The Tasmanian Conservation Trust (TCT) wishes to provide an additional submission to the House of Assembly Select Committee on Firearms Legislation and Policy. The TCT made a submission to the previous Legislative Council Select Committee – Firearms Law Reforms Inquiry and I understand that the House of Assembly Select Committee has been provided with a copy of that submission.
In this submission I wish to build on the arguments made in the earlier submission.
While the TCT understands that the State Government has abandoned its 2018 state election policy on firm arms we remain concerned that the state government is committed to the goals of that previous policy, in particular, the widening of the eligibility for category C licenses and sound suppressors. Indeed it seems that the establishment of this committee is for the purpose of justifying these changes to firearms legislation. I intend to dissuade the state government from this course of action.
The primary argument I will make is that no evidence has been provided by the state government or other stakeholders to show that increasing the number and type of people who are eligible for Category C licences and sound suppressors will significantly improve the effectiveness, efficiency and humaneness of browsing animal control. Also, no evidence has been provided to show that current control measures, where they are properly applied, are not sufficiently effective. Furthermore, it has not been shown that applying other new control measures may be far more effective that expanding the use of category C firearms.
This submission will add to the TCT’s earlier submission by:
- Making comment on the DPIPWE Annual Statewide Spotlighting Surveys 2017-18 in relation to browsing animal abundance.
- Comment on the critical findings of the Alternative to 1080 Program in relation to measuring pasture/crop loss and not animals shot or observed.
- Review information from the Department of Primary Industries, Parks, Water and Environment (DPIPWE), in particular, the browsing animal management toolkit generated by the Alternatives to 1080 program.
- Summarise the Alternative to 1080 Program trial findings on sound suppressors.
- Review the submissions and presentations made to this committee by some groups advocating for changes to legislation regarding category C firearms and sound suppressors;
By way of review of the TCT’s earlier submission, we referred to our attempts after the state election to obtain evidence that the Liberal Party may have used to justify its election policy on category C firearms and sound suppressors. We asked the Minister for Primary Industries in two letters what evidence there may be that these changes would improve browsing animal control and are they preferable to current or alternative control measures. At the time of making that submission we had received no such evidence. Rather bizarrely, our requests to the Minister for Primary Industries and Water Guy Barnett regarding browsing animal control were forwarded to the Minister for Police Michael Ferguson for a reply. Not only has there not been a reply to date by any minister but it seems strange that the minister for primary industries would defer to the police minister on matters related to browsing animal control.
Abundance of browsing animals in Tasmania - DPIPWE Annual Statewide Spotlighting Surveys 2017-18
It is disappointing that none of the presenters that I have reviewed have made reference to the key dataset on browsing animal numbers across the state, the DPIPWE Annual Statewide Spotlighting Surveys 2017-18. I also note that the committee has not as yet had DPIPWE Game Management provide evidence.
Critically the report ‘DPIPWE Annual Statewide Spotlighting Surveys 2017-18’provides long term trends for the key browsing animal species in seven regions of the state as well as showing recent changes.
I note from the basic analysis provided in the table below that on the long term:
- Brush-tailed possum have declined across most of the state but have had a slight increase in the northwest and King and Flinders Island;
- Pademelons have decreased across some regions and had only a slight increase across the rest of the state;
- The biggest long term upward trend is with Bennetts wallabies, where there has been an increase (slight, moderate and high) across all regions except the central region.
Note: the report states that regional densities are more reliable to statewide densities.
It should also be noted that these findings do not necessarily correlate with level of browsing damage. But they do provide objective information to contrast with many subjective observations and qualitative surveys of landowners that have been reported to the committee.
DPIPWE Annual Statewide Spotlighting Surveys 2017-18 – TCT summary of finding
Effectiveness is measured in terms of pasture/crop loss and not animals shot or observed
A number of research projects reported in the ‘2011 Final Report Alternatives to 1080 Program’, emphasised the need to monitor actual loss of pasture or crops and to not rely on spot light surveys to determine number of animals remaining. Spotlight surveys are not an accurate means of determining densities and their impacts at a particular time.
More critically, the research shows that the relationship between abundance of a browsing animal and pasture loss is not a direct or linear relationship. The report states that culling may have to reduce numbers of browsing animals to very low levels to deliver any significant benefit in terms of pasture or crop protection and if shooting or other controls are not reaching this density then the effort and funds are wasted.
This finding supports the need for monitoring of impact of browsing on pasture or crops in order to deter mine if control measures are working. In the absence of monitoring, it cannot be determined if currently applied control measures are being effective or not. I note that no representator to this committee has provided any such evidence.
Given that primary producers and professional shooters have access to Category C
Firearms and professional shooters may obtain approval to use sound suppressors, it begs the question why a trial using them has not been undertaken to support the need for their wider use?
Alternative to 1080 Program findings on sound suppressors
DPIPWE’s Alternative to 1080 Program funded a sound suppressor trial and the findings are contained in a report ‘Trials into the use of firearm sound suppressors for browsing animal control in Tasmania’, August 2011.
