National Farmers Federation. Submission to the. National Codes of Practice for the Humane Control of Invasive Animals.

Transcription

1 National Farmers Federation Submission to the National Codes of Practice for the Humane Control of Invasive Animals 11 February 2011 Page 1

2 Member Organisations Page 2

3 Contents 1. The National Farmers Federation Introduction Pre-emptive decision making Discontinuation of Control Methods Aerial Baiting Research & Development Model Codes of Practice Conclusion NFF Contact Page 3

4 1. The National Farmers Federation The National Farmers' Federation (NFF) is the peak national body representing farmers and, more broadly, agriculture across Australia. It is one of Australia's foremost and respected lobbying and advocacy organisations. Since its inception in 1979, the NFF has earned a formidable reputation as a leader in the identification, development and achievement of policy outcomes - championing issues affecting farmers and dedicated to the advancement of agriculture. The NFF is dedicated to proactively generating greater understanding and better-informed awareness of farming's modern role, contribution and value to the entire community. One of the keys to the NFF's success has been its commitment to presenting innovative and forward-looking solutions to the issues affecting agriculture, striving to meet current and emerging challenges, and advancing Australia's vital agricultural production base. The NFF's membership comprises of all Australia's major agricultural commodities. Operating under a federated structure, individual farmers join their respective state farm organisation and/or national commodity council. These organisations collectively form the NFF. The NFF recently implemented a re-structure of the organisation. An associate member category has enabled a broader cross section of the agricultural sector to become members of the NFF, including the breadth and the length of the supply chain. Each of the state farm organisations and commodity council s deal with state-based 'grass roots' issues or commodity specific issues, respectively, while the NFF represents the agreed imperatives of all at the national and international level. 2. Introduction The NFF welcomes the opportunity to make a submission to the Regulatory Impact Assessment (RIS) for National Codes of Practice (COP) for the Humane Control of Invasive Animals. Moreover, NFF notes that this submission post dates the conclusion of the consultation period and thanks the Federal Government for bringing this to the attention of the NFF. NFF notes that the proposed codes of practice are for foxes, rabbits, feral pigs, feral goats, feral horses, feral cats and wild dogs. Moreover, the NFF notes that National Model Codes of Practice will require the discontinuation (or banning) by 1 July 2013 of toothed steel-jaw traps (rabbit, wild dog, fox and feral cat control), strychnine baiting (fox and wild dogs), chloropicrin fumigation of rabbit warrens, and warfarin and yellow phosphorous (feral pigs). NFF supports mechanisms that reduce the pain and suffering of invasive animals or non-target species. However, in some cases, there remain gaps in the replacement options for some of discontinued practices or, in the case of strychnine, a potentially slower death and increased suffering under some circumstances from the replacement chemical The mammalian pests that are the subject of these codes can, and do impose major burdens on the environment, including on our native animals, as well as on agriculture. The control of pests in Australia is a significant burden on farmers and governments alike. According to the Bureau Page 4

