CHAPTER 20

Commercial Utilisation of Australian Native Wildlife

CHAPTER 20

INDIGENOUS USE OF WILDLIFE

Significance of Wildlife to Indigenous People

20.1 The international regulatory community has on a number of occasions recognised the importance of the inter-relationship between indigenous people and their natural environments. The various international instruments which have embodied this concept include:

20.2 Aboriginal peoples and Torres Strait Islanders [1] have occupied and used large areas of land in Australia continuously for many thousands of years. To them all aspects of life are strongly associated with their natural environment; the physical landscape and the plants and animals that live within it. Their culture is based on a very different association between animals and people than exists among the many other people who are now part of Australia's multicultural heritage.

20.3 Traditionally, hunting and harvesting of wildlife provided food and shelter for Aboriginal people, fulfilment of spiritual and cultural needs and occupied a large amount of time. Although many Aboriginal people now do not depend on native wildlife for survival, the contribution of wildlife to the diet of Aboriginal people in some areas, and particularly those people living on outstations, is often considerable. More significantly, use of wildlife for spiritual and cultural purposes is still of great importance to many Aboriginal people. [2]

20.4 In addition, a significant proportion of Australia's land area (some 17 per cent) is now under the ownership and control of indigenous populations. [3] With this has come the opportunity and need for those people to manage the natural resources in an ecologically sustainable manner, within the constraints imposed by Federal and state legislation.

20.5 In this regard, Section 1.8.5 of the National Strategy on Ecologically Sustainable Development recognises the importance of harvesting of indigenous plant and animal species both on land and in water, to the wellbeing, identity, cultural heritage and economy of Aboriginal and Torres Strait Islander peoples and recommends that assistance be provided for the establishment of management programs for ecologically sustainable harvesting of wildlife by individual communities. [4]

Subsistence Use of Wildlife

20.6 Property rights for all flora and fauna is vested in the crown in Australia and legislation prohibits any taking of native wildlife except through permits. However, in recognition of the importance of wildlife to indigenous people, various state laws have made provision for Aboriginal people to harvest wildlife for 'subsistence' use. The taking of wildlife on this basis occurs widely throughout some areas of Australia and in the sense that it replaces food that would otherwise be purchased, it has a commercial value.

20.7 In the Northern Territory, for example, under the Territory Parks and Wildlife Conservation Act 1993, Section 122 provides for the traditional harvest of crocodiles and their eggs for hunting, food gathering (other than for purposes of sale), ceremonial and religious purposes by Aboriginal people. [5] In this legislation, the word 'traditional' is very important. It means that Aboriginal people must be associated historically, socially and culturally with a particular piece of land to be able to hunt on it or to gather from it. As clarified by Dr William Freeland of the Parks and Wildlife Commission of the Northern Territory:

In other words, if I am an Aboriginal from Melbourne, I cannot come to the Tanami Desert and catch myself a bilby. You have to actually be associated with that piece of land upon which you hunt and gather. [6]

20.8 The Northern Territory Government considers that the only effective way of ensuring the good management of wildlife used by Aboriginal people for sustenance or other traditional purposes is for the people themselves to have control over the management of that wildlife and the Government is currently investigating ways in which traditional owners can be given greater capacity to manage wildlife on their lands. [7]

20.9 In South Australia, Division II of the National Parks and Wildlife Act provides for hunting and gathering of wildlife by Aboriginal people and section 68(d) allows an Aboriginal person to take protected animals, the eggs of a protected animal and native plants from land that is not a reserve, only if it is to be used for food or for cultural purposes. Aboriginal people can take wildlife from a national park or reserve if it has been gazetted (five parks and reserves have been gazetted so far). Conservation groups in South Australia recognise traditional indigenous rights as appropriate exemptions from the normal prohibitions that apply to wildlife. [8]

20.10 However, despite attempts to accommodate the needs of Aboriginal people, laws enacted to protect wildlife may have 'had considerable [adverse] impacts on the use of wildlife by indigenous peoples'. [9] In fact, some Aboriginal people reject the view that the crown owns all wildlife and that there needs to be special provisions made for Aboriginal people to take wildlife. They believe in prior ownership and seek recognition of that. [10] According to Dr Jocelyn Davies, a researcher involved in a global study which is examining community based wildlife management initiatives (known as 'Evaluating Eden'), some indigenous people do not accept regulatory regimes which conflict with their 'rights' to use wildlife under traditional Aboriginal law. [11] In this regard the Northern Land Council described in its submission to the Committee how 'indigenous people within the Land Council's area do not distinguish different systems of classification, use, philosophy, and territorial and resource ownership for land and sea'. [12]

20.11 In addition, different provisions under the various state laws have created some difficulties for Aboriginal people in the use of wildlife on a subsistence basis. As an example, the Northern Land Council cites a hypothetical case of a Northern Territory Aborigine who legally harvests four geese but who cannot legally send them to his daughter studying in Melbourne. [13] On this matter wildlife biologist, Dr Grahame Webb, noted that:

Like all cultures represented in Australia, Aboriginal people should be able to buy traditional foods, which are important to the maintenance of culture, regardless of where they are living in Australia. At the present time a penalty for pursuing economic development, education, business or any other activity that takes Aboriginal people away from traditional lands, is an inability to maintain cultural and traditional links through food. [14]

20.12 The consequence of uncertain and conflicting legal interpretations, according to Dr Davies, has been a diminution in the ability of government to manage indigenous wildlife use by regulation. Dr Davies suggested that the ability of government to manage wildlife resources would be greatly enhanced if the rights of indigenous people to use wildlife were more widely recognised and Aborigines were included more frequently in cooperative management programs. [15]

20.13 In this regard, the Native Title Act 1993 recognises that indigenous Australians may have property rights in species even if they do not have property rights in the land where the species occur, such as national parks and pastoral leases. This means that they have rights to fish, hunt and gather wildlife. Professor John Altman, Director of the Centre for Aboriginal Economic Policy Research (CAEPR), suggested that the issue of 'whether there is a need (or statutory requirement) to recognise existing and potential indigenous property rights in species' should be further explored. [16] Dr Jocelyn Davies went so far as to say that the Act 'now provides that statute law restricting wildlife use does not apply to indigenous peoples acting in the exercise or enjoyment of their native title rights'. [17]

20.14 To this end, the Northern Land Council has claimed that the entitlements of indigenous people to wildlife should extend to sea territory in the first instance to protect Aboriginal subsistence fisheries and then to provide sustainable commercial opportunities in fishing industries for Aboriginal people. [18]

