CHAPTER 1 - INTRODUCTION

Commercial Utilisation of Australian Native Wildlife

CHAPTER 1 - INTRODUCTION

Commercial Use of Wildlife

1.1 Historically throughout the world, many species of wildlife have been hunted and farmed for food and other products, and in this way given a commercial value. More recently, however, commercial use of wildlife has come about through the deliberate placement of a value on a species to provide an incentive to preserve that species and indirectly its habitat. While hunting operations in the past sometimes harvested well beyond the capacity of the population to recover, modern commercial harvesting practices seek to operate at an 'ecologically sustainable' level.

1.2 This philosophy has emerged for two reasons. First, there is increasing concern that 'protectionist' [1] conservation practices are not working particularly well and have become very expensive to support while covering only a small proportion of the land. [2] Australia has a very poor history of conservation, having the highest modern species extinction rate in the world, [3] and the protection of wildlife in national parks will not necessarily ensure the conservation of biodiversity. [4] In addition, insufficient resources have been devoted to resolving the problems of habitat degradation and the detrimental impact of feral species. [5]

1.3 Second, practical experience overseas has shown that in some instances, placing a value on endangered wildlife has ironically resulted in greater protection of that species than when it had no commercial value. Much of this evidence has come from southern Africa where various commercial wildlife programs have passed ownership of wildlife back to indigenous people and thus provided incentives for them to manage their wildlife rather than to poach it.

1.4 Put together, these two concepts have resulted in a 'user-pays' system which is believed by protagonists to be more efficient and effective than a blanket 'protectionist' approach. When used wisely, it has the potential to result in more than just economic gain and can become an important conservation 'tool'. The whole approach, however, depends on whether it is managed in an ecologically and economically sustainable manner.

1.5 In addition to conservation of the species subject to commercialisation, a number of other benefits can arise from commercial utilisation of wildlife including:

1.6 However, while benefits to species and their habitats may arise from commercial utilisation of wildlife, there is also the potential for detrimental impacts to occur. Whether the impact is positive or negative (or neutral), depends on how well the activity is managed and the ability of agencies to monitor sustainability.

1.7 Generally, direct harvesting of wildlife has a greater potential to be detrimental than ranching which itself has greater potential to cause harm than farming of wildlife. The latter, if operated in a closed cycle system, is often neutral in terms of environmental impact. While seemingly benign forms of use such as nature-based tourism may superficially seem more acceptable than highly consumptive use, ecotourism too can damage species and habitats if not managed properly.

1.8 Because of complicated predator/prey relationships within the food chain, a significant change in the number of one species may have an impact on a range of other native species. For example, the removal of rabbits by the calicivirus has had an impact on food availability for birds of prey. Because of the great difficulty of measuring diffuse impact on an ecological system, incipient change may not be detected until an ecosystem has been irreversibly altered. The recent problem of rising salinity in agricultural areas of south-eastern Australia caused by land clearing activities many decades ago, is an excellent example.

1.9 Further, wild populations are susceptible to natural disasters such as fire, drought or flood. While the reproductive capacity and survival rates of animals on farms can be controlled, in the wild they cannot. When a market is created through the commercialisation of wildlife, demand must be satisfied and that demand does not decline simply because a natural disaster has reduced supply.

1.10 For these reasons, and others, the commercial use of wildlife as a conservation tool is not universally accepted and controversy exists among governments, scientists, conservation groups and animal rights organisations as to the degree to which commercial utilisation of wildlife is appropriate and its efficacy as a conservation tool.

