CHAPTER 8 - CONDITIONS OF
COMMERCIAL USE OF WILDLIFE
Valuing Wildlife
8.1 As documented in Part II of this report, many wildlife industries already exist in Australia. Federal
and state governments support ecologically sustainable commercial utilisation of wildlife in policy and in
practice. In short, commercial utilisation of wildlife is a reality, not a proposition.
8.2 There is no debate over whether wildlife should be given a value. The debate centres on what value
it should be given: purely intrinsic worth, a 'common good' value, a legislative value, a scientific value, a
recreational value, a financial value, an economic value, or any combination of these values. While many
people would like to believe that attributing a purely intrinsic worth to wildlife or habitat should be
sufficient to preserve it, the practical reality is that in many cases this philosophy has not resulted in its
protection. The service provided by attributing to wildlife an economic value is that it allows natural
habitat to compete on an equal basis with other land uses which already have a clear economic value
(such as farming, mining or residential land).
8.3 Whether individual species should be commercialised for financial gain is a separate question, the
answer to which is not simple. This is in part because commercial utilisation of wildlife has now been
strongly linked with the concept of serving a good to conservation. But commercial utilisation of wildlife
does not necessarily have to be linked to conservation benefit and separating these two concepts can
allow a more thorough examination of the conditions under which commercial use may occur.
Circumstances of Commercial Use of Wildlife
8.4 As noted in Chapter Two, a spectrum of views on the desirability of commercial utilisation of wildlife
was presented in evidence to the Committee. This range of views can be put into a hierarchy on the
basis of the different degrees to which various sectors of the community accept commercial use of
wildlife (Figure 8.1).
- No commercial use of native wildlife.
- Commercial use of native plants but not animals, with the exception of ecotourism.
- Commercial use of wildlife must not result in detrimental ecological impacts; it must be proven
beyond reasonable doubt to be ecologically sustainable; it must make a positive contribution to
conservation and biodiversity; sound government regulation and management must be available;
and it must be based on the precautionary principle.
- Commercial use of wildlife must not result in detrimental ecological impacts and must be proven
beyond reasonable doubt to be ecologically sustainable; but may be neutral in terms of impact on
biodiversity and the environment.
- Commercial use of wildlife may occur as the market sees fit.
Figure 8.1 - Hierarchy of Limitations to Commercial Use of Wildlife
1. No Commercial Use of Wildlife
8.5 This position is extreme and only proposed by a few people who believe that it is acceptable only to
use plant and animal species that have already been domesticated. Even these people, however, agree
that ecotourism is acceptable.
2. Commercial Use Of Native Plants But Not Animals, Plus Ecotourism.
8.6 This position is held by animal rights groups and some conservation groups which share the same
philosophy. No use of animals is countenanced. Use of plants and ecotourism must be strictly regulated
to ensure a conservation benefit and that there is no harm to individual animals.
8.7 However, to place this view in a historical perspective, it is worth quoting scientist Professor Gordon
Grigg:
For thousands of years humans relied on harvests of wildlife. Only comparatively recently in human
history has it become the norm to depend on domesticated plants and animals. A consequence has been
the gradual downgrading of the perception of the usefulness of wildlife, to the point where its persistence,
its conservation, is now seen frequently as a luxury we cannot afford. It has reached the point that
people who support wildlife conservation are usually lumped under the pejorative term 'greenie' and,
somehow, the extraordinary notion has grown amongst many conservation-minded people that
consumptive use of wildlife is unnatural, unethical and immoral. [1]
8.8 In agreement with Professor Grigg, the Committee rejects the blanket philosophy that the
commercial utilisation of wild animals is wrong simply for ethical reasons. The Committee believes that a
total prohibition on all use of all animals is neither practical nor in Australia's best economic interests.
Commercial utilisation of wildlife is not simply a question of whether animals are killed, nor is it simply a
way in which wildlife can be made it pay its own way. Commercial utilisation of wildlife is a complex
social tool that can be used is a variety of circumstances to benefit both biodiversity conservation and the
economy. The good function that animal rights groups serve is to remind society of the need for best
practice in animal welfare matters.