20.15 The Department of Environment noted that the Commonwealth Native Title Act 1993 recognised indigenous rights with regard to wildlife and recommended that: 'There is a distinct need to assess current practice in the harvesting and dealing of native flora and fauna as it relates to principles in the Native Title Act [s.223(1) and (2)] and the Commonwealth Law Reform Commissions' Recognition of Aboriginal Customary Laws 1986. This further needs to be clarified in relation to the National Parks and Wildlife Conservation Act 1975, the Racial Discrimination Act 1975, The Land Rights NT Act 1976, Local Government (Aboriginal Lands) Act 1978 section 29(1), and the Wildlife Protection (Regulation of Exports and Imports) Act 1982'. [19]

Environmental Impact and Sustainability of Subsistence Use

However, while there may be a broad acceptance that Aboriginal people have a right bestowed by heritage to continue to use native wildlife as they see fit for sustenance and cultural purposes, [20] there are a number of management issues which need to be addressed, particularly the question of whether such use can be ecologically sustained. According to a comprehensive report published by the Bureau of Resource Sciences in 1996, Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, (edited by Mary Bomford and Judy Caughley):

The fundamental question concerning contemporary use of traditional lands and waters is whether the cultural and economic needs of Aboriginal peoples and Torres Strait Islanders can be met. To maintain the spiritual and cultural values associated with wildlife and other natural resources, it is essential that their use be sustainable under contemporary lifestyles. … Pre-European limits on the size and spatial distribution of communities no longer apply. As a consequence, the density and distribution of Aboriginal hunting pressure may now be different from traditional patterns, and the use of local resources may exceed sustainable levels. [21]

20.16 A major problem is that for many Australian wildlife species, and particularly those in remote and arid regions, there is insufficient demographic and scientific data on which to base estimates of sustainable use. Aboriginal people use a wide variety of wildlife species for subsistence and while this use represents one of the largest scale consumptive uses of wildlife in Australia, there is almost no information on the impact that this level of use is having on biodiversity. [22] Significantly, the few species for which there is detailed demographic information are those which are commercially utilised (kangaroos, crocodiles, emus and muttonbirds). [23]

20.17 Dr Davies suggested to the Committee that one of the reasons there was a lack of data about subsistence use, which in some areas had led to a rarity of wildlife around Aboriginal communities, [24] was the prohibitionist regulatory approach of government:

The regulatory approach leads to tremendous stand-offs between governments and local people. Here in Australia, in my experience, in a lot of places with national park rangers and Aboriginal subsistence users, if the rangers have this wildlife police image, \DB\PGN\633Aboriginal people are most reluctant and uncooperative to tell the management authorities about their wildlife use, which is one of the reasons we do not have a lot of data and one of the reasons why it is difficult to do research in that area. [25]

20.18 The submission from CAEPR suggested that Aboriginal people should be more involved in wildlife management and that their knowledge of the land could be used to supplement formal ecological research projects. Species which were regularly used for subsistence or species subject to commercialisation proposals should be targeted first. As explained by CAEPR:

A precedent for this type of arrangement has been set by other countries. For example, in Quebec, Canada, the Cree are paid a fixed income under the Income Securities Program for hunting and for conservation practices such as monitoring the population numbers of hunted game. … If a similar innovation were introduced in Australia it would ensure biodiversity as well as financially assisting Aboriginal people who wish to reside in remote situations such as outstations and undertake productive activities utilising native wildlife. [26]

20.19 As described by CAEPR, examples of this type of cooperation in Australia already exist, but the philosophy of joint environmental management between indigenous and non-indigenous people needs to be more formally embraced by government and the practice extended to many other areas and projects.

20.20 Aboriginal people are becoming increasingly concerned about the quality of the environments in which they live and have sought to become more involved in land management issues in an effort to marry their needs with the need to maintain biodiversity. [27] According to the Northern Land Council, there has been a fairly rapid increase in the emergence of localised Aboriginal land management agencies in the Top End in recent years. [28]

Use of Technology

20.21 An important factor in the level of resource use and whether wildlife populations can sustain non-commercial harvesting, is the impact of changes in hunting techniques from traditional methods (spears, throwing sticks, etc) to modern technology (guns and four-wheel drive vehicles). Compared to traditional methods, modern hunting technology allows a much greater harvest of wildlife over a much shorter period of time. While over-harvesting of species rarely if ever occurred as a consequence of hunting using traditional methods, modern hunting techniques have the capacity to create regional extinctions, especially near roads. About this, the 1996 BRS report commented:

The major constraint to subsistence hunting today is overexploitation arising from loss of traditional regulatory mechanisms caused by societal changes and the interface with cash-based economies. To regain effective regulation of harvest, the traditional system of regulation needs to be reshaped to take into account the changes wrought by the adoption of new technology. In Australia this reshaping is still in its infancy. [29]

20.22 The potential for new technology to result in over-harvesting of wild life has led to the suggestion that Aboriginal people should be allowed to hunt only if traditional methods are used. [30] However, this suggestion is rejected by many, if not all Aboriginal people. In defence of the rights of Aboriginal people to hunt using any method, the Northern Land Council stated in its submission: 'It has been well established in the process of land claims and through other substantial precedents that tradition is not defined by reference to technology, which may change without affecting the traditionality of an act'. [31] In the words of Mr Chris Roberts, who spoke on behalf of the Balkanu Cape York Development Corporation:

The Aboriginal view is that technology has very little to do with the activity of hunting. The activity itself is the part that is important. … Basically, many people who are concerned about technology in Aboriginal hunting are asking Aboriginal people to do the equivalent of asking a farmer to revert back to a horse and plough scenario for cultivating land. What the Aboriginal people would like to remind managers of is that technology might be a way of more efficient harvesting, but it is that efficiency that requires management rather than the harvesting itself. Improved technology means a better handle on management rather than removing the ability of people to maintain their rights to their wildlife resources. [32]

Involvement of Indigenous People in Commercial Activities

20.23 The recognition of traditional links between indigenous people and the natural components of their land and that they have a special interest in the utilisation of wildlife is vital to consideration of any commercial use of native species. In evidence to the Committee Aboriginal people in general supported the concept of commercial utilisation of native wildlife and their involvement in it. [33] They felt that they were in a good position to be involved in commercialising wildlife because they have been closely affiliated with wildlife for thousands of years. [34] Commercial use of wildlife was seen by many as an appropriate activity if there were economic, cultural and social benefits. [35] As described by Mr Rydal Wilson, Manager of Murwangi Community Aboriginal Corporation:

