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Review of the Victorian Kangaroo Harvest Management Plan

Life on land

“Victorian government’s management of kangaroo populations, in particular management of the commercial kangaroo industry is so deficient in meeting its own stated commitments in the Plan, in meeting community expectations or the requirements of good governance that it warrants independent review".

Tina Lawrence

November 28, 2023

With a detailed and acutely intelligent and just eye, Tina Lawrence, reviews the Victorian Government’s Kangaroo Harvest Management Plan (the Plan).

"Note: This analysis by Tina Lawrence was written as a response to the Victorian Government's 'consultation' regarding its development of a new Kangaroo Harvest Management Plan, the new plan covering the years 2024-2028, was made public on 16 November 2023, as yet another 'consultation' by Australia's Commonwealth Government, that is required to approve it. Submissions for the latest 'consultation' are required by 4 December 2023. Needless to say, despite the hundreds of hours of effort from numerous individuals and organisations (there were more than 700 submissions to the original Victorian 'consultation'), the new plan disregards, with the exception of getting this terrible conduct removed from Melbourne's suburbs, every other reality. The opening up of public lands, which will include National and State Parks in Victoria, is an indication, not only of the anything goes mentality that exists in the Victorian Government's current culture, but that the commercial exploitation of kangaroos is not sustainable. The hyperinflation of population estimates and significant government expenditures to defend this grotesque activity, and the culture it creates, will not make any difference to the basic fact that kangaroos are becoming increasingly hard to find. The new plan is indeed a work of fiction". Peter Hylands

I will now leave you in Tina's good hands....

GOAL: The goal of the Victorian Kangaroo Harvest Management Plan is to provide for the sustainable use of kangaroos in a way that protects animal welfare. The goal makes clear that sustainable kangaroo populations and good animal welfare outcomes are the highest priorities.

The Plan does not meet this goal for the following reasons:

The Plan relies sustainable use or exploitation, a sub-category of Ecologically Sustainable Development (ESD). While sustainable use promises a win-win-win scenario between economic growth, ecological sustainability and community benefits:

  • The Plan only serves the interests of those that benefit or profit from the commercial exploitation of kangaroos.
  • There is no evidence that the Plan produces any broader environmental, economic or community benefits.
  • The Plan ignores the significant ecological, animal welfare, economic and resources costs as well as the moral and reputational costs of operating a commercial kangaroo industry in Victoria.

While the emphasis of the Plan is on ecological sustainability, the Plan fails to assess or account for the ecological costs of operating a commercial kangaroo industry in Victoria. These include the loss of important ecological services that kangaroos, as large and populous native herbivores, provide to ecosystems and the long term ecological uncertainties and potential costs of removing large numbers of healthy wild animals from already vulnerable ecosystems across Victoria at a time when the evidence of biodiversity loss, ecosystem decline and the impacts of climate change is overwhelming (Report of the Inquiry into Ecosystem Decline in Victoria 2021).

As a result of its failure to effectively integrate these important ecological considerations, the Plan operates without proper regard to the precautionary principle.

The Plan does not provide for the ethical and humane slaughter of kangaroos in Victoria. It relies on the Commercial Code of Practice for Shooting Kangaroos and Wallabies (2020) (the Code) which institutionalises and legitimises what are inherently inhumane methods of killing both adult kangaroos and their dependent young. In addition, it fails to provide for adequate inspection or enforcement measures to ensure compliance with even the minimum animal welfare standards in the Code.

The documented evidence is clear that after 5 decades of regulation, including the incremental changes made to the Code, Codes of Practice have failed to modify the industry-wide use of inhumane practices at all or resulted in any improvement of animal welfare outcomes.

Objective 1: Ensure that commercial kangaroo harvesting in Victoria is ecologically sustainable

Removal of kangaroos from the population, whether by commercial harvesting or under the ATCW system, must not reduce kangaroo populations to the extent that normal population dynamics are affected or populations cannot recover. The level of commercial harvesting must be balanced with control by landholders under the ATCW system to ensure that all take of kangaroos remains within sustainable levels. Controls will be placed on harvesting activities based on the best available knowledge of Victorian kangaroo populations and kangaroo population dynamics/breeding biology, to ensure harvesting is undertaken sustainably.

The Plan fails to meet this Objective because the methodology used by the Victorian government to estimate kangaroo populations and set quotas is fundamentally flawed and represents a serious risk to both kangaroo populations now and into the future and the health and persistence of the ecosystems in which they are the dominant large herbivore.

The accurate estimation of kangaroo populations is critical to ensure kangaroo populations remain viable. The use of poor methodologies can provide inaccurate estimates undermining the long term sustainability of kangaroo populations.

Over the last two decades respected non-government and independent ecologists have identified flaws in these methodologies and suggested that kangaroo populations are at risk because of the mismanagement of state kill quotas (Boom, Ben-Ami 2012).

Chief among the concerns raised by these experts are that the survey methods used and the use of inappropriate correction factors have artificially inflated population growth estimates in targeted populations of kangaroos, making them unreliable methods of accurately assessing kangaroo populations (Boom, Ben-Ami 2012).

Concerns have also been raised that the way in which quotas are set do not provide a reliable tool for managing the sustainability of the killing because the population estimates relied on do not take into account a range of other significant causes of kangaroo mortality (Ben-Ami 2009).

These concerns were highlighted in evidence provided to the NSW Inquiry into the Health and Well-being of Kangaroos in 2021. A significant portion of the Inquiry was taken up with analysis and evidence from independent experts critical of the way in which kangaroo populations are estimated and harvest quotas set under the NSW KMP.

The Victorian Plan (as do the kangaroo management plans of the other states which operate a commercial industry) relies on the same methodology (with some slight variations) as the one used in NSW, making the evidence and the findings of that Inquiry directly relevant to the assessment of whether the harvesting regime in Victoria is “ecologically sustainable”. Criticisms of the methodology used made to the Inquiry included the following:

Sample selection: The evidence provided to the Inquiry suggested that the sampling method to select which areas were surveyed was not sufficiently transparent or justified with the result that the survey results could not be relied on to extrapolate results to an entire area.

Independent experts that gave evidence suggested that for a sample to be considered reflective of the entire population it needed to be chosen in a way that ensured the area of the sample could be extrapolated to that population.

The evidence also suggested that using densities calculated from a small sample area and assuming uniform density across whole regions with different terrain, ignoring vast areas where kangaroos were completely absent was fundamentally problematic.

Use of correction factors: Expert evidence to the Inquiry questioned the scientific validity of the use of correction factors, and other modelling techniques, to estimate total populations out of the numbers actually sighted during surveys suggesting that it did not represent the best available science and remained unproven in scientific literature.

Another concern that was raised related to the routine changed made to the correction formula. Evidence to the Inquiry suggested that correction factors were used to “systematically inflate” population estimates and that changing correction factors had been used to mask actual decline in kangaroo numbers.

The significance of these criticisms was that the use of correction factors could lead to serious bias, and result in inaccuracies that were a cause for concern when the estimates derived are used to determine management action (such as setting harvest quotas).