3. Commercial Use Must Have A Conservation Benefit
8.9 There is clear common agreement that commercial utilisation of wildlife should not be of significant
detriment to the species subject to utilisation, nor to non-target species and their habitats The next
criteria is whether commercial use must have a direct conservation benefit.
8.10 Some witnesses saw clearly a need to link wildlife use with conservation benefit. For example, the
view held by Worldwide Fund for Nature is that commercial utilisation of wildlife should not occur unless
there is a net conservation benefit. Dr John Wamsley agreed with this, stating in his submission: 'I do not
believe that any person should benefit from the commercialisation of our wildlife without that
commercialisation being of demonstrable benefit to that same wildlife'. [2] The Department of
Environment went so far as to recommend that 'industry levies on ex-situ [captive-breeding] enterprises
should be explored by Commonwealth, State and Territory Governments to contribute to conservation
of wild stock'. [3]
8.11 Dr Frank Carrick, Senior Lecturer in Zoology at the University of Queensland, argued in his
submission that 'an important justification of any commercial exploitation (particularly a consumptive use)
of wildlife must be that it contributes to a reduction in pressures on the Australian environment'. [4] Dr
Carrick, noted that when considering the commercial utilisation of wildlife it was important to distinguish
between: (a) those few species that have benefited from European settlement and have increased in
distribution and abundance; and (b) the much more numerous group (in terms of species) which have
mostly declined in the face of habitat destruction. Dr Carrick noted that there may be a case for
commercial use of the first category (superabundant species), but that the overriding consideration must
be the survival of those species in the wild.
8.12 When considering the second group of species, Dr Carrick noted that most of them were 'just
holding their own or in most cases declining'. He argued that 'for these species, any commercial use
must be subservient to and compatible with conservation of the species'. He went on to qualify this
further by stating: 'indeed any ethical commercial use (including ecotourism) must provide for enhancing
the conservation outcomes for the species in its habitat' and that any use of 'non-pest' species must be
from farmed stock. [5]
4. Commercial Utilisation Of Wildlife Without Conditional Conservation Benefit
8.13 The IUCN has a broader view and suggests that sustainable use of wildlife can provide an
alternative means of supplementary land use, and be consistent with conservation, provided there are
scientifically sound monitoring mechanisms in place to ensure the use is maintained at levels which can be
sustained by the wild populations, without adversely affecting the species role in the ecosystem, or the
ecosystem itself (Recommendation 18.24 of the General Assembly).
8.14 The Western Australian Government argued that the condition of 'non-detriment' to conservation
was preferable to that of 'positive benefit', and could be more readily measured. The Government
recommended that the condition 'non-detriment' be applied to all circumstances of commercial utilisation
of wildlife. [6]
5. Commercial Use as Dictated by Market Forces
8.15 While not stated directly, this view prevails within some sectors of the community, particularly
within industries where wildlife is kept in closed-cycle operations. Because these systems are so
removed from the natural environment, impact on the environment is not considered to be relevant, and
there is no perceived need for a link with biodiversity conservation. Captive-bred wildlife becomes a
commodity in the same way that sheep or cattle are commodities, and the prime consideration is
achieving a beneficial financial outcome. Examples include aquaculture and mariculture, plant species
brought into horticulture (native garden plants) and plantations of trees such as tea tree and macadamia
nuts.
Conservation Benefit
8.16 Interestingly, despite the strong support for the idea that wildlife must have a conservation benefit,
there are a number of wildlife-based industries already operating in Australia which do not provide a
direct benefit to conservation. These include farming of emus and crocodiles, aviculture, inland
aquaculture, the harvesting of jelly fish and seaweed, and the extraction of essential oils. However, it
could be argued that all of these industries provide a range of indirect benefits to conservation (see
Paragraph 4.74).
8.17 This observation leads to the question: How direct must the conservation benefit be? All wildlife
industries in Australia which pay tax to the Federal government provide revenue which may indirectly
benefit conservation through support of relevant federal government agencies. Is this a sufficient level of
contribution to biodiversity conservation?