Something I should point out from the beginning is that our aim in utilising wildlife is that, as you are probably well aware, it comes naturally to Aboriginal people, it is something that they can be very much involved in without any training and it can be on an irregular basis, so it works quite well for us. They have innate skills already, especially the older people, and it is an opportunity. [36]

20.24 The submission from CAEPR noted that: 'based on prior occupation of the Australian continent … many indigenous people see native wildlife as their preserve and responsibility'. [37] In fact, some Aboriginal groups believe that their natural heritage bestows on them a prior right to commercial opportunities with native wildlife and they claim that if there are going to be any further opportunities in farming native species, Aboriginal people should be given the first opportunity and given support in order to develop the industry. [38] A witness for the Yarrabah Community in north Queensland, Mr Ian Kuch, described this belief as follows:

Firstly, with the expansion of commercialisation of wildlife species, the Aboriginal people believe … in intellectual and cultural property rights, which also includes ownership of animals. They have totemic relationships with those animals. They have broad knowledge of animal habits and life cycles and so on. They possess a wealth of scientific information concerning those animals. If further species were looked at, in terms of commercialising native species, Aboriginal people in Yarrabah believe that they should have the first opportunity to be involved in that commercialisation. [39]

20.25 The Northern Land Council noted in its submission that Aboriginal people have traditionally had a strong involvement in commercial utilisation of native wildlife, mainly through trade along the northern coastline, and the Council supports strongly the right of landowning groups to continue to be involved in commercial use of wildlife. [40]

20.26 In addition, there is now an increasing interest among Aboriginal people in becoming less financially dependent on government support and in considering local development proposals [41] and thus a great number of Aboriginal people view positively the commercial utilisation of native Australian wildlife. [42] Some people believe that the involvement of Aboriginal people in commercial utilisation of native wildlife should be as strong as possible because other economic opportunities were so limited. [43] Many indigenous communities have title to land which is unsuited to agriculture based on introduced species and which is remote from markets. The Far North Queensland Network believes that any industry involved in utilising native wildlife should have at least a 50 per cent involvement of indigenous people and that this could come about through partnerships between traditional owners and pastoralists in the peninsula and gulf areas. [44]

20.27 A 1992 BRS report on indigenous use of wildlife noted that wild animal industries could provide employment for Aborigines both on their own land and on neighbouring lands because animal populations were often large there and current harvesting practices led to substantial wastage. The report also concluded that commercial development of wild animal resources would protect native species and aid in management of their populations. [45]

20.28 According to the 1996 BRS report: 'There is a strong demand from Aboriginal peoples and Torres Strait Islander traditional owners for government support for projects using wildlife' but that there is also 'a need to ensure that the aspirations of indigenous people are integrated with the wider community goals of all Australians'. [46] This report identified the strong need for both co-management agreements, which incorporate aspects of both the state and indigenous systems in environmental management, and community-based planning in establishing wildlife projects.

20.29 Dr Jocelyn Davies noted in her submission to the committee that: 'Indigenous people have a strong interest in developing industries based on commercial use of wildlife' and that 'these can help provide economic development opportunities in some of the areas where they are now limited'. [47] In particular, employment opportunities in remote areas of Australia are severely limited and commercial wildlife enterprises are an important source of jobs. In addition, working with wildlife has a particular appeal for indigenous people as it draws on their traditional knowledge and skills and keeps them in an environment for which they hold special attachments.

20.30 However, while some government assistance may be necessary in industry development programs, Professor Altman warned that it would be wrong to see commercial utilisation of wildlife by Aboriginal people as a panacea for employment and economic needs:

The comment I would make there is that I think it is important for government to recognise that there is a lot happening anyway. It is just a question of nudging things along a little bit. I would be concerned if we looked for a commercial utilisation of a wildlife-led recovery of the Aboriginal sector. Sometimes governments get good ideas and push them a little bit too hard. I think that all we really need are some signals to say that this is an acceptable and legitimate economic activity, and there are certainly ways that it can be facilitated and supported; for instance, with access to vehicles, with access to equipment to develop, for instance, hunting roads,just small developments, small capital grants for crocodile incubators in remote communities. [48]

20.31 Finally, a minority view was presented in evidence to the Committee that Aboriginal people, while having subsistence rights, did not have any intrinsic right to commercialise Australian wildlife. As argued by the Kangaroo Protection Co-operative Ltd, if Aboriginal people were to be involved in commercial utilisation of wildlife, then they should be involved in eco-tourism, to explain their culture, and in the planting and harvesting of plant-based bushfoods. [49] The Australian Conservation Foundation believes that: 'Commercial use of wildlife [by Aboriginal Australians] is not acceptable until the issue of sovereign rights to traditional food and genetic resources has been adequately addressed by the Australian community'. [50]

20.32 However, as noted by Dr Grahame Webb, these views may present a discriminatory approach to Aboriginal people:

There would appear to be a conflict of interest with organisations such as The Wilderness Society and ACF purporting to support Aboriginal claims for land, but at the same time opposing any Australians (Aboriginal people included) being able to use wildlife consumptively for commercial purposes – even for commercial trade within and between communities! Given general opposition to agricultural development by some conservation groups, one can only ponder what opportunities are going to be acceptable for Aboriginal people on traditional lands to pursue economic development. [51]

Harvesting

20.33 Aboriginal people are becoming increasingly involved in the bushfoods industry, both through harvesting from wild plants and to a much lesser extent growing plants for cropping. Harvesting has the advantage of providing some financial return without significant financial investment (see Box: Aboriginal Rural Resource Initiatives Projects).