1.11 At one extreme, is the view that animals have an intrinsic right to exist untouched by human interference and that therefore they should not be subject to any form of use, be it commercial or otherwise. The concept of ecologically sustainable use of wildlife has been criticised by these groups as 'a utopian dream pursued at the expense of our natural heritage', [6] an 'unrealistic nightmare', [7] and a 'polite, non-confrontationist theory' which is 'tragic in effect'. [8]

1.12 Close to this position is the philosophical view that native wildlife has an intrinsic value and that its preservation, which is considered to be essential, requires no other rationale. There is a strongly held belief in Australia that it is important to conserve wildlife and its habitat. 'This urge to protect is not motivated by economic gain, or even by a desire to personally experience the natural environment. It is motivated by a simple belief that protecting the natural world is the right thing to do'. [9] Groups which oppose commercial use of wildlife claim that it demeans the inherent nature of humans to behave altruistically and diminishes existing values by reducing our relationship with the natural world to the values of the market place. [10]

1.13 However, there is clearly a hierarchy of intrinsic worth for wildlife in Australia – the 'warm cuddly' syndrome where mammals, and particularly the most attractive mammals to humans, are deemed to be of greater intrinsic worth than, say, reptiles or frogs. [11] So while there has been very little commercialisation of mammals allowed in Australia (and even outrage at the suggestion of culling superabundant koalas [12]), commercial development of crocodiles and to a very large extent fisheries has gone ahead. [13]

1.14 While accepting that some animals may be used, some conservation groups believe that the sustainable harvesting of wildlife and in particular plants, is not possible under any circumstances because taking part of an ecosystem away always has a detrimental impact on other parts of that ecosystem. These groups argue that management tools used to regulate the sustainable use of wildlife, including quotas and 'seasons', do not work, primarily because insufficient resources are put into monitoring and enforcement.

1.15 Next comes the view, held by many scientists and government instrumentalities, that in certain circumstances and with appropriate regulations, wildlife utilisation may be at worst ecologically neutral and at best aid conservation by providing incentives to preserve species and habitat. In the opinion of the then Head of the Biodiversity Group of Environment Australia, Dr Peter Bridgewater, who gave evidence to the Committee: 'Australia has an opportunity to use its undoubted expertise in this area to make sure that we are not only setting our own best practice standards, but we are in fact able to lead globally, by example, what is happening'. [14]

1.16 Finally, those people involved in wildlife industries ipso facto fully support commercial utilisation of wildlife. They do so now, however, with much greater regard for the species they utilise. This is for two reasons. First, as history has shown, to be economically sustainable the industry must manage the species having regard to its biological sustainability. Second, government regulation of wildlife industries are, for the most part, now much more stringent than before. Industry groups believe that they play a significant role in managing a number of native species which, due to changed environmental conditions, now occur in superabundance (such as possums in Tasmania and kangaroos in the rangelands of NSW and Queensland). They also provide a source of employment and flow-on benefits, particularly to rural areas. Products based on native animals, such as meat and leather, are increasing in market share and appear set to play an increasingly important role in export markets in the future.

1.17 The controversy in Australia over commercial utilisation of wildlife was eloquently summed up in the submission by the Federal Department of Environment, Sport and Territories: [15]

The increasing recognition by conservation agencies of the importance of the commercial use of wildlife as a conservation tool has been viewed with concern by some individuals and lobby groups who are philosophically opposed to the commercial use of wildlife, and the killing of animals in particular. The debate has become somewhat polarised, perhaps because it touches on core values of people, and perhaps also due to the difference in focus between the importance of the population (which is the level at which conservation biologists operate) and the importance of the individual (which is often the focus of the animal rights movement). It should be noted that conservation biologists do not focus conservation effort at the level of individual animals and plants as all individuals will die, whereas genes, populations and ecosystems can, with appropriate management, persist for thousands of years. [16]

1.18 There is a second reason for increasing interest in commercial utilisation of wildlife in Australia and this is that wildlife industries may offer opportunities to broaden the income-base of struggling rural businesses. Degradation of marginal agricultural land which has resulted in reduced productivity and increased fluctuation in profitability of traditional income sources (sheep and cattle) has led to an upsurge in interest in alternative agriculture enterprises. Over the last decade, this trend has seen a wide range of animals and, particularly, plants assessed for their commercial potential. New industries include emu farming, wildflower picking and production, essential oil extraction, inland aquaculture of marine species, and bushfood harvesting and horticulture.

