Share your feedback on the proposed Wildlife (Game) Regulations 2024 and Regulatory Impact Statement. The Department of Jobs, Skills, Industry and Regions (DJSIR) has developed the proposed Wildlife (Game) Regulations (2024) (proposed Regulations) to replace the current Wildlife (Game) Interim Regulations 2023 (current Regulations) which will expire in September 2024.

There are several changes and reforms in the proposed Regulations which have been informed by the government's response to the Legislative Council Select Committee Inquiry into Victoria's Recreational Native Bird Hunting Arrangements.

The proposed Regulations are now available for comment along with a Regulatory Impact Statement (RIS) outlining the government’s proposal. The proposed Regulations have been developed in consultation with hunting groups, animal welfare and animal advocacy groups, firearm retailers, government agencies, and a Traditional Owner Representative body.

Key points for a Submission on the proposed new Wildlife (Game) Regulations 2024

Background information before you begin: 

• All Victorian regulations ‘sunset’ every 10-11 years, to ensure they remain up to date. There is  mandatory public consultation on the proposed replacement regulations, your submission is a  way to engage with this process. 
• Victoria’s hunting regulations permit the recreational hunting of native ducks, native quail and  deer. They also permit the shooting of non-native birds (pheasant, partridge and quail) at bird  farms that provide paying guests with a hunting experience. All these are referred to as game animals.  
• The current regulations were developed in 2012 under former Coalition Minister Peter Walsh  (Nationals) - a duck shooter and member of Field & Game Australia (FGA).  

Closing date for submissions: Monday 29 July 2024. Submission site here and at the very bottom of the page.

Call to action: Have your say on the Wildlife (Game) Regulations 2024 and Regulatory Impact Statement - We have provided a guide to assist including the main points to address. 

LICENCE FEES 

Overview: 

In the 10 years of its existence, the GMA has spent more than $30m (in today’s dollars) of taxpayer money because licence fees have been too low to cover costs. These fees have not been reviewed since 2012 (apart from indexation). In 2012, former Coalition  Minister Walsh approved fees at 88% of cost recovery but after he set up the GMA in 2014, costs increased significantly. Cost recovery for GMA has fallen from 73% (2014) to less than 50% (2023).  (Source: RIS, p.50). The 2024 proposed licence fees don’t cover the burgeoning research projects of the GMA. 

The long-running Eastern Australia Aerial Waterbird Survey (EAAWS) led by Prof. Richard Kingsford  (UNSW) has been adequate and effective at tracking population trends of native waterbirds across the eastern states where they migrate. It has been running for 41 years and is jointly funded between those states, including those that do not permit bird hunting.  

Free licence and test waivers for juniors (aged 12-17) were introduced by former Minister Walsh in  2012, yet the 18-27 age group remains relatively small. For overseas visitors, bird farm clients and  concession card holders, a full licence fee is a minor part of overall hunting costs. 

Suggested changes: 

• No more taxpayer subsidies for hunting. Increase hunting licence fees for full cost recovery: 
  • Include all costs incurred by the Game Management Authority (GMA) and the other  eight agencies that support hunting in Victoria (listed on pp 74-75 of the RIS) 
  • Include all research costs (no exclusions for ‘public benefit’ from hunting research). 

• Full annual disclosure of the above costs, and the revenue from hunting licences.
• Discontinue all free licences and test waivers, and the 50 per cent concessional licence. GMA  data shows that one in five are either free or concessional. 
• Regular review of hunting licence fees (not just indexation) to ensure cost recovery continues. 

RECREATIONAL DUCK SHOOTING SEASON  

Overview: 

The proposed default season will start on a Wednesday, to defuse the poor shooter behavior that has historically occurred on weekend openings. For years, GMA has quoted Prof. Klaassen who claims (based on northern hemisphere patterns) that altering season length makes little difference to the number of ducks shot. The season length can be shortened with little impact on hunters but  serves a significant benefit to regional communities. Deer hunting with hounds is banned over  Easter which is “one of the busiest times for camping and public land use” (RIS p.36). Non-hunters cannot access wetlands and waterways during duck shooting season. Regional families and visitors deserve peace and safety at Easter.  