20.34 The company Robins Bush Foods obtains bush tomatoes and wattle seeds from the Aboriginal community Utopia and Kakadu plum is harvested by a number of Aboriginal communities in the Northern Territory. The Aboriginal community at Elliot, in central Northern Territory, plans to establish a bush food farm. [52] In the Wreck Bay area of New South Wales, the Umbarra Aboriginal community conducts 'bush tucker' tours. [53]

20.35 In the Cape York region, according to Mr Chris Roberts who spoke on behalf of the Balkanu Cape York Development Corporation, much of the flora has already been taken by commercial interests for development in nurseries. This removes the commercial edge for Aboriginal people who would perhaps like to become involved in the commercial production of local species. [54] However, seed collection projects are under way in some areas of far north Queensland. [55]

20.36 In Central Australia, a number of Aboriginal people are involved with collecting seeds and fruit but unfortunately the returns are quite small because the harvest is usually sold through a third party who takes some profit and the Northern Territory government charges a levy for collection permits. [56] Aboriginal people in the Top End are interested in increasing the population of agile wallabies in order to harvest meat for the tourist trade [57] and in the export of trepang (beche-de-mer). [58]

20.37 In particular, the NSW Aboriginal Land Council noted in its submission that while the bush foods industry was keen to promote its products as 'green, clean, lean and unique', there had been no attempt to provide financial compensation to the Aboriginal communities which developed them as recommended by the National Strategy for the Conservation of Australia's Biological Diversity. In addition, there had been no attempt to disclose the cultural and spiritual relationships that many Aboriginal and Torres Strait Islander Peoples had with particular species of flora and fauna, or consider the cultural sensitivity when considering the commercial use of a species. [59]

20.38 The Australian Rainforest Bushfood Industry Association, however, has noted that:

Many people in the bushfood industry, have reservations about the concept of paying Aboriginal royalties on bushfood produce. It could discourage potential Australian growers, and provide a competitive advantage to possible overseas producers of our bushfoods by raising this countries [sic] production costs. Also, a royalty system may be complex: yet again, another layer of administration, costs and paper-work. [60]

20.39 Harvesting of animals for commercial use occurs on a small scale. There is a small industry based on the harvest of muttonbird chicks from the islands of Bass Strait (see Paragraph 15.5). While this has for many years combined a traditional activity with a source of supplementary food and income for local indigenous people, the industry is in decline though lack of product marketing. Harvesting of crocodile eggs (ranching) also occurs in the Northern Territory (see Paragraph 11.39). Payments to Aboriginal people for the harvesting of wildlife on their land is also an increasing trend in northern Australia. Examples include: crocodile egg ranching, barramundi fishing, bird-watching enterprises, and buffalo shooting.

20.40 Finally, it should be noted that the Northern Land Council makes a distinction between 'resource raiders' who take a large commercial harvest with little return to the species or its habitat, and the 'stayers', Aboriginal communities who have a long-term commitment to the land which they work. While the 'raiders' deplete the resource they harvest (for example pearlers and crocodile hunters of the past), the 'stayers' harvest is sustainable. [61] Although progress has been slow, Aboriginal communities in the Northern Territory are now moving towards commercial use of species within their traditional practices of harvesting in a sustainable manner.

Farming Native Animals

20.41 Although Aboriginal people have been involved in western-style pastoralism for many years, they do not have a strong farming tradition and quite a number of commercial farming ventures have failed through lack of ownership, either financially or psychologically, by the Aboriginal communities involved. [62] There may be, however, more prospect of industries based on native species being successful because of the less intensive nature of enterprises and the greater inherent interest in endemic species.

20.42 Aboriginal people are already involved in the farming of emus (Paragraphs 10.3 and 10.21) and crocodiles (Paragraph 11.39) for commercial gain. Other species suggested as being appropriate for commercial use through harvesting, ranching or farming included tropical birds, [63] reptiles, [64] marine turtles, [65] cassowaries, [66] scrub turkey, [67] echidnas, [68] red-claw crayfish, [69] dugong [70] and trepang (beche-de-mer, or sea slug). [71]

Safari Hunting

20.43 A number of Aboriginal communities in the Northern Territory have already commenced safari hunting operations for non-native species, such as buffalo and biltong, and have expressed interest in extending this concept to native species such as crocodiles (see Paragraph 19.15). Communities in far north Queensland have also expressed an interest in safari hunting. [72] A proposal put by the Murwangi Community Aboriginal Corporation to the Committee outlined the way in which such an operation would be managed:

… the chosen animals would be old male Crocodylus porosus greater than 14 ft; the number taken would be limited by the Northern Territory NPWS, but no more than four per year; the expected fee would be $13,500 per animal; access by airboat and canoe, with Aboriginal guides; hunters could be expected to be members of recognised recreational hunting associations, such as Safari Club International. [73]

20.44 However, while a number of groups including the Northern Territory Government and the Far North Queensland Network are supportive of the concept of safari hunting because it is seen as a way of allowing Aboriginal people to put a value on their land and thus a secure commercial rationale for retaining it as natural habitat, the Federal Government is not. [74]

Tourism

20.45 The ownership by Aboriginal people of areas of land which contain major tourist destinations (such as Uluru, Nitmiluk and Kakadu National Parks) has resulted in an increasing involvement of those people in tourist related activities and income from them. Such activities have now moved from the initial stage of simply providing accommodation to a higher level of value-adding with guided tours and interpretation facilities, although the overall level of involvement may be still quite small. [75] Cultural tours, for example, brought in royalties for the Northern Land Council of $80,527 in 1994-95, $68,974 in 1995-96 and $88,663 in 1996-97. [76]

20.46 Some Aboriginal groups are keen to be involved in tourism and see possibilities in taking tourists into their lands on nature-based tours. In Central Australia, Aboriginal people are involved with various types of tourist enterprises, including trips to find bush tucker and to see the arid lands. [77] In Cape York, for example, there are a number of endemic species of birds which would be of considerable interest to ornithologists. [78]

20.47 In some areas, however, too great an influx of tourists has the potential to cause problems, both in terms of criticisms which outsiders may have of Aboriginal wildlife harvesting practices, and the psychological impact of too many people visiting Aboriginal lands. As described by Professor Altman of CAEPR:

I guess the classic situation where you can have that sort of interaction might be in a place like Kakadu National Park, where you have Aboriginal communities dotted through the park, out-station communities, and where people on those communities do utilise wildlife for their livelihoods. But they have to do it in a fairly low key sort of way because they have certainly had some fairly negative feedback from tourists who come to see the wildlife. There have certainly been incidents where they get a little bit upset where they see Aboriginal people harvesting.