1.19 As well as a commercial impetus, there is an ecological reason for this movement: the realisation that the Australian landscape is for the most part better suited to production of indigenous species than exotic species. The fact that endemic animal species have co-evolved with their habitat makes them intrinsically better adapted to environmental constraints and thus they represent a more benign form of land use. Wildlife enterprises present a strategy whereby traditional agricultural practices could be replaced, partially or totally, with activities that would allow natural habitats to recover while still providing an income to landowners. In addition, the financial security that could arise from income diversification may allow increased returns to be directed into habitat recovery and protection.

Areas of Commercialisation

1.20 The economic use of Australian native wildlife has been limited in the past by a number of factors including regulations, lack of entrepreneurs and lack of markets. These factors all relate to government restriction on the use and export of wildlife, particularly live fauna. Thus the commercial activities that have occurred have come about in an ad hoc way, rather than through coordinated or systematic processes. In general, with the exception of fisheries and marine mammals (seals and whales), flora has been much more extensively commercialised than fauna.

1.21 In addition to timber production, there are seven main areas of commercialisation of flora:

1.22 In the past, commercialisation of vertebrate fauna has mainly arisen from by-product use of pest culling (such as kangaroos and wallabies) or the taking of abundant species for specific products (for example, koalas and possums for fur). In addition, there has been limited use of reptiles for venom. However, in the last decade commercialisation of several other native animal species has commenced (primarily emus and crocodiles), and the pet trade in reptiles, birds and mammals has expanded considerably, particularly overseas. There is also some use of insects and marine invertebrates such as jellyfish, coral, shells and pearls.

Types of Commercialisation

1.23 The term 'commercial utilisation of wildlife' encompasses a spectrum of activities, ranging from high intensity consumptive use, such as farming of animals and the manufacture of products from those animals, to low intensity, supportive 'management' of wild populations for non-destructive, benign purposes such as ecotourism. There are, however, a number of broad types of commercial utilisation of wildlife, each with its own term: hunting, harvesting, ranching, farming, and nature-based or ecotourism. To these can be added floriculture, aviculture, mariculture and aquaculture. There is also the use of wildlife by indigenous people provided for under various state laws, termed 'subsistence' use, which although not strictly commercial, has a commercial value in the sense that it replaces food which would otherwise be purchased. As wildlife industries develop they generally move through a spectrum of activities from hunting to harvesting (or ranching) and finally, if appropriate, to farming. Generally also, intensive farming makes the least contribution to wildlife conservation and maintenance of biodiversity and harvesting, ranching and hunting the most, if they result in habitat preservation.

Hunting

1.24 For non-indigenous people, hunting is a form of recreation. In Australia, there are over one million registered shooters, 85 per cent of whom are described as hunters. [17] It is important to make the distinction between recreational hunters and commercial hunting operations, on the one hand, and professional and amateur 'culling' operations on the other. Recreational hunters generally travel on foot and hunt at dusk or dawn, or during the day. 'Culling' operations are generally carried out at night with the aid of vehicles and spotlights. 'Big game' hunting organised by specialist tour operators has become a lucrative business in some parts of the world. Utilisation may be a major ethical consideration among modern recreational hunters, and products from hunting are used for food, clothing, items for sale and trophies. [18]

Harvesting

1.25 Harvesting involves the continual or intermittent removal of wildlife living in a free-range wild population through either the collection of plants or plant parts, the live capture of animals, the killing of animals, or the collection of eggs for immediate use. With animals, large adults are usually preferred. Examples of harvesting include commercial removal of kangaroos and possums from the wild, bushfood collection, wildflower collection, seed collection, eucalyptus oil extraction and yacca gum extraction. [19] The major disadvantage of wildlife harvesting is that it is very difficult to monitor the impact that it will have on population sustainability, particularly in the long-term.

Ranching

1.26 Ranching involves the taking of animals from the wild to raise in a controlled environment for subsequent consumptive use for wildlife products, or as live animal displays. In most cases, eggs or juveniles are taken. Examples include crocodile and black cockatoo ranching programs in the Northern Territory. Ranched wildlife are sometimes returned to the wild.