Suggested changes: 

• There should be no default season length. With climate change, habitat loss and long-term decline of species, any season should have to be justified according to environmental conditions.
• It is inappropriate to propose a default season length of a record-long 90 days (up from 87 days),  following a parliamentary inquiry which examined all evidence and proposed a total ban. Historically, seasons often had around 55-60 shooting days. The proposed length is a 50%  increase. 
• Shooting only in clear daylight - permitted only from 8am to 4pm, and not in bad weather or fog.
• No shooting over the Easter holiday period. 
• Review of the exclusion rules for duck rescuers. 
• Fewer shooting sites, and no shooting at Ramsar wetlands. 

ANIMAL WELFARE 

Overview: 

Duck rescuers access wetlands to retrieve injured ducks and take them to veterinary care. In 2024, the GMA began routinely issuing Banning Notices on duck rescuers, removing them from wetlands for the entire season.  

The most common shotgun injury for a flying duck is a broken wing. Unable to fly, they fall to the water, incurring horrific injuries from the impact. Rescuers often witness injured ducks abused by shooters and their dogs; loosening the requirements for dog breeds will further escalate the suffering of injured waterbirds. 

Suggested changes: 

• Veto the proposed exclusion of non-hunters from wetlands until 11am (season opening).
• Roll back the draconian restrictions on duck rescuers that were imposed by the former Coalition  government without public consultation. These exclusion rules are not public safety measures;  they are applied selectively to rescuers (rather than other non-hunters), even when there are no ducks or hunters in the vicinity. 
• Clarify the definition of water shoreline which is subjectively and unfairly interpreted by GMA to  define the exclusion zone.  
• Veto the proposal that GMA approve dogs that are not hunting breeds, for duck hunting.
• Support the proposal that deer hunters must make reasonable efforts to retrieve and kill a wounded animal before continuing to hunt.  

ENVIRONMENT AND SUSTAINABILITY 

Overview:

Shooters pushed to have e-callers permitted in the 2012 regulations, despite the obvious breach of  fair chase principles. The sustainability risks were well known – for example, the RIS (p.24) notes  that the U.S. banned electronic callers for the hunting of migratory game birds in 1957. The highly  toxic properties of lead have been well known for decades with countries in the Northern  hemisphere phasing out lead for years. Tiny lead fragments enter the flesh of the animal and are  consumed when eaten. The RIS over-estimates the number of shooters who may have to replace  their firearms due to a lead ban. Up to half of deer hunters are inactive, and in 2023 more than 80%  of quail licences were inactive (duck licences include an entitlement to shoot quail).  

The migratory shorebird, Latham’s Snipe, was banned from hunting Australia-wide, more than 40  years ago. The Blue-winged Shoveler has not been legally hunted in VIC since 2017, or in SA since  2003, and was part of the 1995 permanent ban on bird hunting in NSW. This species is now on  Victoria’s threatened species list. 

Suggested changes: 

• Immediate ban on lead ammunition for quail hunting, and a maximum of one year (not four  years, as proposed) to end lead ammunition in deer hunting.  
• Immediate ban on e-callers for duck and quail.  
• No compensation for any shooters and retailers who claim disadvantage from these bans.
• Immediate removal of Blue-winged Shoveler and Latham’s Snipe from game bird listings.  

GOVERNMENT POLICY 

Suggested changes: 

• Government needs to update policy following the parliamentary Inquiry into Recreational  Native Bird Hunting Arrangements. The RIS continually quotes government policy circa 2020 - already at least 4 years old. 
• Oppose taxpayer-funded Action Plans to expand hunting, given cost-of-living pressures,  mounting state debt and majority community support for a ban on bird hunting. 
• Native bird hunting should be put on hold until all proposed reforms take place. 
• Government agencies should cease claims of economic and social benefits from hunting; these rely on hunters’ self-assessment through opt-in surveys that attract keen hunters.
• Government agencies should cease claims of hunting’s environmental benefits. The main conservation work of hunting groups is to install nest boxes to produce gun fodder. More than 70 per cent of game hunters do not belong to any club. The privately owned wetlands  showcased by FGA have been largely funded by taxpayers and a philanthropic trust6. The government should task another agency to study the negative economic and social impacts of hunting on regional communities (e.g. loss of amenity, income, tourism, sleep,  and mental health).  