… with an increase in tourist visitation you are getting something in the region of 250,000 visitors per annum. There is a sense that the Aboriginal communities are a little bit dissatisfied that if a particular place becomes popular with tourists, it tends to then restrict their access to that place, to that hunting ground or fishing place for their subsistence purposes. So there is a potential problem there. [79]

20.48 Following on from this comment, Ms Lynette Liddle of CAEPR commented: 'From my experience, it would be a good idea for a lot of the government agencies to be proactive in providing information to Aboriginal clients either through land councils or through other organisations for disseminating information about animal welfare issues and harvesting'. [80]

Feral Animals

20.49 In some Aboriginal areas, small industries are based on the commercial use of feral animals. In Central Australia, for example, camels are caught and sold for stud purposes or for meat and the Central Land Council owns a truck which is used to assist people to transport camels into town or to an abattoir. [81] In Arnhem Land, Aboriginal communities have for many years been involved in harvesting of feral animals, mainly cattle, buffalo and pigs. [82]

20.50 In fact this has occurred to such an extent that some Aboriginal people now view some feral animals (such as pigs) as a legitimate part of their diet. According to Mr Chris Roberts, who spoke on behalf of the Balkanu Cape York Development Corporation:

With regard to feral animals, many people consider these just to be a nuisance. Aboriginal people have got some very interesting views on feral animals. Apparently, pigs substitute around about $300,000 worth of meat protein for Aboriginal people. To some extent it takes the heat off turtle eggs and turtles themselves, which are species recognised in the conservation arena.

Some Aboriginal communities take offence at people hunting their pigs because this is their tucker that runs around in the bush. They have been associated with pigs ever since pigs arrived a couple of centuries ago. Therefore, it is not hard to see that they see feral animals as part of their environment and a resource that they can use. [83]

Barriers to Increased Commercialisation

20.51 However, despite strong interest in commercial use of wildlife, the involvement of Aboriginal people in commercial ventures in remote parts of Australia has not been, overall, greatly successful. A number of factors have contributed to this which mainly relate to locational, financial and cultural constraints. [84] Experience, however, is slowly leading to ventures which may have more positive outcomes. Examples of this are the Bawinanga Aboriginal Community Corporation involvement with crocodile ranching and incubation in Arnhem Land and the Cherbourg Community Emu Farm near Murgon in southern Queensland.

20.52 Because many Aboriginal communities are located in remote regions of Australia, one of the major obstacles to increased development of wildlife resources is distance from markets. [85] In instances where horticultural ventures have been started in remote Aboriginal communities, they have failed largely because of lack of easy access to markets. [86] In addition, consumer resistance to products sourced from native wildlife also needs to be overcome [87] and this may not occur without public education about sustainable management of Australian wildlife. [88]

20.53 A major inhibition to increased commercialisation is the lack of experience and expertise in commercial ventures. As explained by Ms Lynette Liddle of CAEPR:

I think that government agencies have to look beyond the conservation element and look at ways in which Aboriginal people can have scientific and economic support to be involved in the industry but be supported by scientists and government agencies. There are a lot of Aboriginal people out there wanting to be involved in commercial utilisation, but they do not have the avenues within the Commonwealth government or state government agencies to access information and data and issues about legislation and breeding information of wildlife that is necessary for them to manage those wildlife resources. [89]

20.54 The establishment of joint ventures between indigenous partners having knowledge and expertise in wildlife and non-indigenous partners who can provide venture capital, with equal involvement in management decisions, may be one way of overcoming the financial, bureaucratic and market barriers that indigenous people face with any proposal to commercialise wildlife. [90] The value of this type of approach was described by Ms Linda Roach, also from CAEPR:

There is one area that probably shows potential for involving Aboriginal people, and that is in the co-management of wildlife, especially commercial operations which involve co-management, because then the Aboriginal people can contribute their skills. Very often Aboriginal people do not have a level of management skill that would enable them to successfully run an operation but they do have other skills and knowledge that the enterprise could use and which would be valuable to the enterprise or, in fact, necessary for it. In that way the enterprise is profitable and Aboriginal people are included at an important level. [91]

20.55 Another major barrier is that legislation allows Aboriginal people 'subsistence' use of wildlife but does not allow them to sell any wildlife harvested from their own lands, although some 'trade' no doubt occurs on an informal basis. [92] There is strong evidence to suggest that both indigenous and non-indigenous people are interested in purchasing native wildlife as food, or for other purposes. Species include goanna, echidnas, bush turkeys, snakes, magpie geese, dugong, turtles and fish. [93]

20.56 Another legal barrier is that which allows pest-destruction permits to be issued for superabundant species, but which does not allow any commercial use of the animal after it has been killed. A good example of this is the emu in Western Australia. State legislation provides for the issue of pest destruction permits and many thousands of birds are disposed of when they become an agricultural nuisance in the Merredin and Mullewa areas near the Barrier fence, but the carcases cannot be used in any way.

20.57 Dr Jocelyn Davies noted in her submission that the demise, in 1996, of the Aboriginal Rural Resources Initiative, which had been managed by the Bureau of Resource Sciences, was 'regrettable' given that program had been a catalyst for much support for Aboriginal groups interested in commercial wildlife use. [94]

20.58 For many years, Aboriginal people have produced artefacts for ceremonial and limited market exchange and over the last few decades some of these objects have been manufactured for sale as tourist items (boomerangs, didgeridoos, spears, bark paintings, etc). Some have incorporated in them by-products of subsistence harvests (echidna quills, feathers, turtle shell, etc) and the inclusion of these animal parts technically contravenes state laws which allow harvesting for subsistence use but not for commercial use. [95] In addition, should any of these items be purchased by overseas tourists and taken out of the country, there is also the risk of contravening the Wildlife Protection (Regulation of Exports and Imports) Act 1982.

20.59 The Northern Land Council points out that 'Aboriginal people again find non-Aboriginal behaviour in this respect illogical, as the rights of Aboriginal people in the Northern Territory to kill and eat the relevant avian species is recognised by the state, but the state prescribes that they may not gather up the surplus feathers and utilise them for commercial purposes'. [96]

Concerns About Commercial Utilisation of Wildlife

General Concerns

20.60 The submission provided by the Central Land Council outlined a number of key issues of concern about commercial utilisation of wildlife held by the Aboriginal people it represented. These are summarised as follows.