Farming

1.27 Farming involves the breeding of wildlife in an enclosed environment, or the cultivation of native plants in nurseries. Offspring are used for products. The most important determinant of wildlife 'farming' is that after initial breeding stock are removed from the wild, all subsequent breeding is carried out 'in-house' and usually no more animals are taken. This is termed 'closed-cycle' or 'captive' breeding. Farmed wildlife are not usually permitted to be returned to the wild. When native animals are farmed their status may change. In Tasmania, for example, once an animal is farmed or husbanded it is subject to another set of Australian standards for meat production, as opposed to game meat production where an animal is field-shot and subject to different standards. [20]

Aviculture

1.28 Aviculture is a specialist term for the captive breeding of birds, whether native or exotic. In contrast to birds that are farmed commercially for food (such as chickens, turkeys and quail), these birds are kept, bred and sold primarily for their intrinsic worth. While most aviculturists breed native birds as a hobby, the industry has considerable economic value because of the large number of birds that are bought and sold and because of associated expenditure on infrastructure which at times may be considerable.

Horticulture and Floriculture

1.29 Horticulture is the propagation of native plants by nurseries for garden and civic plantings. Floriculture is the use of native flowers and plant parts (such as leaves, stems and seed-pods) in the cut flower industry. Flowers are either harvested under licence from the bush which provides an incentive to preserve habitat or, increasingly, cultivated by horticulturalists.

Aquaculture and Mariculture

1.30 Aquaculture is the closed-cycle farming of aquatic species in large tanks or ponds. Species farmed include abalone, prawns, trout, barramundi, eels, marron (freshwater crayfish), freshwater yabbies and redclaw crayfish. There is increasing interest in inland production of marine fish (for example, snapper, mulloway, black bream, and silver perch). Mariculture is the farming of saltwater aquatic species in cages or on racks on leases along the coastline or at sea. Species farmed include a number of fish species, abalone, coral, and oysters. [21]

Subsistence Use

1.31 Various state laws provide for the use of wildlife by Aboriginal people and Torres Strait Islanders for food or cultural purposes ('subsistence use'). The circumstances under which Aboriginal people can remove wildlife are specified in each statute. A considerable amount of wildlife is consumed in this way.

Wildlife Parks and Tourism

1.32 This area has expanded greatly over the past two decades and is seen by some as the economic 'panacea' for biodiversity conservation. In addition to public zoos, there are now private zoos, private wildlife parks and a burgeoning industry in ecotourism. Almost every area that has wilderness, great natural beauty or abundant wildlife is being used or considered for ecotourism.

Definitions

Wildlife

1.33 To many people, the concept of wildlife is clear: the word means 'animals and plants that live in the wild'. However, what is not clear is how far this definition extends when wildlife and, particularly, animals are taken from the wild and kept in a captive environment. In short, when does wildlife become domesticated?

1.34 The Wildlife Protection (Regulation of Exports and Imports) Act 1982 does not define 'wildlife'. According to Environment Australia, however, the word 'should be interpreted in its broader sense and (unless indicated otherwise) refers to all animals and plants subject to regulation under the Act'. [22] This is a somewhat circular definition and in practical terms means that wildlife is anything that the legislature decides is wildlife, whether it exists in its native habitat or in a cage.

1.35 The Oxford dictionary defines 'wild' as 'not domesticated or cultivated', the converse of which is that domesticated animals or cultivated plants are 'not-wild'. The Macquarie dictionary defines 'wild' as 'living in a state of nature, as animals that have not been tamed or domesticated' and it defines 'wildlife' as 'animals living in their natural habitat'.

1.36 To many people the expression 'wildlife' has this meaning, and if an animal is taken from the wild and kept in captivity, it is still considered to be 'wildlife'. Associated with this is a common perception that a caged 'wild' animal has just recently come from its natural habitat and could easily go back to its natural habitat.