Kangaroo population growth rates: A wildlife population can only be harvested sustainably if harvesting occurs at the same or a lower rate than that at which the population would otherwise increase (Caughley and Sinclair 1994).

Evidence that the maximum natural rate of population growth (replacement rate) for grey kangaroos of around 10% per annum and around 14% for red kangaroos and wallaroos raised doubts about the plausibility of the population estimates on which the harvest quotas were based and the sustainability of the current harvest quotas.

Lack of transparency: Evidence provided to the Inquiry asserted that the science underpinning the quota reports was insufficiently transparent and that the annual surveys should be subject to independent scrutiny through peer review. The same issues relating to lack of transparency and the lack of independent scrutiny apply to the Victorian Plan.

Minimum density thresholds: Evidence to the Inquiry suggested there was insufficient transparency around the thresholds at which harvest quotas are reduced or suspended altogether. Specifically, there was criticism of the fact that there was no public explanation of how the thresholds were determined and what they actually were for each species of kangaroo. The same criticism applies to the setting of thresholds under the Victorian Plan.

Quotas based on previous year's population: Concerns were raised at the Inquiry about the fact that harvest quotas were set based on population estimates from surveys done in June or July of the previous year. Expert evidence to the Inquiry suggested that this delay that meant that when a population was in decline (for example during drought) setting quotas based on the previous years’ population estimate would represent a much higher proportion of the actual kangaroo population and automatically result in an over-allocation of quota.

The same issue arises in Victoria. Quotas are set on the basis of out of date survey data which can skew the allocation and put kangaroo populations under increased risk of over- exploitation.

Setting harvest quotas: Like NSW, the commercial kangaroo industry in Victoria operates under a “proportional threshold harvest system” where quotas are set as a percentage of the estimated kangaroo population. Expert evidence given to the NSW Inquiry made it clear that:

  • The many errors in the survey program fed into officially published population estimates through a number of flawed system processes. This resulted in significantly inflated population estimates, which in turn led to an over-allocation of (an unobtainable) quota;
  • The multiple serious deficiencies in the methodology used for estimated kangaroo numbers, including the fact that quotas were based on annual trends in population estimates rather than by biological and ecological information and did not take into account age and sex of kangaroos killed meant that the public could not have any confidence that the way in which harvest quotas (“sustainable yields”) that were set met the precautionary principle of preventing local population collapse;
  • The fact that population estimates (and quota) had diverged from the “take” to such an extraordinary degree in recent years, where the allocated quota had become unobtainable, was a further indication that there were critical errors in the derivation of population estimates and the resulting quotas.

What makes Victoria’s kangaroo populations so vulnerable to over exploitation is that Victoria has a fraction of the number of kangaroos of any of the larger states that operated a commercial kangaroo industry. This means that even minor errors in estimating populations or minor errors in management decisions or actions could have a disproportionately significant impact on local kangaroo populations.

Uncertainties-Impacts on ecosystem function and integrity: Ecologically sustainable refers to practices and processes that can be maintained in balance with the environment over the long term without causing significant harm or depletion of resources.

Kangaroos are a keystone species and play a crucial role in ecosystems across Victoria. As large herbivores they influence vegetation composition and structure through grazing, seed dispersal and nutrient cycling. Their presence in ecosystems is essential for ecosystem stability and functioning, as described in more detail below.

Large scale removal of kangaroos risks disrupting ecosystem dynamics, leading to cascading effects on other species including changes in plant community composition which provide of habitat for other native species.

Even government scientists have expressed concerns about the ecological, economic and social uncertainties regarding the long term impacts of removing large numbers of kangaroos from the landscape. These concerns relate to the fact that this form of commercial exploitation is based on a “maximum sustainable yield” model that completely ignores important ecological role of kangaroos and the complexity of the environments in which the killing takes place (McLeod 2019).

There is nothing in the Plan that suggests that any consideration has been given to the ecological importance of kangaroos in Victorian landscapes and what impact of removing large numbers of them might have on the ecological integrity of those ecosystems.

Objective 2: Ensure that commercial kangaroo harvesting in Victoria is humane and animal welfare is protected

To meet legal requirements and community expectations, commercial kangaroo harvesting must be undertaken with the welfare of the kangaroos as the highest priority. Controls will be placed on harvesting activities to ensure harvesters are required to adhere to recognised animal welfare standards, and that they are capable of doing so.

The Plan fails to meet this objective because it fails to ensure that the welfare of kangaroos is given high priority or provide for the ethical and humane treatment of kangaroos in Victoria.

The Plan relies on the Commercial Code of Practice for Shooting Kangaroos and Wallabies (2020) (the Code) a document produced by the kangaroo industry that relies on highly selective use of animal welfare science and endorses clearly inhumane methods of killing both adult kangaroos and their dependent young without imposing the necessary conditions for use required by the AVMA Guidelines.

In addition, the Plan fails to provide for adequate oversight or enforcement measures to ensure compliance with the minimum animal welfare standards in the Code.


Animal welfare costs in the kangaroo industry: The potential for suffering

The scale of the kangaroo industry in Victoria and the numbers of individual adult kangaroos and dependent young killed under the Plan every year, the field conditions under which they are slaughtered, the methods that are used, the lack of training provided in those methods as well as the lack any effective oversight or enforcement by the responsible government authorities means that there is very significant potential for suffering and poor animal welfare outcomes for both individual animals and broader kangaroo population structure and dynamics.

Numerous non-government scientific assessments have raised serious questions about the humaneness of these methods of killing young animals and suggested changes that would improve welfare outcomes. (Boom,Ben-Ami, Boronyak 2012).

The animal welfare costs of the kangaroo industry were assessed by independent scientists in 2014 (Ben Ami et al 2014). They were found to be significant:

“...The welfare costs include deliberate and indirect harm to dependent young (a by-product of the commercial kill), and a number of unintended harms to adult kangaroos, including increased mortality during drought, inhumane killing of a portion of adult kangaroos, and a disruption of social stability and the evolutionary potential of individuals. Furthermore, a substantial gap exists between the intended welfare standards of the code of practice governing the kangaroo industry and the welfare outcomes for both dependent young and adult kangaroos...”

A further independent animal welfare assessment of the methods used for the harvesting, hunting and population control of kangaroos and wallabies which was carried out in 2015 (Descovich 2015) also found that the methods used to kill the dependent young had significant associated welfare challenges and noted the need for extensive further data and research.

None of the recommendations made in these reports have been acted on in any of the states which operate a commercial kangaroo industry, including in Victoria.

The scale of the killing in Victoria

The Annual Kangaroo Harvest reports for 2019, 2020, 2021 and 2022 produced by DEECA confirm that between 1/10/19 and 31/12/2022, a total of 184,461 adult kangaroos were shot and processed by the commercial kangaroo industry in Victoria.

The Annual Reports also confirm a total of 53,326 orphaned dependent young were also killed in that same 3 year period as industry“wastage”.

These figures should be viewed with caution given these numbers are self-reported by shooters and there is no oversight at the point of kill to verify these numbers are accurate.