DUCK SHOOTING SITES 

Overview: 

The number of duck licences has fallen by 16% from 26,296 (2014) to 22,043 (2023), meanwhile, the Victorian population has boomed by 18%. The land use rules date back decades when duck licences were much higher. The Inquiry disclosed the total area of public land available for duck shooting,  covering one-seventh of the state. In addition, most ducks are shot on private land. 

It is time to scale back the area available to duck shooters:  

(1) because of proportionality grounds, and  

(2) because community sentiment has shifted against duck shooting, and  

(3) because of growth in regional populations and nature-based tourism.  

Although hunting is permitted on Ramsar wetlands, a recent report released by Geelong Duck  Rescue reveals widespread environmental abuse by duck shooters. The majority (60%) of Ramsar  sites around the world are not permitted as hunting sites. Well-supported requests from community members and environmentalists have long advocated for the permanent closure of some wetlands. 

Suggested changes:

• Reduction in the number of duck shooting sites in Victoria. 
• Disclosure of the number of duck shooting sites in Victoria. This number has never been disclosed by government agencies, even in approximate terms, but is thought to be around  20,000 – an impossible number to monitor. 
• A safety review of all duck shooting sites before they become available for any future season; consider proximity to residences, farming properties and business premises. 
• Banning of duck shooting on all Ramsar wetlands and on other sites supported by cogent community campaigns.  

DEER HUNTING  

Suggested changes:  

• Disclosure of the total area where deer hunting is permitted. 
• No Shires should be approved for deer hunting until there has been thorough consultation  with their ratepayers; many are probably unaware of the current public consultation  process.  
• The RIS proposes to approve heat-imaging devices for daytime use in hunting deer. These  should not be approved before thorough independent assessment of the risks to public  safety. 
• In NSW, deer hunters must provide details of their planned location, vehicle, and gain  written approval before each hunting trip. This should also be a requirement for deer  hunters in Victoria.  
• Do not proceed with the RIS proposal of ‘artificial watering points’ to attract deer onto  private properties that offer hunting experiences to paying clients.  
• Do not support the use of crossbows for hunting deer (RIS p.17)  

BIRD FARMS 

Overview: 

In 2012 former Minister Walsh removed the requirement for a bird hunting licence for clients at  game bird farms and introduced free 7-day licences for these clients. The RIS in 2012 stated (p.100): 

“Game bird farms often cater for corporate events where most participants are not regular hunters.  These people can experience hunting in a controlled environment under expert instruction…The  proposal to attach no fee will support industry, with commercial benefits outweighing the small  costs associated with the enforcement of regulations on game bird farms.” 

The potential for cruelty would appear to be high, with novices shooting for entertainment at  corporate gatherings, possibly intoxicated, and well away from any regulatory supervision.  

Suggested changes:

• Full disclosure on GMA website of:
  • the name, address and owner of each bird farm business.
  • Licence fees paid by the owner.
  • Dates of GMA inspections, whether there was advance warning of the inspection, and  the report of the inspection. 

• Installation of CCTV at these properties, with the footage to be independently reviewed by  animal experts selected by RSPCA Victoria (even though RSPCA has no jurisdiction over any  hunting offences). 

OTHER ISSUES TO ADDRESS 

Suggested changes  

• A review of past offences that must be disclosed when applying for a game licence. It is no  longer sufficient to rely on police vetting for a gun licence.  
• The online application for a game licence does not require disclosure of domestic violence  offences. Disclosure is limited to wildlife, animal cruelty, environmental, and firearms  offences. 
• Review the online licence application, e.g. remove reference to compliance with the Wildlife  (Game) Regulations 2012. 
• If concessional licences continue, require online applicants to provide the number of their  concession card and GMA should verify this as genuine, before issuing the licence. • Full disclosure of special arrangements that allow people to hunt game animals without a  game licence (p.15 of the RIS).  
• Full disclosure of the work undertaken, and results achieved, by the persons or organisations  that make use of these provisions that circumvent the need for a game licence. None of  them should be granted an exemption from complying with the Wildlife (Game) Regulations  2024.

Thumbnail Image Credit: Jo-Anne McArthur / We Animals Media