1.37 In its submission to the Committee, Department of Environment also defined wildlife in the sense of being 'not domesticated', [23] and many of the state statutes also define wildlife in this way. The South Australian National Parks and Wildlife Act 1972, for example, defines wildlife as meaning all plants and animals indigenous to Australia existing apart from cultivation or domestication. [24]

1.38 However, this loose definition of wildlife being 'not domesticated' produces a 'grey' area because once a group of animals belonging to an endemic species have been brought into captivity and bred for a number of generations their status subtly changes. Already state governments have introduced legislation to ensure that captive-bred native animals such as emus and crocodiles are not returned to the wild and have introduced penalties for letting them escape. As stated by Animal Welfare (ACT) in its submission to the Committee, this regulation is based on the philosophy that: 'Once a species has been selectively bred in captivity, it is no longer a wild animal and its reintroduction to the wild, even if animals survive, will actively threaten any of the wild species that remain, both genetically and competitively'. [25] Yet these animals (emus, crocodiles and many species of native birds), are not normally classified as 'domesticated' or 'livestock'. If they were, a whole new set of statutes would apply to them, and the Wildlife Protection (Regulation of Exports and Imports) Act 1982 would not.

1.39 Curiously, while some submissions questioned at what point an animal stopped being 'wildlife' and became 'livestock', [26] an answer was forthcoming only from the aviculture industry. In noting that some native birds have been bred in captivity for so many generations that they do not even look like their wild ancestors (being an entirely new colour or size variation), the avicultural industry maintains that second or later generation native birds, bred in captivity, should no longer be defined as 'wildlife' but instead should be defined as 'livestock'. This concept is supported by wildlife biologist Dr John Wamsley, who stated while discussing the concept of 'commercialisation of wildlife': '… I do not believe that an animal can be called wildlife once it has been put in a cage'. [27]

1.40 The significance of this discussion becomes more apparent when the issue of export of live native wildlife is considered. While the export of live native animals is currently prohibited under the Wildlife Protection (Regulation of Exports and Imports) Act 1982, the export of domestic animals is not. If a point is determined when farmed wildlife becomes domesticated livestock, then such animals could arguably be exported. Predictably, pressure to address the question of when wildlife becomes domesticated livestock will increase substantially in the future as more wildlife is subject to farming and, like aviary bred birds, become further removed genetically from their ancestors.

Native Wildlife

1.41 In its submission to the Committee, the Department of Environment defined 'native wildlife' as 'plants and animals established in Australia prior to European settlement in 1788'. [28]

Commercial Use or Commercial Utilisation

1.42 The Department of Environment defined 'commercial use (or commercial utilisation)' as:

The collection, harvesting, processing and preparation for sale of native fauna and flora and of products derived from these. Commercial uses may be consumptive, or non-consumptive, including eco-tourism and tourism. 'Use' and 'utilisation' are considered synonymous.

1.43 However, the Cape York Herpetological Society noted in its submission that the word 'commercial' was an evocative word which could be interpreted by different people in different ways. Indeed, the Society suggested that, to animal rights and welfare groups, the word commercial would prompt an emphatic 'knee-jerk' reaction which would oppose any and all commercial utilisation of wildlife, even those activities which were carried out on a scale too small to be normally considered 'commercial', or produce any significant economic return. The Society defined 'commercial' as large scale harvesting of animals which are distributed through more than one level. [29] The World Wide Fund for Nature (WWF) defined commercial use as 'the management of wild, native species for profit'. [30]

Consumptive Use and Non-Consumptive Use

1.44 The Department of Environment defined consumptive use and non-consumptive use as follows:

Consumptive use:

An activity by which human beings derive benefit from a population or ecosystem by permanently removing organisms or their products from the population or ecosystem concerned. Examples of uses that permanently remove the whole organisms are: hunting, egg collecting, trapping, live capturing, fishing, shellfish gathering, logging and plant gathering. Examples of uses that permanently remove only certain products, and not the whole organism, are: tapping wild trees for exudates and similar activities involving animals (for example, milking wild snakes for venom); gathering fruits; collecting honey from wild bees; cutting plants for foliage; and putting livestock to graze on wild vegetation.