The trial involved the use of a .22 calibre rifle fitted with a sound suppressor.
The results include:
- ‘The value of using this technology for control of bennets wallaby is limited due to the need for close range shooting’.
- ‘a number of fear cues (such as vehicle noise, spotlights, footsteps, human smells or the sound of a bullet impacting) can cause a flight response, so the use of firearm sound suppressors alone is unlikely to increase shooting efficiency over the longer term. Therefore to maximize the benefits of sound suppressors they need to be used as part of an integrated control strategy using a variety of approaches and varying the way they are used; for example, alternating the use of white and red spotlights, using different vehicles when shooting and shooting at different times of the night.
- ‘Only 40 grain, sub-sonic .22 calibre ammunition should be used for the shooting of wallabies, with a sound suppressor.’
It note that centerfire rifles were not used in the trial, although this would have provided a longer range, because of the cost and limited availability of ammunition required for this type of firearm and other operational limitations that are detailed. One of the category C firearms that advocates want greater access to is a centrefire rifle. This type of rifle would seem to have little applicability in conjunction with a sound suppressor.
The report identifies serious limitations to the use of sounds suppressors but it has not been addressed in representations I have reviewed. A number of representors including the TFGA made reference to a report on the use of sound suppressors undertaken in NSW but did not refer to the outcomes of the earlier Tasmanian study
DPIPWE’s game management programs and toolkit
Based on the findings of the Alternatives to 1080 program DPIPWE and TIAR have developed a range of guides and tools to assist landowners in managing browsing animals, including:
- Managing Browsing Wildlife – Toolkit;
- A range of guides to fencing to control browsing animals;
- Guides to effective shooting;
- The BITE, a computor based system to model the losses caused by browsing animals.
I have recently received feedback from DPIPWE regarding these tools and how they have been applied. There has been a high take-up by farmers of these publications and DPIPWE departmental browsing animal management officers have been able to provide support to implement these tools via field days and property visit etc.
However, there have not been resources to monitor whether these tools and advice have been implemented and if so whether they have been effective. There is informal feedback from landowners but no systematic way to capture it and report on it.
There is very consistent informal feedback shows that farmers understand the limitations of shooting, in particular gun shyness, the skepticism of fencing is less common and farmers know of the need for multiple tools.
Traps and repellants are not used by farmers, but are limited to plantation forestry.
Some farmers and graziers monitor browsing damage but their is no compilation of these results that I could determine.
There has been a reduction of property-based management plans.
It would appear to be very beneficial to undertake a review into the level of implementation by farmer and graziers of the DPIPWE browsing animal toolkit and where they are implemented an assessment of the effectiveness for controlling browsing animals.
Submissions and presentation by the Tasmanian Farmers and Graziers Association
Position on category C forearms and sound supressors
The TFGA provided a written submission to the Legislative Council Select Committee – Firearms Law Reforms Inquiry dated 3 August 2018 and another to the HoA Committee dated 26 October 2018. Both submissions appear essentially the same. The TFGA also made a presentation to the Committee on 10 December 2018.
The TFGA written submissions do not state support for the extension of eligibility for owning and using sound suppressors to ‘agents’ of primary producers, stating only that they should be able to be owned and used by primary producers. I could not find any statement of support in their presentation to the HoA Committee.
Both written submissions by the TFGA contain just two sentences, in seven page submissions, stating their support for an extension of the eligibility for owning and using category C firearm licences to contractors and agents of primary producers for ‘standard crop protection and pest control purposes’(page 6 in both submissions). There is no evidence provided that this change would have any benefit for control of browsing animals and pests other than saying that these are ‘tools fit for purpose’.
At the HoA Committee hearing on 10 December 2018 the TFGA did not state its support for extending eligibility for Category C firearms to include contractors or agents.
Given that the TFGA did not state its support for these two changes when they presented to the committee, it makes me think there are other changes to firearms legislation and policy that are a far higher priority, that may not be related to browsing animal control.
The TFGA made two submissions and had considerable time at the committee hearing but did not provide any evidence that the proposed changes to category C firearms and sound suppressors would benefit browsing animal control.
Impact of browsing animals and management methods
The TFGA written submissions rely on very old information about the impact of browsing animals on primary production: mainly referring to reports produced as part of the Alternatives to 1080 Program dated 2010 and 2011 and some studies that are much older.
The TFGA relied on two surveys of members (birds in 2016 and browsing animals in 2018) as evidence of recent impacts of browsing and other problem species. I assume that these were opt in surveys, which is a method that does not provide a representative sample. With such surveys it is expected that more people with a problem will participate that those who do not. While some farmers do monitor browsing damage systematically the survey results would seem to be largely opinion e.g. asking ‘what animals causes the most damage?’.
The TFGA written submissions provide no evidence of the effectiveness of control methods being used by farmers, reporting only on the survey found what were the most common control methods.