5 of Rural Science, 80 introduced pest animal species have become established pests in Australia 1. Of these, some 30 of have become significant agricultural pests (foxes, rabbits, pigs and cats) 2. Importantly, no established pest has been eradicated on the mainland 3. The Bureau of Rural Sciences 4 (BRS) estimates the direct cost of control to be $420 million (conservatively), with this figure excluding social and environmental costs as well as ecosystem degradation 5. In 2004, the Animal Control Cooperative Research Centre attempted to quantify the cost and estimated a conservative $720 million per annum 6. In 2009, the Federal Department of Agriculture Fisheries and Forestry estimated the cost (management, administration and research) to agriculture from feral pests (wild dogs, rabbits, foxes, pigs, birds and mice) was approximately $745 million. The major impacts include: competition with livestock and wildlife for resources (food, water, shelter, breeding sites) predation on stock and native wildlife damage to grain and horticultural crops soil disturbance and general land degradation damage to fences and water sources, and biosecurity risk for potential transmission of diseases to livestock and wildlife 7. Due to the difficulty in eradicating pests, effort should be focused on effectively managing pests (including limiting the spread of existing pests) and preventing the introduction of new pests into Australia 8. It is on the former that NFF and its members have focused their efforts. While the drafting of national codes of practice may not be controversial (i.e. as these ensure consistent approaches to management across jurisdictions), the removal of control methods is often met with concern for a number of reasons, including the lack of a viable commercial replacements that are readily available and cost effective. 3. Pre-emptive decision making NFF notes that the development of these codes and the proposals to phase out some practices has been underway for several years and that this may have resulted in jurisdictions pre-empting the codes and introducing changed practices. NFF members have commented that changed practices have been imposed, for example, the restrictions have already been imposed was the response from one state farming organisation. It is for this reason, that NFF remains sceptical regarding the outcomes in Table 2 (RIS, p ). A comparison of jurisdictions practices that pre-date 2007 and the reasons for changes are appropriate. This will determine if the current practices are pre-empting the codes or were factually based internal jurisdictional decisions to change the regulatory policy BRS, Australia s Pest Animals: New Approaches To Old Problems, Science for Decision Makers DAFF, Australia s Agriculture, Fisheries & Forestry: At a Glance. Available: data/assets/pdf_file/0003/ /aag-2010.pdf BRS, Australia s Pest Animals: New Approaches To Old Problems, Science for Decision Makers 4 Now merged with ABARE to become ABARES. 5 Ibid 6 Ibid BRS, Australia s Pest Animals: New Approaches To Old Problems, Science for Decision Makers Page 5

6 NFF recommends that an additional Table is inserted which shows a comparison of predevelopment of the codes with current practice to determine what jurisdictions and what control methods have been pre-emptively targeted ahead of approval. 4. Discontinuation of Control Methods According to the Australian Vertebrate Pests Committee, the following are the nationally significant invasive animals: Feral pigs Sus scrofa Feral goats Capra hircus Rabbits Oryctolagus cuniculus Foxes Vulpes vulpes Common carp Cyprinus carpio Cane toads Bufo marinus Common starlings Sturnus vulgaris Feral cats Felis catus Wild dogs and dingoes o Canis lupus familiaris; o Canis lupus dingo and o hybrids Feral deer species o Fallow Dama dama o Red Cervus elaphus o Sambar Cervus unicolour o Rusa Cervus timorensis o Hog Axis porcinus o Chital Axis axis If Table 2 in the RIS is taken as a reflection of current practice, then it would appear that Queensland is the state with least compliance with the agreed inter-jurisdictional position as this state still uses four out of the five control methods. In terms of the practices, chloropicrin remains relevant to five jurisdictions, followed by unmodified traps (three jurisdictions). Moreover, some of the practices are allowed but have certain restrictions, for example, restricted to specific areas within the state, or for specific animals. There are also concerns, for example if strychnine is banned for baiting, how long before it is banned for use on modified steel traps? This is particularly the case if this is about the humane treatment of pest animals. As observed by one member, strychnine results in a quicker death than other controls methods. As a result, it is well regarded by farmers. Regardless of the outcome, NFF agrees that there is an ongoing need to develop improved control techniques that address efficacy, specificity, safety and humaneness requirements. This needs to be supported by education that informs the public about the need for pest control and encourages pest managers to implement control according to public expectations. Moreover, farmers note that in many cases, the replacement options for banned control methods are often: Page 6

