Regarding the Puckapunyal Military Area, Environmental Management
Plan (February 2003) and our concerns about the plight of the
kangaroo, there are certain deficiencies in the framework of
the plan, which are neglectful of key humanitarian issues concerning
the health and welfare of kangaroo populations that we believe
need to be addressed urgently.
We
believe the key issues we address in this letter should be developed
and incorporated into the present and any future environmental
management plans for Puckapunyal Military Area.
The
2003 Management Plan sets the framework for the sustainable
future management of the PMA that will guide the future use
of the site. The framework itself, is guided by (a) the Legislation
(Environment Protection and Biodiversity Conservation Act 1999);
(b) the Code of Practice for the Humane Shooting of Kangaroos;
and (c) the content of the document itself.
(a)
The Legislation
The Environment Protection and Biodiversity Conservation Act
1999 (the Act) is virtually silent on matters of animal welfare.
The Act facilitates trade in wildlife, but as a legal instrument
for 'protection and biodiversity', regarding animal welfare,
it does virtually nothing to protect our wildlife from cruel
and inhumane treatment. There are only vague references dealing
with acts of cruelty and the use of the clearly ambiguous word
'may' in Section '303GO Regulations relating to welfare, negates
a strict compliance concerning matters of the welfare and protection
of animals (wildlife). The following extract from the Act demonstrates
this point:
"(1)
This section applies to regulations made for the purposes of
paragraph 303CG(3)(c),
303DG(4)(b), 303EN(3)(e), 303FN(3)(c) or 303FO(3)(f)
(2) The conditions specified in those regulations in relation
to a live animal may:
(a) deal with the welfare of the animal:
(i) when the animal is taken; or
(ii) when the animal is being held after it has been taken;
or
(iii) when the animal is being prepared or shipped; or
(iv) when the animal is under the control of the proposed recipient;
and
(b) may deal with eliminating or minimising the risk of:
(i) injury to the animal; or
(ii) adverse effects on the health of the animal; or
(iii) cruel treatment of the animal."
In
effect, compliance on grounds of a humane treatment of wildlife
is arbitrary under the 1999 Act and in practice is non-existent.
The intent of 'protection' under the Act is silent on the humane
treatment of wildlife. Therefore, the 2003 PMA Environmental
Management Plan should not be silent on this matter and should
include practices and procedures for the humane treatment of
wildlife on the Puckapunyal reserve.
We
believe the Act operates to facilitate trade in wildlife for
commercial purposes and we are alarmed and concerned that the
kangaroos on the Puckapunyal Military reserve are targeted as
a renewable resource for future commercial use. Our point is
demonstrated by the media releases, from the Parliamentary Secretary
to the Minister for Defence, when she said of the kangaroos
on the Puckapunyal Army base, "…that they would be
shot as quickly as possible so they could be processed…".
We understand this to mean kangaroos utilised for commercial
purposes.
(b)
The Code of Practice for the Humane Shooting of Kangaroos
The Code of Practice is deficient in terms of the humane treatment
of kangaroos and therefore legally unenforceable in these terms.
There is no policing or monitoring at the point of slaughter
in the field, not only in the act of killing, but in the manner
in which joeys are dispatched. The Code calls for in-pouch joeys
to be wrenched from their mother's pouch and bashed until dead
with a water pipe or iron bar.
The
older but still dependent ex-pouch joeys flee in terror when
their mother's are shot, to die of chilling, starvation, increased
predation, and psychic deprivation. These appalling methods
of dispatching joeys leave a trail of cruelty unacceptable in
a National climate of environmental awareness.
Unless
matters of animal welfare are adequately addressed in the PMA
Environmental Management Plan it must be said that it falls
silent on these important issues of animal welfare. We request
the Environmental Committee urgently consider the following
issues for development and inclusion in the PMA Environmental
Management Plan 2003:
1 Erect Safe Kangaroo Fencing
We
recommend the design and erecting of safe kangaroo fencing to
replace inadequate,
existing sheep fencing.
The
hinge joint/ring lock and barbed wire combination of the original
farm fence is disastrous for kangaroos because they get themselves
hooked on the barbed wire on the top, or get their feet caught
in the gap between the hinge joint and the wire to which it
is attached. This type of fencing is a death trap for kangaroos
and should be replaced urgently.
Safe
kangaroo fencing is a priority in combination with wildlife
corridors.
(2)
Establishment of Wildlife Corridors
We
recommend the establishment of wildlife corridors to enable
the freedom of movement essential to healthy, viable kangaroo
populations. Kangaroo habitat should be opened up on the State
forest side of the Puckapunyal Military Army Base. It is our
aim that connecting wildlife corridors will eventually be expanded
throughout Victoria.
Presently
kangaroos are trapped in small fragmented areas so kangaroo
populations are therefore enclosed and implosive.
(3)
Eradicate Cruelty in 'Culling' Practices
We recommend constant monitoring for the health and wellbeing
of the kangaroos on the Puckapunyal property. If animals are
deemed to be ill, lame, infirm, injured, or diseased, we believe
a Veterinarian should be engaged to administer euthanasia to
alleviate suffering. A Veterinarian must be in attendance to
ensure humane and ethical treatment is provided for the wildlife.
The use of professional kangaroo shooters who would commercially
use the meat and skins from these sick kangaroos is unacceptable
and objectionable.
We
stress that culling take place only after all other avenues
have been exhausted, and we strongly recommend the following
guidelines, which eradicate cruelty in culling practices.
That
any kangaroo cull would ensure that:
1. It is carried out by a credible wildlife control company
accountable for the humane
treatment of all animals.
2. Pouches of all female kangaroos must be physically checked
(not just visually)
because many small 'pinkies' will be missed unless they are
physically checked.
3. Joeys are handled (meaning humanely euthanased or saved to
be reared by wildlife carers) by the attending Veterinarian.
It is an unacceptable and inhumane practice that under the Code
of Practice joeys can be dispatched by a sharp blow to the head,
such as a water pipe or iron bar, until dead.
4. An RSPCA Officer/Inspector is in attendance at all times
and at each incident.
5. It is fully, and openly accountable to the public by the
Department of Defence.
(4) Removal of Introduced Grasses
We
recommend the removal of introduced grasses and replanting with
stable plant
communities dominated by native plants that are healthy and
palatable for kangaroo populations.
The
kangaroos' native grasses have been reduced by the invasion
of introduced and exotic
grasses. The provision of suitable native grasses would not
only be best for native kangaroos but also would remove the
need for introduced livestock.
The development and implementation of humane animal welfare
policies for the kangaroo population of Puckapunyal are urgently
needed and in this regard the PMA Environmental Management Plan
should reflect best practice standards.
We
welcome the recommendation contained in the Environment Management
Plan that stakeholder consultation will take place as part of
the process of development. As wildlife management is of public
interest, this is a sensible recommendation and we therefore
look foreword to your advice as to how we can not only obtain
the Environment Management Plan but also be part of the consultation
process.
We
have news of a recently retired, local Seymour Veterinarian,
who has extensive wildlife knowledge and who may be in a position
to oversee the welfare of the wildlife on the Army Base. We
are pleased to recommend him to you.
We hope that the above suggestions will help to ensure healthy
and viable populations of kangaroo on the Puckapunyal Military
reserve and look forward to your reply.
Sincerely,
Maryland
Wilson
President
Australian Wildlife Protection Council and
Member of the NSW Kangaroo Management Advisory Committee
This
letter is a collaborative effort by Members of the Australian
Wildlife Protection Council.
Anne
Frazer
Research
Rheya
Linden
Media Liaison
