runs along the lines that commercial harvest increases levels of acceptance of numbers of kangaroos in the environment, therefore reducing damage mitigation activities that can be inhumane and damaging to local populations. Therefore commercial harvest results in more humane and less unsustainable killing. Some say this argument is ‘drawing a long bow’.

Issue 25. Poor service in western areas.

KIAA refutes arguments that there are areas of Western NSW that are poorly serviced by the carcass industry. We agree with the KIAA on this point. Western areas of NSW appear to be well serviced, particularly if compared to similar areas in Queensland.

Issue 26. Infrastructure

KIAA has stated that a re-introduction of skin-only harvesting would cause continued investment in infrastructure by carcass processors to be questioned as short term speculative skin only operations become possible. This could result in less quota utilisation than presently the case. Whilst this may be the case, we do not agree that a complete review of the decision to invest in infrastructure by carcass processing companies is necessary. This is because skin/carcass buyers currently have the market share, infrastructure and established trade links that mean they can probably out-compete and even force out any new skin buying trade that tries to establish.

Also licences are limited in NSW, which means the current arrangement of the industry is likely to persist because there is not open access to the licences required to buy direct from trappers in NSW anyway. Should a skinonly market establish however, we concur that this would be a legitimate reason for the skin/carcass buyers and processors to rethink their level of investment and degree of financial exposure in those areas where they would be impacted by unstable and speculative markets. This could result in less quota utilisation than presently experienced as shown by the QLD case study in the initial report.

Issue 27. A strong stable industry

DPI has submitted that it is important that the kangaroo industry remains strong and does not open itself up to destabilisation and further criticism. A risk is that the re-introduction of skin-only shooting would detract from the image of the industry. We agree with this submission on all points.

Issue 28. Compliance

DPI has concurred with the finding of the initial report that skin-only harvests would increase the level of compliance monitoring necessary and reduce the current level of control over animal welfare. We agree with this submission.

Issue 29. A benefit to a few DPI has concurred with the finding of the initial report that skin-only shooting benefits few people (some landholders) and these landholders can with some investment participate in carcass harvest anyway. The report demonstrates that the skin industry prefers to obtain skins from carcass processors and that overall, benefits to landholders would be small and not worth the damage to industry that might occur from opponents emphasising the negative aspects. Obviously we agree with this submission.

Issue 30. Decreases in skin markets

DPI has submitted as a reason for supporting a decision not to introduce skin-only harvest, the fact that the report identifies the declining role of skin-only shooting in Queensland where skin only shooting has decreased to low levels in comparison to carcass shooting. We agree with this submission.

Issue 31. Current program

DPI has offered a statement of support to the current Kangaroo Management Program by submitting that it offers opportunity to minimise kangaroo damage to crops and pastures while maintaining the best opportunities for the long term future for the kangaroo industry. We agree with this submission.

Conclusions:

The authors stand by the original feasibility report in its entirety and can make no new recommendation to the Advisory Panel. It must be pointed out key issues have been ignored completely by landholder affiliated groups and others alike. These issues include the impact of the ‘new activity’ provisions in the EPBC Act 1999 and the political and legal consequences of the reintroduction of skin-only and its likely impact on an Administrative Appeal Tribunal Process.

Furthermore issues regarding the lack of market opportunity for skin-only harvests have been ignored completely by landholder affiliated groups. Some attempt has been made at addressing compliance and administrative issues, however no real suggestions for handling the issues were made by any of the respondents. *End

The full reports (both of them)can be found on the NSW NPWS website here.

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