7 Less than optimal; Expensive; Not as widely available; Where good replacements are available, they may still be undergoing testing for the optimal dispensation methods, or it may not yet be registered for use. For some particular pest species, the availability of control techniques that are economically, environmental and socially acceptable is far from satisfactory. Therefore, simply banning existing methods, while these may not be socially acceptable, without viable and cost effective replacements is not supported. This issue relates as much to the management of pests on private land as well as public land. One of the five most contentious issues about farms neighbouring public land is the lack of control of pests harboured on public lands. Consideration must be given to how best to control pest animals on public lands. A further issue of concern is how to manage incursions that rapidly increase, for example an explosion of rabbits due to good feed and breeding conditions. Importantly, in recent years, farmers have learnt a lot about working together to reduce predation by foxes rather than acting alone. NFF notes that the most useful pest animal control methods are: killing or removal (e.g. baiting, shooting, trapping or mustering); exclusion (e.g. fencing or netting); biological or fertility control; habitat manipulation (e.g. removal of surface refuges); and changes in land use including agricultural practices (e.g. timing of lambing or planting different crops). NFF notes that where a choice of methods is available, there needs to be a balance between efficacy, humaneness, community perception, feasibility and emergency needs. Important for a farmer are the resources at his disposal in which to undertake control actions (time, money, labour, equipment). Farmers will also use a range of options, for example, exclusion of rabbits is not cost effective but burrow destruction/removal of surface refuges may well be the most optimal solution. It is for these reasons that the removal of existing control methods brings significant concern, as well as the removal of control options pre-emptively. NFF Members have noted that the recent removal of control options in some states was imposed. Comments by Members about the banning of control methods can be best summed up in the following comments:...the restrictions have already been imposed, not that we like them. Before any method of control is banned there needs to be some form of (viable) replacement control measure....are obviously wary of additional regulations being applied which could further constrain the ability of farmers to adequately control invasive species on their property. many [farmers] do state that this control method [strychnine] was very effective Page 7

8 it is of concern that [public land managers] will have to cease the use of this [Chloropicrin] fumigation method by would be concerned if this method of control [Chloropicrin] was phased out before an equal alternative was available. We would be more comfortable if this method was still possible under controlled use until a suitable alternative was made available. [use of] padded steel jaw traps...needs to be maintained. the right to use a foot trap which has had the jaws bandaged and treated with a toxin (traditionally strychnine) should be retained...as a means of removing individual problem dogs. peri-urban and selected trap application of strychnine should only be fully banned once PAPP is actually registered and available nationally. In the event of an exotic disease outbreak requiring the regional removal of all feral pigs then every means of elimination must be available to authorities. It might be sensible to retain Warfarin and CSSP for the emergency use of state authorities. Pigs easily learn to avoid baits and will no doubt condition to avoid the limited range of commercially manufactured products once they are in more widespread use. The sodium nitrite toxin in Hog-Gone is yet to be tested widely in the field and landholders and authorities must retain speed and flexibility in the means to deliver an effective toxin if required. Recommendation i. Prior to the banning or removal of any pest animal control method, that Governments ensure viable and cost effective replacement options are available. 5. Aerial Baiting NFF s members have expressed some concern about 1080 aerial baiting. Members have noted that while there is a potential risk that there is some danger to non-target species from the use of 1080, a number of studies have shown that the impact on native species (namely the spotted tail quoll) is minimal. It must be stressed that where aerial baiting is utilised, it is done in a strategic manner where there is a demonstrated necessity for baiting, not simply applied across large areas of the landscape. In some states, Members are actively lobbying for the State to take up aerial baiting of wild dogs and foxes to be part of a comprehensive program including ground baiting, trapping and other on-ground management activities. There is a perception that aerial baiting is simply the broad scale application of baits from helicopters across vast areas of land. Members understand that this is not the case, but it is difficult to dispel that rumour within environmental circles. It is very important that the strategic nature of aerial baiting is conveyed and supported by research on the impacts of this form of baiting on non-target species. 6. Research & Development BRS advises that there are a number of impediments to effective pest animal management control, including: Page 8