20.61 Despite these concerns, the Central Land Council believes that the introduction of commercial utilisation of native wildlife may present 'an opportunity to establish a regulated commercial environment in which Aboriginal landowners might successfully participate'. [98] The Council also noted that should any farming proposals be made, Aboriginal people should be involved in the capture of live animals to establish breeding stock, under the guidance of wildlife officers. [99]

20.62 The New South Wales Aboriginal Land Council stated in its submission that it did not 'have a blanket objection to the utilisation by people of our native fauna and flora', but the Council emphasised the importance of public consultation in determining the manner and extent of any such utilisation. [100] The Council also emphasised the importance of taking into account Aboriginal perspectives on the interconnectedness of indigenous people, the various components of the environment in which they lived and their cultural heritage, including totemic species and sacred sites. [101]

Impact on Subsistence Use of Wildlife

20.63 Because many Aboriginal communities consume wildlife on a subsistence basis, commercialisation may result in a reduced availability of those resources for subsistence needs. There is evidence of this occurring in Torres Strait where prawn trawling is apparently affecting the availability of subsistence fish and off the coast of Arnhem Land where prawn trawlers are having an impact on dugong and turtles. [102] Aboriginal people on the whole believe that maintenance of subsistence rights should have precedence over commercial uses, whether by indigenous people or by others. [103]

20.64 The Northern Land Council suggested that before the commencement of a commercial venture which was based on the harvest of an important subsistence species, a cost-benefit analysis should be carried out which included both monetary and non-monetary factors, and an analysis of alternative commercial ventures. As an example, the Council suggested that ecotourism and safari hunting may be more profitable than extractive harvests for meat and skins, although there may be other negative social or environmental impacts. [104]

Respect for Totemic Species

20.65 A significant element of traditional Aboriginal culture is the ancestral link between people and a particular animal or plant species. As described by the Northern Land Council: '… there may be some tension between ownership of animals based on their presence in particular estates and their association with totemic collectives, but in daily life, the right to harvest plants and animals rests with the patrifiliated and matrifiliated members of land-owing lineages in respect of their estates'. [105]

20.66 More importantly, from the point of view of commercial harvesting, individual totemic animals may hold strong spiritual qualities and it is an affront to an Aborigine for his or her totemic 'kin' to be killed by another person and left to rot (that is, for the animal to 'die for nothing'). Because non-Aboriginal people do not have the cultural awareness or insight to be able to discriminate between ordinary animals and a spiritually potent member of that species, commercial hunters and fishers often kill these spiritually significant creatures, either directly as a target species or indirectly as by-catch. Examples include the death of crocodiles and dugong in barramundi nets, and death of turtles in drift nets. The Northern Land Council stated that this was an issue of great concern to Aboriginal people in the Northern Territory.

20.67 Related to this concern is the issue of fisheries by-catch wastage. Aboriginal philosophy encompasses a belief that no food animal or plant should be wasted and Aboriginal people consider it 'barbaric' that commercial fisheries are legally allowed to dump by-catch. According to the Northern Land Council: 'It is not uncommon for large quantities of non-target species eg. grouper, catfish, sharks, crocodiles, dugong and turtle to be found washed up and rotting along the tideline on Aboriginal land. It is understood that further considerable by-product waste occurs off-shore in the prawn fishery but may not reach the shore when dumped overboard by trawlers a long way out'. [106]

Respect for Traditional Knowledge

20.68 A number of Aboriginal groups expressed particular concern about the loss of 'intellectual property' of indigenous people through increasing commercialisation of aspects of their culture, such as bush foods and knowledge of plant medicines. The NSW Aboriginal Land Council assured the Committee that their concerns did not indicate an unwillingness to share, provided that the prior and informed consent of indigenous people was obtained. [107] Concern about loss of 'intellectual' property rights was also expressed by Mr Chris Roberts who gave evidence on behalf of the Balkan Cape York Development Corporation. [108]

20.69 In the opinion of CAEPR: 'if commercial utilisation of wildlife in Australia is to expand, it is imperative that not only do indigenous people have equal opportunities to participate in such growth, but also that expansion of non-indigenous interests do not limit the subsistence and commercial options available to indigenous people'. [109] CAEPR also questioned whether there was a need, or in fact a statutory requirement, to recognise indigenous property rights in native plant and animal species.

20.70 The bushfoods industry has already indicated a sensitivity to this matter. In its first newsletter, the Australian Rainforest Bushfood Industry Association noted:

… there are ethical considerations around the cultural property rights of Aboriginal people and the use of their bushfood lore for financial gain … Where Aboriginal knowledge is used, prior permission, and acknowledgment of the specific source of information should be standard procedure by the person(s) introducing the product into the industry. [110]

20.71 Finally, Mr Peter Core, Managing Director of RIRDC noted in evidence to the Committee the importance of respect for prior Aboriginal knowledge, but claimed that the various rights and obligations of the parties involved in commercial utilisation of wildlife were currently unclear:

On the linkages between commercialisation of native wildlife and native title issues, the corporation recognises that indigenous groups in Australia have for a number of years been advocating the recognition of indigenous rights to intellectual property including biological resources. That issue is, as we are advised, currently with the federal government. At our level as a research funding organisation, we will continue to work closely with indigenous people in the development of our program goals in areas such as bush foods, but we have no substantive comment to make to the committee beyond the obvious one that the current position is unclear as to what extent, if any, rights to biological resources are associated with native title. [111]

Opposition to Positive Discrimination

20.72 In some areas of Australia, Aboriginal people have been given special rights to hunt and to harvest wildlife. For example, the New South Wales Government has banned the hunting of duck and quail for all non-Aboriginal people, but Aboriginal people are allowed to hunt these birds. There was some discussion in the evidence as to whether this constituted positive discrimination. The Safari Club International, for example, did not agree that Aboriginal people should be given special rights, a position based on the premise that all people, regardless of race or origin have a tradition of hunting which can be traced back thousands of years. [112]

20.73 As another example of objection to positive discrimination, Mr A M Golding of Little Meadows Emu Farm in Western Australia argued that favoured treatment by government of two Aboriginal communities in establishing emu farms had caused difficulties for private businesses which were in competition with them. In Mr Golding's submission he wrote:

One of the biggest problems that has affected the viability of the emu industry are the vast sums of taxpayers money poured into two Aboriginal communities in Western Australia and Queensland to assist them to establish emu farms and market their products in detriment to others in the industry, because they do not have to borrow from the normal lending institutions to build abattoirs, tanneries and service wage bills.

When the Industry has put in for funding Government Departments have cited the millions of dollars spent on the industry. When the question is asked where the money has gone the answer is mostly to Aboriginal communities, which is not to the benefit of the industry as a whole.