Non-consumptive use:

An activity by which human beings derive benefit from a population or ecosystem without permanently removing organisms or their products from the population or ecosystem concerned. Examples include wildlife viewing, visiting sacred sites and other culturally important ecosystems, and managing wild insects for crop pollination.

1.45 However, Mr Peter Johnson, Chief Executive Trustee of the African Gamebird Research Education and Development Trust, did not agree that there was any difference between consumptive and non-consumptive use of wildlife. As he explained in evidence to the Committee, there is a form of consumption in every type of wildlife use. When asked whether he agreed that tourists simply watching elephants was a non-consumptive form of wildlife utilisation he replied:

No, it is as consumptive a use as a dead elephant, because the moment you come and you want to go and see that elephant, I have to find the transport to get you there. I have to provide meals. I have to go into the water supply. I have to go into every single thing. … If I produce elephants, they are as good dead as they are alive. They are good transferred, that is, caught alive and re-put somewhere else, or eaten, or used to restock other areas or just seen in situ by the visitor. [31]

1.46 When asked whether some forms of use were more 'correct' than others, or more desirable, Mr Johnson stated: 'All forms of use are correct provided that they are sustainable'. [32]

1.47 Consumptive use was defined by WWF as any use that involved removal of individuals from the wild population and described three categories of consumptive use:

Sustainable Use

1.48 'Sustainable use' is defined by the Department of Environment as:

An activity by which human beings derive benefit without reducing the future use potential, or impairing the long term viability, of either the species being used or other species; and is compatible with maintenance of the long term viability of the supporting or dependent ecosystems. It can be applied to both non-consumptive uses such as wildlife watching and tourism as well as consumptive use (subsistence use or commercial harvesting).

1.49 The IUCN defines 'sustainable' use as: 'Use of a population or ecosystem at a rate within its capacity for renewal and in a manner compatible with the conservation of the diversity and long-term viability of the resource and its associated ecosystems'. [34]

Biodiversity

1.50 Biodiversity is generally defined in terms of: 'The variety of all life forms - the different plants, animals and microorganisms, the genes they contain, and the ecosystems of which they form part'. [35] Biodiversity comprises three elements: genetics, species, and ecosystem diversity. [36]

Precautionary Principle

1.51 The Rio Declaration of Environment and Development outlined a 'precautionary principle' which has been used as a guideline to minimise risk when proposals for commercial utilisation of wildlife are considered. [37] This principle is defined as:

Where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.

In the application of the precautionary principle, public and private decisions should be guided by:

(i) careful evaluation to avoid, wherever practicable, serious or irreversible damage to the environment; and

(ii) an assessment of the risk-weighted consequences of various options.

Conservation, Animal Welfare and Animal Rights

1.52 The committee notes that there is a clear distinction between the concepts of 'conservation', 'animal welfare' and 'animal rights' (also termed 'animal liberation') and that the opinions of groups having each of these concepts as their prime objective differ. [38]

1.53 Conservation groups are more concerned with collective good and recognise that individual rights may need to be waived in some instances for the ultimate benefit of the environment. Some conservation groups accept commercial utilisation of wildlife, provided that it is ecologically sustainable and has no detrimental impact on the environment, and provided that it can be shown to be beneficial to conservation.

1.54 The concept of 'animal welfare' recognises that utilisation of animals occurs and seeks to minimise cruelty towards them and thereby prevent pain and suffering. The concept of 'animal rights' is based on the philosophy that all animals are sentient beings and people have no right to use any animal in any way. A network of 'animal liberation' organisations exists throughout first world countries which espouse this philosophy and which actively campaign to reduce commercial use of animals and to highlight the suffering experienced by them.