9 The lack of cost-effective, safe, target specific and relatively humane control techniques for some species; Poor implementation of existing techniques, or poor coordination between land managers for controlling mobile pest species that readily cross property boundaries; Inadequate consideration of the population dynamics of the pest species, resulting in rapid recovery of pest population between control events; Landholders may lack time, money, knowledge, expertise, equipment or interest, or may rely too heavily on silver bullet solutions (e.g. rabbit haemorrhagic disease and immunocontraception; and The fact that Australia is large and sparsely populated limits resources for pest management, particularly in the rangelands n the potential conflict between commercial use versus control 9. Moreover, the research challenges are: better understanding costs of environmental impacts; addressing all pathways of introduction and spread; understanding changes in risk posed by pest animals due to climate change; and continuing to provide improved methods and knowledge for optimising pest animal management; In terms of extension (i.e. education/training), the challenges are: improving awareness of problems and solutions, including improving knowledge of pest species distribution, ecology and impacts, and developing alternative management techniques; ensuring the availability of training for those involved in pest management; greater acceptance of stakeholders perceptions, responsibility and priorities for pest animal management; and acknowledging the benefits provided by pest animals as well as their costs 10 The NFF is concerned about inadequacies in funding for management of pest animal issues by Governments. These concerns relate to the quantum of funding and its distribution. A substantial investment by the Australian Government into programs to eliminate wild dogs, feral pigs, rabbits and foxes is urgently required. Recommendation ii. That there is significant investment in replacement control options, including dispensers where appropriate, through appropriate research, development and extension. Minimum Bait Rate Research One of the major issues in wild dog control has been the Australian Pesticides and Veterinary Medicines Authority s (APVMA) demand for the minimum bait rate research. At this stage, the only willing participant to commit funding has been Australian Wool Innovation (AWI). It is very important that the government commit more funds to this research, as the main research item BRS, Australia s Pest Animals: New Approaches To Old Problems, Science for Decision Makers 10 Aust pest animal strategy Page 9

10 7. Model Codes of Practice The NFF in principle supports the introduction of the National Codes of Practice for the Humane Control of Invasive Animals, as the harmonisation of Codes of Practice across all States and Territories will ensure that all jurisdictions have the same compliance and confer similar obligations on any person operating within the area of applicability. This will achieve a better outcome in addressing Pest Animal Control throughout Australia. However, the NFF notes that there has not been any mention of the welfare of livestock preyed upon by pest animals in the code. The inhumanness caused, for example to domestic livestock by wild dog predation is horrendous especially the damage and eventual death of ewes, lambs and young calves. The need to take account of animal welfare impacts of attacks on livestock has been recognised by various animal welfare organisations. The proposed National Model Codes of Practice for the Humane Control of Invasive Animals (COPs) include agreed best practice procedures for the humane control of rabbits, foxes, wild dogs, feral pigs, feral cats, feral goats and feral horses. Humane Vertebrate Pest Animal Control (page 4) is defined as the development and selection of feasible control programs and techniques that avoid or minimise pain, suffering and distress to target and nontarget animals. Humaneness should not be looked at in isolation. In any humane control of invasive animals, there is a need to balance humaneness against efficacy and therefore suggests that the selection of the most appropriate vertebrate pest control technique requires consideration of both humaneness and efficacy. For instance in relation to humaneness and efficacy the joint workshop organised by RSPCA Australia, Animal Welfare Science Control and Vertebrate Pests Committee 11, generally agreed that decision-making concerning the continued use or specific need for using particular techniques cannot be based upon humaneness alone. In the absence of a humane alternative, especially in the face of a valid need to address high priority needs, a technique that is considered to have poor humaneness may be justifiable if it has high efficacy. On the other hand, some techniques that are considered humane may have low efficacy and cannot therefore be justified in any circumstances where desired objectives cannot be met. Thus contrary to the arguments against the use of Sodium Fluoroacetate (1080) the above no doubt gives justification for the continued use of 1080 for the control of wild dogs. Currently the use of 1080 for the control of wild dogs, provided the bait material, correct toxicant loading (including injection of 1080 into the bait rather than surface coating), placement of baits, and timing, coordination and area of baiting is carried out correctly, it has proven to have a higher efficacy than other humane alternatives such as M44 ejectors. National Parks and Wildlife Service news release of 5th October 2010 titled New tool in battle against feral dogs and foxes highlights the success of M44 ejectors technique on the basis of some field trials. While the introduction and use of any new technique that will effectively 11 A National approach towards humane vertebrate pest control, Discussion paper arising from the proceedings of an RSPCA Australia/AWC/VPC joint workshop, Melbourne, 4-5 August 2003, p. 12. Page 10