In addition to this, DEECA has continued to issue hundreds of ATCW “damage mitigation” permits to landholders (including public land managers such as Parks Victoria which operates an annual large scale kangaroo control program in the Mallee Parks) during this period. Under those permits an additional 214,875 adult kangaroos were authorised for control since the commencement of the permanent kangaroo industry on 1/10/19.

As DEECA openly admits, because there is no oversight at all of the activities of landholders under the ATCW permit system and there is no requirement to provide evidence or returns regarding their activities, there is no way to know if these figures are in any way accurate.

One set of figures that are not accounted for at all in any of the government reporting are the numbers of dependent orphaned young killed under ATCW permits. Again, because ATCW permit holders are not required to record or report these numbers, it is difficult to say with any certainty how many orphaned dependent young are killed under these permits.

If the same percentage of the number of females in the commercial industry of 30 per cent and the same ration of females to dependent young killed is applied, this would amount to an additional 71,624 dependent young since 1/10/19.

When these figures are added together, the total number of kangaroos killed in Victoria since 1/10/19 is 524,286. Not only are these figures a concern with regard to the sustainability of the industry when in the same time period, the state government estimates the total number of kangaroos in Victoria was between 1.4 and 2 million but highlights the numbers of individual animals that are subject to the inhumane methods of killing endorsed in the Code.


Evidence of widespread use of inhumane practices

The kangaroo industry is known world-wide for its violence and cruelty. This is why it is losing markets in both the USA and Europe as legislative bans are enacted and numerous global sports and fashion brands abandon kangaroo leather and UK and European supermarkets refuse to sell kangaroo meat. It has been a major obstacle to its efforts to expand its markets, including in China where trade discussions have stalled for 15 years because of animal welfare concerns.

The kangaroo industry’s reputation for cruelty is well-founded. Repeated investigations into the slaughter practices employed in the kangaroo industry over the past 40 years have revealed that even under observation there is widespread and routine non-compliance with the minimum animal welfare standards set out in the Codes of Practice.

These investigations have included RSPCA investigations in1985 and 2000-2002, independent investigations into wounding rates in 2008-2009 and the Commonwealth government’s own investigation of the use of inhumane practices within the kangaroos industry between 2011 and 2013, details of which were published in a report in 2014 (McLeod, Sharp 2014).

The 2014 RIRDC report recorded multiples instances where commercial kangaroo shooters committed numerous serious breaches of the Code in the killing of dependent young and revealed that this was because:

  • Kangaroo shooters are largely ignorant of their obligations under the Code of Practice in relation to the humane killing of dependent pouch young and young at foot;
  • Kangaroo shooters had little or no understanding of kangaroo biology and development;
  • Kangaroo shooters had no training in the methods of killing the orphaned dependent young;
  • Kangaroo shooters were largely indifferent to the suffering and welfare outcomes of the kangaroos they killed; and
  • There was no fear of detection for wrongful behaviour as their activities in the field were not subject to any oversight.

These investigations found evidence of unacceptably high non head shot/wounding rates (in one study, of up to 40 per cent), a consistent failure to address the welfare of the young at foot which were often left to die after their mothers were shot and the routine use of unacceptable methods of killing pouch young.

Since 2014, animal welfare assessments carried out by veterinarian observers from Ecotone Veterinarian Services in order to evaluate animal welfare outcomes in government-run large scale kangaroo control programs carried out in the ACT in 2016 and 2017 and the Mallee National Parks in Northern Victoria between 2015 and 2021 have also found highly variable wounding rates of between 2 per cent and 11 per cent as well as evidence the commercial shooting contractors involved were so incompetent in performing blunt force trauma to kill furred joeys that they inflicted multiple (up to 7 but an average of 2.8) blows in order to render these joeys insensible (Copies of these reports are available on request).

It is notable that these assessments were conducted via direct observation of government contracted commercial shooters that had undergone competency testing in order to fulfil the requirements of a commercial kangaroo shooters licence as well as a government tender and vetting process. If wounding rates and incompetence in the killing the dependent orphaned young were found to be high even under these circumstances, there is little question that these rates would be even higher in situations where there is no oversight and where profit is the only consideration.

What is clear from the findings of these investigations is that in the decades the Codes of Practice have been in operation in the kangaroo industry, there is no evidence that the Codes have produced any verifiable improvement in welfare outcomes for kangaroos or their dependent orphaned young.

In fact, there is strong evidence to suggest that the Code is preventing significant animal welfare improvements from being realised.

Animal Welfare under the Plan

The Victorian state government has stated repeatedly that animal welfare is a high priority and that its policy and legislative frameworks support good animal welfare outcomes. The same messaging is reflected in Objective 2 in the Plan.

At least in relation to its support of the commercial kangaroo industry in Victoria, this is demonstrably untrue.

The Code was developed by the kangaroo industry not as a legitimate attempt to improve animal welfare in the kangaroo industry but as a marketing tool to re-assure wavering export markets that the industry was taking the issue of animal welfare seriously.

As a result, the Code relies on the highly selective use and in some respects the misuse of animal welfare research to justify the use of slaughter methods that are clearly inhumane without specific training and direct supervision.

Neither the research that supported the development of the Code nor the Code itself was conducted by an animal welfare expert nor was it subject to any form of peer review or independent scrutiny. The result is that the Code is highly favourable to the kangaroo industry and does not give due weight to the animal welfare issues raised by the commercial slaughter of kangaroos.

There is no evidence that the Victorian government has taken any steps to independently assess the Code to ensure that the animal welfare standards it contains are supported by the best available scientific evidence or that adequate training and oversight is in in place to that ensure that those standards are met, as it would have done had it prioritised animal welfare.

Deficiencies in the Code

The current Code came into operation in November 2020. It replaced the earlier 2008 code which contained a clear directive against targeting female kangaroos with obvious pouch young. The 2020 code removed this protection and introduced changes which weakened welfare protections for kangaroos and their dependent young, including:

  • The weakening of the standard of accuracy for shooting kangaroos, with the removal of the requirement that shooters aim for the brain and replacement with the less rigorous requirement head shots are sufficient;
  • The significant weakening of the protections for both female kangaroos and their dependent young with the removal of the direction in the 2008 Code that shooters avoid targeting female kangaroos with obvious dependent pouch young. This, together with the removal of the male only policy adopted by some processors in 2019 has led to an exponential increase in the number of females and dependent orphaned young being killed;
  • The introduction of a definition and assessment of sentience in unfurred pouch young which does not reflect major advances in the science and understanding of sentience and its application to neurologically immature, foetal and neonatal animals over the last 10-15 years;
  • The endorsement of physical methods of killing pouch young including cervical dislocation, decapitation and blunt force trauma in the face of clear scientific evidence and warnings in the AVMA Guidelines (2013) that each of these methods has significant potential to be inhumane without imposing the conditions set out in the AVMA Guidelines or mandating training.

The failure to properly apply the precautionary principle in the positions taken on the weakening of the protections for female kangaroos, the issue of the onset of sentience in unfurred pouch young and its acceptance of the use of the physical methods of killing dependent young that have significant potential to be inhumane.