It makes the non-Aboriginal commercial emu farmer almost wholly unable to compete on the open market as such communities can sell in the market place almost without cost. [113]

20.74 Finally, Mr Golding noted in evidence before the Committee that the Wiluna enterprise in Western Australia had now 'all but closed down', despite considerable funding and he argued that that money would have been better spent assisting the entire industry. [114]

Summary and Conclusions

20.75 To Aboriginal peoples and Torres Strait Islanders all aspects of life are strongly associated with their natural environment: the physical landscape and the plants and animals that live within it. In recognition of the importance of wildlife to indigenous people, various state laws have made provision for Aboriginal people to harvest wildlife for 'subsistence' use. However, different provisions under the various state laws have created some difficulties for Aboriginal people in the use of wildlife on a subsistence basis.

20.76 Because a significant proportion of Australia's land area is under the ownership and control of indigenous people there is a need to manage the natural resources in an ecologically sustainable manner, within the constraints imposed by Federal and state legislation. However, Federal and state legislative arrangement are not completely clear resulting in some uncertainty as to the rights of indigenous people in their subsistence use of wildlife. The consequence of this has been a diminution in the ability of government to manage indigenous wildlife use by regulation. Although subsistence use may constitute a significant commercial use of wildlife (in the sense that it replaces food which might otherwise have been purchased), little effort has been made to quantify the level of use or its impact on biodiversity conservation.

20.77 The Committee is concerned that there is insufficient monitoring of the level of subsistence use by Aboriginal people and its impact on wildlife populations and hence on biodiversity. The Committee notes that the lack of clarity as to what constitutes 'rights to wildlife' and the prohibitionist approach generally taken by government wildlife authorities are major factors which may inhibit Aboriginal people in assessing the full extent and impact of subsistence use. The Committee believes that joint environmental management between indigenous and non-indigenous people is crucial to the welfare of Australia's environment and urges both government and Aboriginal peoples to work together towards sustainable use objectives. More specifically, the Committee recommends a remote Aboriginal community be invited to carry out a trial survey of the levels of subsistence wildlife use and its impact on biodiversity, supported by a grant through the National Heritage Trust.

20.78 In evidence to the Committee, Aboriginal people in general supported the concept of commercial utilisation of native wildlife and their involvement in it. It was seen by many as an appropriate activity with economic, cultural and social benefits. There is already a variety of projects involving Aboriginal people in the commercial utilisation of wildlife. Payments to Aboriginal people for use of wildlife on their land is also an increasing trend in northern Australia. Examples of this include crocodile egg ranching, barramundi fishing and buffalo shooting. Aboriginal people are also involved in the farming of crocodiles and emus. Tourism enterprises are of increasing importance to Aboriginal people, and interest has also been expressed in safari hunting of native animals (currently prohibited). The Aboriginal Rural Resource Initiatives includes a number of projects which involve harvesting or horticulture of bush foods.

20.79 Despite strong interest, however, the involvement of Aboriginal people in commercial ventures based on wildlife in remote parts of Australia has not been, overall, greatly successful largely for reasons relating to locational, financial and cultural constraints. The two major obstacles to increased development of wildlife resources are distance from markets and lack of experience and expertise in commercial ventures. A number of key issues of concern about commercial utilisation of wildlife were expressed by Aboriginal people and in particular those people represented by the Central Land Council. In essence these concerns related to the lack of scientific information on species distributions and abundances, the potential for detrimental impact on Aboriginal traditions, customs and contemporary land uses, respect for traditional knowledge and the potential for interference with subsistence use. Nevertheless, the Committee concludes that commercial utilisation of wildlife by Aboriginal people has an important role to play in the economic development of some Aboriginal communities. The Committee recommends that Aboriginal people should be consulted where commercial opportunities are identified on lands where there are communities which have strong traditional links to those lands.

20.80 The Committee notes that the various rights and obligations of parties involved in commercial utilisation of wildlife with respect to prior Aboriginal knowledge are currently unclear. The Committee believes that the importance of intellectual property rights of Aboriginal people in relation to the use of wildlife has not received sufficient recognition and the Committee recommends that the Federal Government give greater attention to this issue.

20.81 Finally, the Committee supports the suggestion made by CAEPR that government agencies provide information to Aboriginal peoples, either through land councils or other organisations, about animal welfare issues.

Senator J Woodley

Chairman

Aboriginal Rural Resource Initiatives Projects

The Aboriginal Rural Resource Initiatives is a national program of some 73 land management projects aimed to enhance opportunities for employment and income generation among Aboriginal and Torres Strait Islander People, with funding provided by the Royal Commission into Aboriginal Deaths in Custody. Of the total number of projects, some 17 directly involve the commercial utilisation of native wildlife. The following is a description of five projects, to exemplify the range of opportunities being explored.

Billy Goat Plum – Oenpelli (Arnhem Land, NT).

Some ten women are involved in this project, with the assistance of two men on specialised tasks when needed, which has seen the planting of a grove of 300 Billy goat plum trees. Contacts are being developed in Darwin for marketing.

Djigay Bush Foods – Kempsey (NSW)

The Djigay Bush Foods project has two aspects – the development of a traditional food tree park and a bush tucker production enterprise. The official opening of the Park took place in August 1997 and two of the six planned stages are complete. The two projects employ some 15 people and a joint venture has been entered into with two non-indigenous businesses for marketing purposes.

Mankuni wilykaja bush tucker and seed collection – Western Desert (Central WA)

The aim of the Mankuni Wilykaja project was to develop a bush tucker and seed harvesting enterprise to meet the subsistence needs of the community, with the possibility of expansion into plant and seed sales in the future. The seed collection component of the project is still operating and 30 women are licensed to collect seeds. Sufficient income has been generated to keep the project going for another year.

Tea Tree Plantation - Cape York (Far North Queensland)

A five-hectare tea-tree plantation is now at production stage and preliminary extraction of oil was initially carried out with borrowed machinery. The enterprise has now installed its own machinery but has had some problems with the distillery and pumps. The project employs eight men, two days a week. Although a profit has not yet been made, the project has the potential to be very successful.

Ceduna Emu Farm – Ceduna (South Australia)

The project at Ceduna aimed to develop a sustainable emu farm and went through a two year planning period before stock were obtained. Although now operational and employing five people, marketing problems in the emu industry have led to a need to look at diversifying the project to include other income streams such as tourism.

Footnotes

[1] Hereafter referred to as indigenous or Aboriginal people.

[2] Evidence, p. RRA&T 296.

[3] The Central Land Council, for example, covers an area of 775,000 sq km, which is 55% of the land area of the Northern Territory (Evidence, p. RRA&T p. 299).

[4] Submission No. 198, p. 9.