1.55 The Committee also notes that owing to the very public activities of animal rights groups in protesting against commercial utilisation of wildlife, their philosophies are often taken by others to be shared by all conservation groups. [39] While this may be the case in some instances, it is not true in all instances. In fact, in some cases the views of some conservation groups may be diametrically opposed to one another. This misunderstanding is not unique to Australia, nor is it new:

The international conservation lobby appears often indistinguishable from the animal rights movement, which is unfortunate and potentially damaging for conservation … The two are quite distinct but with limited areas of overlap. The one is rooted primarily in science, the other in individual human values. The conservation lobby, well meaning as it is, must look first to its scientific principles before being seduced by emotional issues that are attractive 'causes' for the raising of public contributions. [40]

Other Recent Studies

1.56 Over the last five years a number of major reports and conference proceedings have been published in Australia on sustainable utilisation of Australian native wildlife. These include, in reverse chronological order:

Footnotes

[1] In 'protectionist' systems large areas of land are secured from any commercial use in designated areas (termed nature reserves, national parks, etc). This concept of 'protected' fauna and flora extends to most native animals and some plants on other land (such as crown land, freehold and leasehold).

[2] See for example, Evidence, pp. RRA&T 89, 116, 196, 667, 676, 722, 824, Submission Nos 77, 103, 322.

[3] Over the last 200 years, more than 400 plant and animal species have become extinct and large areas of habitat lost through urbanisation and agriculture.

[4] Evidence, p. RRA&T 697, Submission No. 200.

[5] See for example Submission No.s 40, 116.

[6] Submission No. 57, p. 1.

[7] Diekman, B (ed) 1995 Sustainable Use of Wildlife: Utopian Dream or Unrealistic Nightmare?, Proceedings of a Seminar on the Commercial Exploitation of Wildlife held at the Royal North Shore Hospital, St Leonards, Sydney, 23-24 September, by the Nature Conservation Council of NSW Inc.

[8] Submission No. 57, Attachment p. 4.

[9] Koalas and Tourism: An Economic Evaluation by Professor Tor Hundloe & Dr Clive Hamilton, The Australia Institute, Discussion Paper No. 13, July 1997, ISSN 1322-5421, p. 3.

[10] Submission No. 339, p. 1.

[11] Evidence, p. RRA&T 383, Submission No. 157, p. 7.

[12] Herald Sun, Shoot Them: Koalas Plea, Sunday 26 April 1998, pp. 1, 3.

[13] Evidence, p. RRA&T 695.

[14] Evidence, pp. RRA&T 16-17.

[15] Hereafter referred to as the Department of Environment.

[16] Submission No. 198, p. 22.

[17] Submission No. 118, Attachment: Hunting, Sustainable Utilisation and Conservation, in Diekman, B (ed), op cit, pp. 1-2.

[18] Ibid.

[19] Submission No. 318, p. 9.

[20] Evidence, p. RRA&T 905.

[21] For more detail see RIRDC 1998 The New Rural Industries A Handbook for Farmers and Investors, edited by K W Hyde, ISBN 0642246904, p. 85ff.

[22] An Outline of the Wildlife Protection Act - Notice 01, Information Sheet No. 1 Effective from 2 May 1996. Http://www.biodiversity.environment.gov.au/plants/wildlife/inf0.1htm., p. 1.

[23] Wildlife was defined as: 'a generic term referring to both live plants and animals living in an undomesticated state'; Submission No. 198, p.1.

[24] Submission No. 318, p. 4.

[25] Submission No. 66, p. 8.

[26] See for example, Submission No. 203, p. 6.

[27] Submission No. 77, p. 2.

[28] Submission No. 198, p.1.

[29] Submission No. 308, p. 1.

[30] Submission No. 102, p. 2.

[31] Evidence, p. RRA&T 1061; see also Submission No.s 48 and 61, for example, which argue that ecotourism is an invasive form of commercial activity.

[32] Evidence, p. RRA&T 1062.

[33] Submission No. 102, pp. 2-4.

[34] As quoted by Submission No. 318, p. 5.

[35] Submission No. 198, p. 2.

[36] Submission No. 199, p. 1.

[37] Rio de Janeiro 3-14 June 1992.

[38] Submission No. 157, p. 6.

[39] Supplementary Submission No. 175, p. 1.

[40] Grossman D, Ferrar T A & du Plessis P C 1992 Socio-Economic Factors Influencing Conservation in South Africa TRAFFIC Bulletin, Vol. 13 (1): 29-31.