The misuse of science in the Code

The animal welfare science relied on to justify the positions in the Code is skewed in significant ways. There is a heavy reliance on industry funded science in the standard-setting process. Much of the science relied on is out of date and ignores significant developments in animal welfare science both in Australia and internationally in the last decade.

The following examples illustrate how the selective use of the science was used to justify the positions in the code regarding the humaneness of the methods used to kill the dependent young:

Sentience: For the first time the commercial code introduces the concept of sentience as a determinant of the applicable method of destruction or dependent young.

The Code defines “sentient” as follows:

“....the capacity to perceive sensations originating from sensory outputs which is present from a certain developmental stage onwards”.

The Code relies on research conducted in 2008 and 2010 by Deisch and Mellor to justify its position that unfurred joeys are not sentient and therefore unable to experience pain.

Review of the 2010 study referred to in the Code reveals that the findings of that research were heavily qualified by the authors themselves who acknowledged that:

  • While it was clear that most neurological development occurred post-natally in macropods, there was no scientific research to determine precisely when neurological development was sufficient to permit conscious sensory perception in these species;
  • The results found DID NOT directly indicate whether unfurred tammar wallaby joeys were able to experience pain but only allowed them to draw inferences regarding possible pain experience.

More recently, one of the authors of those reports, Professor David Mellor published an opinion paper in July 2019 in which he substantially revised his earlier position regarding the onset of sentience in neurologically immature animals. In that paper, Professor Mellor expanded the criteria for the assessment of sentience to include the capacity for positive subjective experiences and goal-directed behaviours (Mellor 2019).

By omitting these very significant developments in the science and understanding of sentience in neurologically immature animals, the Code does not present an accurate and balanced presentation of the scientific evidence on sentience.

Methods of killing the dependent young: The code prescribes the following methods of killing pouch young and their application:

  • Cervical dislocation (“CD”)-method for use on unfurred joeys under 5 cm in length (from head to tail);
  • Decapitation-method for use on unfurred joeys over 5 cm until furred (from head to tail);
  • Concussive blow to the head (blunt force trauma) (“BFT”) method for use on furred joeys (up to 5 kilograms).

The AMVA (American Veterinary Medical Association) Guidelines (2013) which the Code refers to, provides assessments of a range of euthanasia methods makes it clear that there are significant issues relating to the humaneness of each of these methods.

For example, the AVMA Guidelines caution that there are few scientific studies to confirm that CD is in fact humane. According to the AVMA Guidelines, cervical dislocation appears to be humane only when performed well by well-trained people on suitable animals, under-scoring the importance of expertise in using the method. This is not a requirement that has been adopted in the Code.

In relation to the use of decapitation as a slaughter method in the Code, the science relied on omits the warning in the AVMA Guidelines that the use of this method is conditioned on the person performing the method having high levels of training and being monitored for competence to ensure it is done as humanely as possible.

As well, the Code ignores the findings of a 2010 review of the scientific literature (Bates 2010) in which the author concluded that:

“Viewed in toto, the almost inescapable that decapitation is a painful procedure and that conscious awareness may persist for up to 29 seconds in the disembodied heads. This comports poorly with the strict definition of euthanasia”.

Again, the AVMA Guidelines concede that the use of BFT has the potential to be inhumane unless strict conditions are met, including training and oversight of those performing the method. This is supported by a number of international scientific studies including research carried out in 2017 and 2018 that challenged the humaneness of the use of blunt force trauma to kill neonatal animals.

The conditions imposed by the AVMA Guidelines do not appear in the Code or in the training and accreditation requirements for licensing kangaroo shooters referred to in the Plan.

Legal status and enforceability

Because it is a voluntary Code and not legally enforceable against wrongdoers, it is ineffective at deterring wrongful conduct and inhumane practices.

Worse, the Code shields offenders from any criminal liability under state-based animal welfare laws when the activity has been conducted in accordance with the Code.

While Objective 2 refers to a commitment to put controls in place to ensure compliance with the Code, the reality is that compliance activity, investigation and enforcement action in relation to breaches of the Code is virtually non-existent in Victoria. This evidence for this is discussed in more detail in relation to Objectives 3 and 4.

Where there is no fear of detection let alone prosecution for wrongdoing, there is no deterrent effect for illegal and inhumane practices and no motivation to modify wrongful behaviour or to improve animal welfare outcomes.

Objective 3: Ensure that commercial kangaroo harvesting and processing activities are appropriately regulated

Regulating the activities of harvest participants via suitable authorisation and licensing regimes will provide a mechanism to manage and monitor risks. This will be achieved through the interaction of this plan with authorisations and the inclusion of appropriate conditions on licences and authorisations.

The Victorian government claims there is no serious threat to kangaroos from commercial shooting or other kangaroo management programs because the large species that are targeted are both abundant and widespread and the management and control programs it oversees are well-regulated. These claims do not stand up to scrutiny.

There has been a long history of regulatory failure by Victorian government wildlife agencies in protecting the state’s kangaroo populations from harm and decline:

  • The Victorian government and their wildlife agencies failed to act when it was clear that red kangaroo populations were being decimated by uncontrolled commercial overshooting in the midst of severe drought in the 1960’s including in Victoria (Senate Inquiry report 1971);
  • The Victorian government and its wildlife agencies failed to act when an earlier attempt to establish a commercial kangaroo industry in Victoria in 1980 resulted in kangaroos being reduced to quasi-extinction levels across the date in just 2 years due to overshooting (Short and Grigg 1982); and
  • The Victorian government and its wildlife agency failed to take appropriate measures or conduct sufficient oversight during the Kangaroo Pet Food Trial in 2014-2019 to prevent widespread corruption and fraud which resulted in a massive increase in kangaroos being killed of 260 per cent in just 4 years which DELWP at the time itself described as a threat to the viability of kangaroo populations across the state (KFPT Evaluation Summary 2018).

Regulation under the 2019, 2020 and 2021-2023 Plans

Under the KPFT, DELWP (now) DEECA had sole responsibility for regulating commercial shooting. This ensured there was at least some accountability for the failures the KPFT exposed.

Under the administrative arrangements set out in the 2019, 2020 and 2021-2023 Plans, responsibility for the commercial kangaroo industry in Victoria is dispersed over 4 government departments and agencies:

  • DEECA-Responsible for managing and determining the quotas via ARI and the Plans;
  • DJPR-Responsible for administering the commercial industry as regional employment program;
  • Services Victoria-Responsible for delivering a “stream-lined” application and authorisation process); and
  • GMA (Game Management Authority)-Responsible for monitoring/compliance in the commercial kangaroo industry under a Service Agreement with DJPR.

The decentralisation of governance for this industry has had a serious impact on the ability of the public to access documents relating to the program, on transparency and on the accountability of these agencies for their regulation of commercial kangaroo operations, as discussed below.

Of most concern is the designation of the GMA as the agency with the responsibility for issuing licences and for monitoring compliance and enforcement.

The GMA was the subject of a damning Pegasus Economics report in 2017. That report found that it was neither a credible nor an independent regulator of hunting in Victoria following its failure to enforce its own regulations during the 2016 duck hunting season which led to a large number of endangered waterbirds being illegally shot and killed.