[5] A Management Program for Crocodylus porosus & Crocodylus johnstoni in the Northern Territory of Australia. November 1996 Parks and Wildlife Commission of the Northern Territory, p. 3.

[6] Evidence, p. RRA&T 331.

[7] Evidence, p. RRA&T 332.

[8] Submission No. 318, p. 17.

[9] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders edited by Mary Bomford & Judy Caughley, Bureau of Resource Sciences, AGPS A62208, 1996, p. 1.

[10] Evidence, p. RRA&T 288.

[11] Submission No. 340, p. 3.

[12] Submission No. 300, p. 1.

[13] Submission No. 300, p. 9.

[14] Submission No. 157, p. 25.

[15] Submission No. 340, p. 3.

[16] Submission No. 327, p. 11; also Evidence, p. RRA&T 1113.

[17] Submission No. 340, p. 3.

[18] Submission No. 300, p.7.

[19] Submission No. 198, p. 41.

[20] There is also a minority view that indigenous people have a right to use native wildlife only if traditional methods of hunting and gathering are used (Evidence, p. RRA&T 108).

[21] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, op cit, p. 9.

[22] Evidence RRA&T 626, Submission No. 340, p. 2, Submission No. 327, p. 6.

[23] Submission No. 327, p. 4.

[24] Evidence, p. RRA&T 626.

[25] Evidence, p. RRA&T 632.

[26] Submission No. 327, p. 10; see also Evidence, p. RRA&T 1109.

[27] Evidence, p. RRA&T 226.

[28] Submission No. 300, p. 3.

[29] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, op cit, p. 1.

[30] See for example Evidence, p. RRA&T 108 & Submission No. 297, p. 4.

[31] Evidence, p. RRA&T 365; Submission No. 300, p. 5.

[32] Evidence, p. RRA&T 220.

[33] Evidence, p. RRA&T 179, 218, 284, 358 &, 392; Submission No.s 174, 300 & 310, but see 298.

[34] Evidence, p. RRA&T 219.

[35] Evidence, p. RRA&T 287.

[36] Evidence, p. RRA&T 393.

[37] Submission No. 327, p. 2.

[38] Evidence, p. RRA&T 288.

[39] Evidence, p. RRA&T 285.

[40] Submission No. 300, p. 5.

[41] Submission No. 327, p. 3.

[42] Vardon 1997 cited in Submission No. 327, p. 4.

[43] Evidence, p. RRA&T 223.

[44] Evidence, p. RRA&T 202.

[45] Wilson, G., McNee, A. & Platts, P. 1992 Wild Animal Resources: their Use by Aboriginal Communities, AGPS Canberra, ISBN 0644248629, Summary.

[46] Sustainable Use of Wildlife by Aboriginal Peoples and Torres Strait Islanders, op cit, p. 1.

[47] Submission No. 340, p. 2.

[48] Evidence, p. RRA&T 1111.

[49] Supplementary Submission No. 129, p. 1.

[50] ACF Policy Statement No. 61, Tabled by the Nature Conservation Council of NSW, 8 September 1997, p. 3.

[51] Submission No. 157, p. 25.

[52] Evidence, p. RRA&T 1009.

[53] Evidence, p. RRA&T 1010.

[54] Evidence, p. RRA&T 221.

[55] Evidence, p. RRA&T 201.

[56] Evidence, p. RRA&T 303.

[57] Evidence, p. RRA&T 88.

[58] Evidence, p. RRA&T 376.

[59] Submission No. 174, p. 8.

[60] Australian Rainforest Bushfood Industry Association, Newsletter No. 1, Autumn 1996, PO Box 6407, Lismore NSW 2480, p. 3 President's Report.

[61] Submission No. 300, p. 12.

[62] Evidence, p. RRA&T 300.

[63] Evidence, p. RRA&T 203; Submission No. 83.

[64] Evidence, p. RRA&T 829.

[65] Submission No. 340, p. 4.

[66] Evidence, p. RRA&T 286.

[67] Evidence, p. RRA&T 289.

[68] Evidence, p. RRA&T 220.

[69] Evidence, p. RRA&T 221.

[70] Submission No. 340, p. 4.

[71] Evidence, p. RRA&T 365, 376.

[72] Evidence, p. RRA&T 200.

[73] Submission No. 310.

[74] Evidence, p. RRA&T 332.

[75] Evidence, p. RRA&T 1108-9, Submission No. 327, p. 3.

[76] Submission No. 300, Appendix, p. 1.

[77] Evidence, p. RRA&T 304.

[78] Evidence, p. RRA&T 222.

[79] Evidence, p. RRA&T 1115.

[80] Evidence, p. RRA&T 1115.

[81] Evidence, p. RRA&T 302.

[82] Submission No. 300, p. 4.

[83] Evidence, p. RRA&T 221.

[84] Evidence, p. RRA&T 1103, Submission No. 327, p. 6-7.

[85] Submission No. 327, p. 3.

[86] Evidence, p. RRA&T 1112.

[87] Evidence, pp. RRA&T 630, 1106-7.

[88] Submission No. 340, p. 3.

[89] Evidence, p. RRA&T 1113.

[90] Submission No. 327, p. 8.

[91] Evidence, p. RRA&T 1110.

[92] Submission No. 300, p. 8.

[93] Submission No. 327, p. 8.

[94] Submission No. 340, p. 2.

[95] Submission No. 300, p. 8; Submission No. 340, p. 4.

[96] Submission No. 300, p. 8.

[97] Submission No. 298, p. 4; Evidence, p. RRA&T 294-5.

[98] Evidence, p. RRA&T 294.

[99] Evidence, p. RRA&T 294.

[100] Submission No. 174, p. 1.

[101] Submission No. 174, p. 2.

[102] Submission No. 327, p. 4.

[103] Submission No. 340, p. 3.

[104] Submission No. 300, p. 12.

[105] Submission No. 300, p. 6.

[106] Submission No. 300, p. 7.

[107] Submission No. 174, p. 3- 8.

[108] Evidence, p. RRA&T 219.

[109] Submission No. 327, p. 11.

[110] Australian Rainforest Bushfood Industry Association, Newsletter No. 1, Autumn 1996, PO Box 6407, Lismore NSW 2480, p. 3 President's Report.

[111] Evidence, p. RRA&T 1119.

[112] Supplementary Submission No. 118, p. 3.

[113] Submission No. 171, p. 3.

[114] Evidence, p. RRA&T 465.