11 control the wild dog attacks is welcome, it may be premature to claim a high success rate in controlling wild dog attacks by the use of M44 ejectors, as they have been proven ineffective by experienced pest animal controllers. Specific Comments on Control Techniques in the Model Code of Practice for the Humane Control of Wild Dogs Exclusion Fencing The code highlights that the use of exclusion fencing is generally regarded as a humane, nonlethal alternative to lethal control methods. However, exclusion fencing does not actually reduce wild dog population. It merely deflects an ever-increasing number of dogs into another area of private grazing land. Use of Sodium Fluoroacetate (1080) in Fresh Meat Bait It has been argued that the use of 1080 is a threat to non-pest wildlife species. The use of 1080 in fresh meat bait is very target specific. The 250-gram bait is too large for small lizards, birds etc to consume, or contact the 6mg dose injected into the centre of the bait. Goanna s are not affected, and research has established that quoll numbers increased with aerial baiting reducing the numbers of wild dogs. However, the code does not mention the advantages of the use of 1080 for the control of wild dogs. Public Land Management A major concern for farmers is the impact of public land management on private lands, including those land and specific paddocks that abut public lands. NFF have raised the concerns of private land managers in terms of weeds, pests, disease, fire and fencing from public land management. Therefore, it is unacceptable for farmers to forego the use of adjoining paddocks to run livestock due to for example, wild dog predation. Public land managers have a moral duty to contain and control their invasive pest animals. It has been proven along the Great Dividing Range in NSW that a nil tenure, coordinated and integrated system of strategic aerial 1080 baiting and trapping by experienced pest animal controllers, is the most effective and practical means of wild dog control. Wild dogs may also have a positive environmental impact. For instance, where landowners have managed to reduce wild dog numbers in adjacent public land by strategic aerial baiting, they have seen a marked increase in wildlife numbers. It is therefore imperative that before any of the current methods of pest animal control is banned through the introduction of the Code, farmers need to be assured that a wide range of cost-effective methods are available and that barriers to effective pest animal control are minimised as far as possible. The NFF notes that no single control technique is likely to be effective in isolation, and farmers therefore need access to a range of methods. 8. Conclusion There is a need for effective, long-term strategies for pest animal control since many pest animal species are already established in various regions of Australia. While the eradication of exotic Page 11

12 pests is the optimal outcome to deal with pest animals, it is recognised that this will not be a feasible alternative for many species. Pest animals continue to be a problem because of reintroductions, edge effects and imperfect control operations. Such being the case perhaps the best that can be achieved is for low concentrations of pest animals to be sustained over large areas of management. Significant economic and environmental outcomes can be achieved by substantial reductions of pest animals in local areas. Pest animals are one of the most serious issues currently facing Australian farmers. Wild dogs, feral pigs, foxes, rabbits and many other pest species have a tremendous impact on agricultural industries, both in lost production and control costs. Pest animals also affect the environment, competing with native species, destroying native plants and causing land degradation. Approaches to managing pest animal problems currently vary across state and territory jurisdictions, making coordinated cross-border control difficult. Hence, a national approach to the pest animal problem through the National Codes of Practice for the Humane Control of Invasive Animals is a step in the right direction. However, effective humane control of invasive animals requires integration of different methods; any single technique used in isolation is less effective than two or more techniques carefully combined. When reliance is placed on only one technique and follow-up control is not implemented, initial gains are lost, as invasive animals will readily recolonise in the absence of further control. The degree of inhumaneness suffered by domestic livestock on one hand and the wild dog and other invasive animals on the other can be tempered by sensible planning and professional conduct of all parties involved. Finally, an increased effort in research, development and extension is needed, particularly with reviews on the appropriateness of some control methods leading to the withdrawal of some methods. Viable, effective and efficient replacements must be available prior to withdrawing the use of methods deemed now to be unsuitable. NFF Contact Deborah Kerr NRM Manager Ph: Fax: dkerr@nff.org.au Page 12