The delegation of the state government’s licensing, compliance and oversight role in the commercial kangaroo industry to a clearly discredited and incompetent regulator raises serious questions about the state government’s ability to meet its stated objectives to make animal welfare a priority and to properly monitor and protect Victoria’s kangaroo populations from overexploitation and long term harm.

Objective 4. Effectively monitor and enforce compliance

Compliance with the requirements of the plan by participants in kangaroo harvesting is essential to protect animal welfare, ensure sustainable kangaroo populations, and ensure the community’s confidence in Victoria’s commercial harvesting program. Compliance can be promoted and achieved through several measures ranging from education and information provision, effective record-keeping and reconciliation, through to proactive audits and enforcement actions including prosecution of alleged offences.

The state government’s compliance and enforcement activity in relation to the kangaroo industry is weak and ineffective and incapable, in its current form, of meeting the Objective 4 in the Plan.

The risk-based approach to monitoring compliance under the Draft Plan

Under the Plan, the Victorian government takes a risk-based approach to regulation of the commercial kangaroo industry. This approach emphasises voluntary compliance by kangaroo shooters and other industry participants through the provision of education and guidance over stricter or more coercive controls.

The theory is that by focussing on risk rather than prescriptive rules, regulatory effort can be more targeted, freeing up resources and removing administrative burdens for those that conduct low risk activities.

However, for a risk-based regulatory approach to work effectively, it needs to be guided by the reliable and good quality data, the best available science and information, linked to measurable objectives and designed to set clear parameters for decision-making which are transparent and capable of scrutiny by the public (Rothstein et al 2007).

The risk-based approach to monitoring compliance and enforcement in the Plan does not in any way meet these best practice standards.

Lack of effective enforcement

Effective enforcement requires an adequate inspection regime to drive compliance and address conduct that constitutes breaches of the Code and any other licence conditions.

Inspections play a major role in the detection of offences within animal industries because in the absence of whistle-blowers or reports from the public, the victims are unable to report offences or cruelty to the regulatory authorities (Boom, Ben-Ami, Boronyak, Riley 2013).

Inspections are also important because animal industries, including the commercial kangaroo industry, operate under a veil of secrecy and within an entrenched culture of silence especially when it comes to slaughter practices.

Lack of an adequate inspection regime also undermines deterrence. When offenders realise that the likelihood of their being punished is low, there is no motivation to change their conduct or practices.

Adequacy of compliance monitoring in the Victorian kangaroo industry

Inspections of kangaroo shooters are an essential precondition to ensure compliance and the detection of offences, particularly in relation to the killing of dependent young and injured kangaroos which are major problems in the kangaroo industry.

Review of the Victoria’s Annual Kangaroo Harvest Program reports in 2019, 2020, 2021 and 2022 provides an insight into the inspections and compliance and enforcement regime and the compliance and enforcement actions taken by the Victorian government since 2019.

The reports confirm that between 1/10/19 and 31/12/2022 a total of 184,461 adult kangaroos were shot and processed by the commercial kangaroo industry in Victoria.

These reports also confirm a total of 53,326 orphaned dependent young were also killed as industry “wastage”. The total number of kangaroos killed in this time was 237,787.

Despite these numbers, the Annual Program reports for that same period confirm that there were extremely low levels of inspection and other forms of compliance activity in the Victorian kangaroo industry:

  • There were between 87 and 157 licensed kangaroo shooters operating in the Victorian industry between 2019 and 2022, an average of 122;
  • The reports do not indicate how many of these were “active” shooters and therefore subject to inspection;
  • There was no compliance activity at all in 2019;
  • There were extremely low levels of inspection and other compliance activity in relation to kangaroo shooters in 2020, 2021 and 2022;
  • Between Jan 2020 and December 2022 there were a total of 157 programmed inspections (about 1 per month). Given these inspections were notified ahead of time, this would have allowed the kangaroos shooters to ensure they were compliant, raising questions about their utility and effectiveness;
  • In the same period, there were 51 unannounced inspections of kangaroo shooters - an average of 1.5 per month;
  • 92 desktop audits were also conducted, at an average of 2.7 per month. Again, these audits do nothing to address the key issue of animal welfare and are of questionable utility; and
  • There were no inspections at the point of kill.

Inadequate inspection regime-no inspections at point of kill

The Kangaroo Pet Food Trial Evaluation report 2018 highlighted serious problems associated with the regulation of commercial kangaroo shooting in Victoria that had resulted in widespread fraud and corruption. This had in turn led to massive levels of overshooting that DEECA itself considered was a threat to the viability of kangaroo populations in the state.

The failures identified in the Evaluation Summary report were found to be due to the inability of the regulator to undertake field audits of shooters or properties at the point of kill. This key obstacle has not been resolved under the Plan and continues to undermine the state government’s claims about its oversight of the industry.

The absence of any provision or requirement for oversight or inspections of the activities of kangaroo shooters in the field that could detect animal welfare breaches or other wrongdoing where slaughter practices take place is a key regulatory gap that has not been addressed since 2014.

In the absence of direct observation at the point of kill in order to verify shooter accuracy and the level of skill and competence in performing the methods of killing dependent young is compliant with the code, it is impossible to ensure that the minimum animal welfare standards set out in the Code or other licence conditions are being met.

Limited and under-utilised compliance and enforcement powers

Given the low levels of inspection activity, unsurprisingly there have also been extremely low levels of enforcement activity since the commencement of the commercial industry in 2019.

According to the Annual program reports for 2019, 2020, 2021 and 2022:

  • There was no investigative or enforcement activity at all in 2019.
  • There were 3 information reports relating to illegal activity in the kangaroo industry in 2020. There is no information in the 2020 program report to suggest these were investigated, any offences detected or any enforcement actions taken;
  • In 2021, there were 36 reports of illegal activity in the kangaroo industry. The annual program report does not contain any reference as to whether these were acted on, investigated or any enforcement actions taken or the outcomes of those enforcement actions; and
  • In 2022, there were 36 information reports. 13 of these were investigated. There were also 3 licence suspensions/cancellations. There were no prosecutions.

Despite the number of reports made and investigations undertaken, these reports suggest that only 3 kangaroo shooters in Victoria have suffered any significant penalty for non- compliance with the Code or breach of licence conditions in the last 3 years.

This evidence suggests that enforcement provisions are rarely applied and serious action rarely taken.

There are a number of reasons Industry capture conflicts of interests

The key reason there is so little effective compliance or enforcement activity is due to the underlying political considerations that operate to undermine the effectiveness of any oversight of the kangaroo industry in Victoria.

At its core, kangaroo management is a political enterprise, created and maintained by state and federal governments to placate rural landholders that overwhelmingly regard kangaroos as a pest and a threat to the profitability of their farm businesses.

These political considerations, together with high levels of industry capture in the setting of policy and decision-making, mean that Victorian government policies in relation to compliance and enforcement are weighted toward unconditional support for the industry and away from strong or effective regulation.