8.18 A more revealing question, however, is to ask: Why should there be a conservation benefit at all?
Although this question was never directly addressed in evidence to the Committee, the answer may well
lie in the proposition that because commercial utilisation of wildlife has a high risk of environmental
impact, there should be some built-in 'insurance' mechanism to counter that risk. This 'insurance' could
be provided by requiring that commercial utilisation of wildlife must have a net conservation benefit. It
would seem logical then to offset 'risk' with an insurance 'premium': the higher the risk of detrimental
environmental impact, the higher the requirement for conservation benefit. Thus wildlife farming activities,
which have a low risk of detrimental environmental impact, should have a lesser requirement for
conservation benefit. Harvesting and ranching, which have a higher risk of detrimental environmental
impact, should have a higher requirement for conservation benefit.
Principles Applicable to Commercial Utilisation of Wildlife
8.19 What then are the broad conditions under which commercial utilisation of wildlife should operate?
In evidence to the Committee a wide range of suggestions were made. [7] Of these, the Committee
concludes that the following principles are important.
- There should be broad legislative frameworks within which proposals for the commercial use of
wildlife can be approved, regulated and administered. Regulatory structures should be consistent
across legislatures and allow industry to operate at maximum efficiency.
- The principle of ecologically sustainable development should underpin any assessment of
commercial use of wildlife and before any approval is given for commercial utilisation of wildlife, it
should be proven beyond reasonable doubt that such use will be ecologically sustainable.
- In granting approval for proposals to use wildlife on a commercial basis, governments should take
into account the precautionary principle and the principle of inter-generational equity.
- Proposals for the commercial use of wildlife need to be identified and managed on a case-by-case
basis. The conditions of commercialisation that are appropriate to each animal must be
determined by the biology of the species, a basic knowledge of which should be ascertained prior
to commencement of the proposal. Information about the species should include its distribution,
abundance and demography. However, lack of detailed information about a species should not be
used as an argument against the commencement of commercialisation on a trial basis.
- The risk of overharvesting should be low and legal harvesting should be set at a level well below
the scientifically calculated off-take rate. Where a legitimate increase in quota is indicated, it
should still incorporate a safety margin. There should be a low risk of 'by-catch' of non-target
species.
- The management of commercial use of wildlife must be adaptive so that managers can respond to
changing circumstances.
- The management of commercial use of wildlife must include monitoring of population levels and
demography; large proposals must include provision for independent monitoring.
- The management of commercial use of wildlife must include monitoring of environmental impacts
through an EIS procedure. Small, diffuse commercial harvesting programs must be monitored by
a centralised agency to allow assessment of total impact across each state or across Australia.
- The risk of detrimental environmental impact should be matched to the requirement for
conservation benefit. Commercial utilisation of wildlife should never be a threat to the
conservation status of a species or population.
- Decision making, public accountability and monitoring processes must be transparent and
accessible.
- Regulations should be in place to ensure that the treatment of animals is humane at all times and
that all wildlife programs endeavour to achieve the highest standard possible for animal welfare; as
far as possible, all suffering and cruelty should be eliminated.
- It is undesirable to remove adult birds from the wild for any purpose other than to provide
breeding stock, either for a closed-cycle breeding program or to breed up numbers of rare or
endangered species.
- Governments should make efforts to ensure that there are no unnecessary economic, legal or
administrative barriers to inhibit wildlife from realising its competitive advantage as a land use.
- In general, the principles of 'user-pays' and 'cost-recovery' should be applied in the administration
of wildlife industries but in calculating these costs community benefits should also be taken into
account.
- Wherever possible, there should be local community participation in and benefit from
commercialisation of wildlife.
Footnotes
[1] Grigg, G New Directions in Conservation, Abstract of a paper presented at a conference on
Conservation Through Sustainable Use of Wildlife Hosted by the Australian and New Zealand
Environment and Conservation Council and the Centre for Conservation Biology, University of
Queensland, University of Queensland.
[2] Supplementary Submission No. 77, p. 5.
[3] Submission No. 198, p. 28 (Recommendation 4).
[4] Submission No. 323, p. 1.
[5] Submission No. 323, p. 2.
[6] Submission No. 329, p. 4.
[7] See for example, Evidence, p. RRA&T 38 & 819, Submission No.s 169 (pp. 3-4), 175 (p. 7), 177,
198 (p. 32), 199 (p. 4) and 204 (Attachment ).
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