In both the submissions and presentation there is no reference to the critical findings of the Alternatives to 1080 Program (outlined above) in regard to the need for monitoring of actual pasture or crop loss and the possibility that browsing animal numbers may need to be reduced to very low levels, rendering many shooting programs ineffective and a waste of resources.
The Alternatives to 1080 Program led to many changes to our understanding of browsing animals and how they are managed. The program concluded with the development of numerous management guides and tools which DPIPWE advises have been enthusiastically taken up by primary producers. Some of these documents were tables by the TFGA but there was no attempt made to comment on their application and effectiveness.
The TFGA was asked several times to provide evidence regarding the effectiveness of current management methods but failed numerous times to answer. At one point Mr Skillern asks the question himself but does not answer it. He asks ‘are the current set of tools adequate enough’ but doesn’t answer it, other than referring to reports tabled and that there is need for a range of methods. Finally he states that ‘current tools and mechanisms available to us are not adequate’ but provided no evidence.
Mr Jones addresses the limitations of recreational shooters stating that many farmers want them to have their own insurance and work within the demands of farm management.
Mr Jones makes the case that semi automatic shot guns are essential for control of certain birds but he does not suggest that volunteers would help farmers cull birds using these firearms. Neither Mr Jones or Mr Skillern supported the right of recreational shooters to have access to Category C firearms.
In their submissions and presentation the TFGA supported the use of sound suppressors for browsing animal control. While they tabled a report from NSW that supports the use of sound suppressors in animal control they did not address the findings of the Alternatives to 1080 Program Tasmanian trial of sound suppressors and their limitations. The trial found that sound suppressors are unsuited to rimfire rifles (one of the category C firearms), that they are not recommended for use in controlling bennetts wallaby and that a number of fear cues can cause a flight response and reduce the effectiveness (see above for more detail).
Response to the TFGA
In summary the TFGA:
- Has not supported extension of eligibility for owning and using sounds supressors to agents or contractors of primary producers (which would include recreational shooters).
- Did not state their support for an extension of the eligibility for owning and using category C firearm licences to contractors and agents of primary producers when it presented to the committee and made only a cursory mention in its two submissions.
- Did not provide any recent quantitative evidence in regard to the impact of browsing animals on primary producers.
- Has not provided any evidence that the proposed changes to category C firearms and sound suppressors would benefit browsing animal control.
- Provided no evidence of the effectiveness of control methods being used by farmers.
- Did not provide any assessment of the level of application and effectiveness of the DPIPWE management guides and tools despite tabling them.
- Did not address the findings of the Alternatives to 1080 Program Tasmanian trial of sound suppressors and their limitations.
Given the cursory manner in which the TFGA supported extension of Category C eligibility to recreational shooters and its failure to support extension of eligibility in relation to sound suppressors, it may be concluded that the farming lobby sees little benefit for them in such changes.
Given the absence of evidence provided by the TFGA in relation to the impact of browsing animals and the potential benefits of extending the eligibility of category C firearms to recreational shooters, the Committee should conclude that no such evidence currently exists.
Rather than rush to change the law in relation to firearms the TCT urges the Committee to support my earlier recommendation to support a study into the level of implementation and effectiveness of currently applied browsing animal management methods.
That the Committee seek additional expert advice in regard to the potential for sound suppressors to assist with browsing animal management.
Presentation by Matt Allen, Tasmanian Deer Committee
Mr Allen focused a lot on the advantages of sound suppressors and claimed that they ‘would help take more wildlife’. As with the TFGA, Mr Allen did not refer to the limitations of sound suppressors.
Mr Allen argued that sounds suppressors would allow culling without disturbing residents. The committee did not explore the potential negative side of shooting in close proximity to houses i.e. residents may not know shooting is occurring and be at greater risk. The Committees did not ask questions about how common shooting in these circumstances might be - I assert that it is uncommon given that most grazing occurs on large rural properties.
Mr Allen said that he and his association’s members only hunt for deer and shoot wallabies to please the farmer and that he only shot where the deer were. Given the large number of licenced deer shooters in Tasmanian this statement should be explored further by the Committee. Mr Allen suggests that most recreational shooters are not necessarily shooting where the browsing animal problem is the greatest and that shooting wallabies is not part of any considered and planned culling operation.
Presentation by Mr Donald Riddell, Sporting Shooters Association of Australia
When asked about the concern that many thousands of recreational shooters might get access to category C firearms Mr Riddell said that probably ‘under 100’ of his association’s 5000 members would probably want to obtain a Category C licence. He raised issues to do with cost of the firearms, cost of the licence and need to upgrade the storage facilities and install alarms.
If this is an accurate reflection of a large sample of the states recreational shooters, then it is my view that changing Category C eligibility would have close to no impact on browsing animal control. There are approximately 2000 farming properties statewide and if 100 shooters obtain a category C firearm they would be expected to only shoot on a fraction of farms statewide. Many only shoot where there are deer for instance. The additional benefit for browsing animal control would be negligible.
Yours sincerely,
Peter McGlone
Director
Tasmanian Conservation Trust