The combination of these influences and the economic alignment between the state government and the kangaroo industry has led to the development of a reactive compliance and enforcement regime that largely focuses on the “worst cases” without sufficient attention to smaller, more institutionalised wrongful behaviour and a failure to address clear regulatory gaps.

Weak compliance and enforcement culture

The same political considerations have also contributed to the weak and passive compliance culture within the agencies that have responsibility for overseeing commercial kangaroo industry operations in Victoria, leading to them being either unable or unwilling to monitor and enforce compliance.

This is evidenced by the minimal compliance and enforcement activity that has been carried out since 2019 and the fact that there have been only 3 cases in 3 years in which any penalty at all was imposed for wrongful conduct.

These failures have nothing to do with resourcing. In 2020, the government allocated an additional $6 million to the GMA to cover the additional staffing required to exercise its compliance and enforcement functions, including under the Plan.

The need for strengthened oversight and regulation

Strong inspection activity, investigation, compliance and enforcement is essential to protecting kangaroos from harm and to meeting reasonable community expectations that breaches of animal welfare standards and inhumane practices will be acted on proactively and transparently.

None of these things is currently occurring.

The 2013 report from Boom, Ben-Ami et al offered a number of simple and achievable measures to improve compliance and enforcement in the kangaroo industry including:

  • Integration of the Code into state laws with more focus on its objectives in relation to animal welfare;
  • Increasing the number of both announced and unannounced inspections across the board;
  • Including control measures such as minimum inspection rates in the Code to ensure regular and uniform inspection rates;
  • Enhanced methods of inspection should be accompanied by more coercive command and control measures and more significant penalties such as licence suspensions and cancellations as well as prosecutions.
  • Providing improved training programmes for humane slaughter methods;
  • Making the granting of commercial licenses conditional on meeting competency requirements in humane slaughter methods; and
  • The introduction of more effective selection and elimination processes for the granting of licences.

None of these recommendations have ever been considered, let alone incorporated into the Plan or into the compliance monitoring or enforcement policies of the Victorian government agencies that are responsible for kangaroo industry operations.

The same political considerations have also contributed to the weak and passive compliance culture within the agencies that have responsibility for overseeing commercial kangaroo industry operations in Victoria, leading to them being either unable or unwilling to monitor and enforce compliance.

Objective 5. Facilitate adaptive management and research

Establishing a commercial kangaroo harvest provides new opportunities for collecting information for the management of the commercial harvest as well as broader kangaroo management approaches in Victoria. Learning from the outcomes of management approaches and continuously applying improvements will be actively pursued.

It is not possible to learn “from the outcomes of management approaches” or “apply improvements” to a regulatory regime when those approaches rely on industry funded science that neglects significant areas of relevant inquiry and fails to acknowledge important knowledge and information gaps.

The 2021-2023 Plan states that:

“While there is a large body of research on the ecology and management of kangaroos, there are information gaps which, when filled, may lead to improved management of the commercial harvest”.

There is a large body of government and industry funded research (comprising hundreds and hundreds of research papers) that has been produced in relation to kangaroos over the past 50 years. That research has almost exclusively focussed on topics that support and promote the interests and strategic goals of the kangaroo industry by:

  • Depicting kangaroos as an overabundant destructive pest, that causes significant damage to fencing and threatens agricultural productivity through competition with livestock;
  • Justifying the need for widespread lethal management of kangaroos to “reduce grazing pressure”, to “restore balance” and to mitigate “damage”; and
  • Supporting and promoting expansion of the industry and kangaroo products to both domestic and export markets.

By contrast, there has been almost no examination of the ecological value, or important ecological role kangaroos play in creating and sustaining species richness and maintaining ecosystems or to properly analyse obvious threats faced by kangaroo populations.

The Plan fails to acknowledge the potential ecological costs of large scale extraction, including the impact the loss of the ecological services kangaroos provide has on ecosystem functioning and the overall integrity of those ecosystems in Victoria.

This is because the kangaroo industry and the governments that support it seek to portray the commercial industry as being a win-win situation that provides “something for nothing”, one that has no real consequence or costs. This is not the case, as is evidence below demonstrates.

These gaps in research undermine any claim that the Plan takes seriously its obligation to integrate ecological considerations into decision-making or that the conservation of biological diversity and ecological integrity is a fundamental consideration in the management of commercial kangaroo industry operations in Victoria.

Kangaroos as ecosystem engineers-the ecological services kangaroos provide

There is no serious dispute that kangaroos, having co-evolved with the Australian landscape, are uniquely adapted to its various landscapes and climates (THINKK submission 2021). The Plan does not acknowledge this basic fact nor does it attribute any ecological significance or value to the kangaroo species to which it relates, despite the fact that kangaroos, as the state’s dominant large herbivores and mammalian grazers, modulate critical ecosystem processes.

Contribution to species richness

Contrary to the “pest control” narrative that underpins much of the Plan, there is evidence to suggest that kangaroos increase, not deplete, species richness where they are present.

Kangaroo fur traps spores and seeds which can then be distributed throughout the landscape as they move around. In this way, they play an important role in maintaining levels of vegetation diversity (Dawson 2012).

A long term study in Mulga dry forests in Qld that had been chronically degraded by livestock grazing found that areas where kangaroos were present had the highest species richness and that there was evidence the presence of kangaroos had led to an increased range and abundance of native plants including perennial grasses as well as the regeneration of Mulga forest (Fensham 2011).

These findings and the importance of the role of kangaroos in ecosystem health and species richness was also acknowledged in a conservation research technical report published by the ACT government (Snape, Caley et al 2018) which described the key role of the kangaroo as follows:

“As the overwhelmingly dominant herbivore in lowland grassy ecosystems, kangaroos occupy a central place in the ecology of such ecosystems (Fletcher, 2006)...In some situations they are ‘ecosystem engineers’ as defined by Jones et al. (1997) and Wilby et al. (2001) due to their ability to modify both their own habitat and that of other species”.

Contribution to soil health

Kangaroos also contribute to soil health in a number of ways. Their toes aerate compacted and depleted soils (Dawson 1992). Kangaroos also create diggings (hip-holes) that may beneficially modify the chemical and physical properties of soils through entrapment of faeces and litter, and soil turnover (Eldridge and Rath, 2002) (Eldridge, James 2009).

Similarly, a CSIRO Plants Industries study in 2014 which examined kangaroo impacts on the ACT's urban reserves, found that areas where kangaroos were present had healthier ground level vegetation with higher levels of vegetation diversity (Vivian, Godfree 2014).

Research in 2009 argued that given their wide-ranging effects on surface soil and ecological processes, that soil disturbance by native animals (including kangaroos) had the potential to contribute to restoration of degraded landscapes, particularly in arid and semi-arid areas (Eldridge, James 2009). That research described the impacts of these animals on soil health as follows:

“Soil-disturbing animals have wide-ranging effects on both biotic and abiotic processes across a number of Australian ecosystems. They alter soil quality by mixing surface soils and trapping litter and water, leading to areas of increased decomposition of organic matter".

Research completed in 2021 suggested that even at high densities (~70 kangaroos per km2) in a peri-urban mesic environment, the grazing of eastern grey kangaroos was found to be benign-not detrimental-to soil health (Eldridge et al., 2021).

Threats to kangaroo populations

The Plan contains a list of potential threats to kangaroo populations in Victoria. These assessments rely on outdated research and do not adequately address the seriousness or imminence of risks those threats pose which would allow for the proper application of the precautionary principle. The assessment of the risks that climate change poses is just one example of the lack of any substantive research that contradicts the dominant narrative that there is no down side to the commercial exploitation of kangaroos.

Climate change

Rapid climate change is causing increased incidence of severe drought, increased fire intensity, more days of extreme heat and changes in foliage nutrient composition (EPBC Act Independent Review report 2020).

There is consensus in the most recent scientific evidence that climate change will result in permanent reductions in average rainfall, increased and more prolonged droughts and more extreme heat events (Bergstrom 2021).

There is also clear evidence that more frequent and extreme temperatures have the capacity to result in large-scale contractions in kangaroo ranges that could push many macropod species beyond their physiological capacity to cope (Ritchie, Bolitho 2008).

More recent international research suggests that environmental stress resulting from climate change will cause mass die-offs of native unless species can shift ranges as the temperatures increase (Fey 2015).

The Plan fails to deal with the potential impact permanent reductions in average rainfall will have on kangaroo populations despite the fact that research undertaken in relation to red kangaroo population dynamics In NSW in 2010 suggested that if average rainfall dropped by more than 10 per cent in the NSW commercial harvest area, the massive reductions in kangaroo populations that would follow would mean no level of commercial shooting would be sustainable and the end of the commercial industry in NSW. (Jonzen et al 2010).

The Precautionary principle/precautionary decision-making

As previously discussed, there are significant ecological, economic and social uncertainties regarding the long term impacts of killing large numbers of kangaroos.

These uncertainties are exacerbated by the predictable (ie reduced rainfall) and unpredictable impacts of climate change on already degraded ecosystems where much of the commercial kangaroo industry operates in Victoria.

The Plan does not acknowledge or address these uncertainties or seek to incorporate them into adaptive management practices. This raises serious questions about the Victorian government’s capacity to manage risks and engage in proper and informed precautionary decision-making in relation to commercial kangaroo industry operations in Victoria.

Objective 6. Maintain openness, accountability and transparency

A diverse range of stakeholders are interested in kangaroo management. These include landholders, state and commonwealth agencies, pet food processors, kangaroo harvesters, animal welfare groups and members of the public. Community confidence in the design and implementation of the program, particularly in relation to protecting animal welfare and population sustainability, is essential to maintain social licence for the commercial kangaroo harvest. This is particularly important for Victoria, given that harvesting kangaroos specifically for commercial purposes is a new approach in this state. An important element of ensuring improved community confidence is providing a transparent and open account of the operation and outcomes of the commercial harvest and this plan.

The Plan does not meet Objective 6 nor does it comply with the basic requirements of good governance for the reasons set out below.

Equity is a key social concept of sustainable use. It embodies the idea that that each person within a society should have equal access to its natural resources and have an equal say in how those resources are distributed and used or enjoyed.

It is important to be clear that kangaroo populations in Victoria are a natural resource that belong to the Victorian community and that although the Victorian government is vested with legal responsibility for regulating and protecting wildlife it has an obligation to do so in the public interest (Yanner V Eaton (1999) 201 CLR 351 [10-31]).

This obligation requires that the Victorian government and the departments and agencies that have responsibility for the management of the state’s kangaroo populations:

  • Acts fairly and impartially in the exercise of its powers and discretion;
  • Encourages public engagement and facilitates public participation in policy development and decision-making in relation to kangaroo management;
  • Provides sufficient publicly available information for the community to make informed decisions about the adequacy and competence of kangaroo management in the state;
  • Is transparent in both the setting of policy and its decision-making; and
  • Is accountable for the outcomes of its policies, management actions and decision- making.

The Victorian government does not meet these any of these basic principles of good governance in its management of the state’s kangaroo management programs.

Social licence

A social licence to operate (SLO) refers to the level of acceptance or tacit approval by the community of industries and their operations, publicly owned resources. particularly in relation to the exploitation of publicly owned resources.

The kangaroo industry claims it has public acceptance and a social licence to operate but this is only because it and the governments that support it have systematically limited public participation in its policy development and decision-making, limited access to information and resisted providing basic transparency into kangaroo industry operations.

This is because the industry (rightly) fears public awareness of the realities and actual outcomes of industry operations. There is no question that if the Victorian community had open access to information about the true animal welfare and financial costs of the kangaroo industry, there would be significant and possibly irreparable damage to its social licence to operate.

As described above there are well-documented enduring animal welfare concerns associated with commercial kangaroo shooting including the frequency of adverse animal welfare events such as non-fatal wounding as well as the manner of euthanasia of the orphaned dependent young.

For decades, the kangaroo industry and the state governments that support and oversee it have resisted transparent monitoring and reporting of animal welfare outcomes and sought to limit public access to reliable data on this issue. It has instead dismissed public concerns as reflections of a lack of community knowledge or understanding.

This is the case in Victoria where both the industry and the Victorian government have engaged in deliberate and systematic efforts to limit, conceal or suppress public access to information in relation to kangaroo industry operations and in particular the animal welfare, ecological and financial costs to the Victorian community of this industry.

Public Participation

Public concern about the treatment of kangaroo populations that are targeted by the kangaroo industry has resulted in the establishment of government inquiries and reviews of this industry attract significant public feedback in other jurisdictions.

In the last 5 years alone, a review of the South Australian KMP in 2018 received 6,600 submissions, the review of the Code of Practice in 2020 received 17,000 submissions and the NSW Parliament’s Inquiry into Kangaroos in 2021 received hundreds of lengthy submissions together with live evidence from a range of experts and stakeholders.

The way in which this current review/consultation on the Plan is being conducted is just the latest example of the way in which the Victorian government has sought to limit public participation in the review and evaluation of kangaroo management within the state.

Public consultation is one of the key regulatory tools that can be employed to improve transparency, efficiency and effectiveness of regulation. The current review is not designed to achieve those goals but instead represents a deliberate effort to limit the number of responses and submissions to the review.

The structure of the review is unjustifiably restrictive in the following ways:

  • The three week time period allowed for responses (I note in this regard that almost all of the other consultations on Engage Victoria are much longer at around 6 weeks) is inadequate given the complexities of the issues involved and the fact that this period covers school holidays when many people are away or otherwise occupied;
  • The design and format of the survey and the framing of the questions posed limit questions and responses to the adequacy or otherwise of the goal and objectives of the Plan, excluding any comment on the broader issues associated with the DEECA’s woeful governance and oversight of this program; and
  • The review fails to provide any opportunity for members of the public or animal welfare and other community organisations to make long form submissions outside the survey format.

This attempt to limit public participation is part of a long standing and well-documented failure by DEECA and its predecessors to provide opportunities for the Victorian community to have a say its policy and program development, in its decision-making and in its review processes in relation to the management of the state’s environment, its wildlife and in particular its management of the state’s kangaroo populations.

In 2017, the Victorian Auditor-General’s Office noted that while all state government agencies have engagement policies, the real question is whether these are adequate and effective processes and methodologies to ensure that participation was meaningful, noting that incomplete public consultation had had a negative impact on public participation outcomes.

That report found that while DEECA had established public participation as a priority, it did not have an overarching framework or guidance for public participation and that this had led to a “consistently poor performance” in this area.

The following year in 2018 DEECA conducted a review of the ATCW permit system. This review was conducted via a survey on Engage Victoria. Apparently ignoring the VAGO’s criticism from the previous year, early consultation which was used to design the review was confined to landowners and vested economic interests and the discussion paper was limited to narrow questions focussed on reducing the administrative burden on landowners in applying for and obtaining ATCW permits.

Significant numbers of members of the community made submissions. There was no acknowledgment of this, nor was there any satisfactory conclusion to this consultation. No report has ever been released detailing the recommendations or outcomes of the review.

DEECA has also declined to provide any effective opportunities for community input and consultation in relation to its development and management of the commercial kangaroo industry in Victoria.

There was not any public consultation in relation to the development of the Kangaroo Pet Food Trial before it commenced in 2014 nor any public consultation during the entire time the Trial was in operation between 2014 and 2019.

There was also no public consultation in relation to the development of the first Kangaroo Management Plan in 2019, as the Minister at that time had indicated there would be in several media releases and despite the damning findings of the KFPT Evaluation Summary report in 2018.

Again, despite clear provisions in the “Review and Evaluation” sections of each of the 3 Kangaroo Management Plans (2019, 2020, 2021-2023) that have been in operation since 2019 that “Public consultation on this plan will occur during the life of the plan”, DEECA has not provided any such opportunity until the current narrow and time limited Engage Victoria survey review.

DEECA’s past failures to provide a proper opportunity for the Victorian community to have a say in the development and operation of these earlier Plans and its current effort to prevent it from having any meaningful input into the review of the 2021-2023 plan is and should be of significant concern to the Victorian community because these Plans:

  • Involve the appropriation of the state’s natural resources, resources which belong to the Victorian community, to the sole benefit of the commercial kangaroo industry whose only objective is consistent supply and maximisation of profits;
  • Do not acknowledge strong public sentiment about animal welfare or the intense interest of the broader Victorian community in the humane management and treatment of kangaroos;
  • Relate to a state government run program that relies on extensive public funding and use of scarce government resources to the benefit of an influential few.


Both transparency and accountability encompass timely, reliable, clear and relevant public reporting on the activities, operations and performance of regulating authorities.

There are significant issues regarding the provision of timely, publicly available information about commercial kangaroo industry operations in Victoria.

For example, the KPFT Evaluation Summary report which set out major failures in the design and outcomes of that program was compiled in 2018 but was not published until after the commencement of the permanent commercial industry in 2019.

Another example is the release of the annual kangaroo program reports (including both the commercial kangaroo industry and ACTW data) months after the end of the previous reporting year.

Neither the state government, nor the kangaroo industry provide any public access to information relating to measures used to monitor animal welfare or to reliable data describing animal welfare outcomes.

As described above, the Annual Program reports provide minimal information about compliance and enforcement. Significant gaps remain.

As well, and despite an explicit commitment to do so in the following terms:

“The kangaroo harvesting program will be regularly evaluated to assess its effectiveness (the impact of the program and success against its goals and objectives) and its efficiency (how processes, including governance and decision-making, are operating, and other measures such as costs and benefits”.

In the 2019, 2020 and the 2021-2023 Plans, the Victorian government has not at any time since the KPFT Evaluation Summary report in 2018 published any economic data or independent analysis regarding:

  • The financial viability of the industry;
  • The financial cost of the program to Victorian taxpayers; and
  • The economic value or contribution of the industry to the Victorian economy.

The failure to provide this information runs counter to recommendations made in the Senate Inquiry into the Utilisation of Australian Native Wildlife in 1998 which made it clear that:

  • Industries based on the commercial exploitation of wildlife had the potential to result in high administrative and regulatory costs to the public sector (as is the case with the Plan) and that there was a need to fully and publicly monitor those costs; and
  • Wildlife industries were niche industries with unquantified economic benefits and ensuring information relating to the assessment of the economic benefits of these programs was critical to any assessment of the value of these industries to regional economies and the broader economy.

The KPFT Evaluation Summary report noted that between 2014 and November 2018, the KPFT had cost at least $2.5 million and was diverting a significant amount of scarce government resources. That report confirmed:

  • The majority of DELWP costs were associated with staff. More than half of DELWP’s staff costs were for positions funded specifically for the KPFT, but this also included significant time of other wildlife officers and administrative staff;
  • While new resourcing provided for the KPFT was intended to enable increased compliance and enforcement efforts during the trial, the efforts of wildlife officers have almost entirely been dedicated to the application stage and reactive investigations of reports of illegal activity; and
  • The costs of the trial vastly outweighed the benefits with each dollar of taxpayer spending providing benefits to processors and landholders worth around 62 cents.

The kangaroo industry is an economically marginal industry in Australia but it is even more marginal in Victoria. Roughly, based on the current price of $1.10 per kilo and an average carcass weight of 23 kilos, the total gross value of product for the 184, 461 kangaroos killed in the industry in the last 3 years amounts to a total of around $4.5 million or $1.5 million per annum for the last 3 years. This figure is insignificant compared to the costs to the Victorian community of the state government’s financial support for the industry.

It is important to note that as DELWP, at the time, had sole responsibility for administering and oversight of the trial, these costs were limited to DELWP staffing costs. The expanded and permanent commercial kangaroo industry which came into operation in October 2019 has required far greater financial and staffing resources in order to operate.

Additional costs incurred under the 2019, 2020, 2021-2023 Plans include the costs of developing the Plans, the costs of staffing and administration of the Plan at DEECA, DJPR, Services Victoria and the GMA, the substantial additional costs of conducting annual population surveys (estimated at around $250,000-$300,000 pa) the extensive funding allocated to the Arthur Rylah Institute and Melbourne University for staffing and research into survey design, data collection and analysis for the setting of quota as well as producing annual quota and program reports. These costs do not include the costs of obtaining and allocating tags and monitoring compliance with food safety regulations.

FOI applications made to both DEECA and DJPR for this information have been met with delays and denial of access to relevant economic data.

The Victorian community have a right to information about these matters and the fact that scarce financial and technical resources are being directed away from desperately needed conservation efforts to the management and regulation of private commercial kangaroo industry operations.


For the reasons provided above, the Victorian state government and the departments and agencies responsible for the governance and operation of the commercial kangaroo industry in Victoria are neither transparent nor accountable to the public for the management or outcomes of this program in any meaningful way.


The Victorian government’s management of kangaroo populations in Victoria and in particular its management of the commercial kangaroo industry under the Plan is so deficient in meeting its own stated commitments in the Plan, in meeting community expectations or the requirements of good governance, that it warrants independent investigation and review.