supplementary submission 2
Revisiting the criteria for listing as threatened
Two years after first submitting the nomination, the NSW Scientific Committee had still been unable or unwilling to formalise a decision, and again invited additional "new" information in support of the 2011 Nomination to List the Four Large Macropods as VULNERABLE under the TSCA 1995.
The Committee had continued to assert "that these species do not meet any of the criteria for listing as threatened species" whilst not engaging with the evidence provided in the 2011 Nomination or in the 2012 first supplementary submission.
This second supplementary submission revisits the criteria for listing species to the NSW Threatened Species List.
The Committee had continued to assert "that these species do not meet any of the criteria for listing as threatened species" whilst not engaging with the evidence provided in the 2011 Nomination or in the 2012 first supplementary submission.
This second supplementary submission revisits the criteria for listing species to the NSW Threatened Species List.
3.11.2013
To the NSW Scientific Committee
PO Box 1967
HURSTVILLE NSW 2220
Dear NSW Scientific Committee,
Thank you for your invitation to submit additional “new” information to the Committee in support of my 2011 Nomination to List the 4 Large Macropods as VULNERABLE under the TSCA 1995.
It is fair to place the “new” information (below) within the context of the Scientific Committee’s response to the 200 page nomination I submitted in December 2011, and the 70 page supplement I submitted in December 2012:
The Committee has found that these species do not meet any of the criteria for listing as threatened species…
In the first place the Committee in their response have so far failed to acknowledge a very important criteria for listing: the fact of severe decline in simple abundance, in 200 years of European settlement.
There has so far been no attempt to contest my suggested reductions of 90-98% in large macropod numbers (based on the departments own data, as well as on historic and contemporary situations) by either the Committee or the kangaroo “experts” who support the harvest industry and the widely promulgated theories of so-called “over-abundance”.
That the Committee has acknowledged that the data showed decline, but was followed by recovery (based on Payne 2013) and again simplistically suggesting there are more than there ever were on account of “no aborigines or dingoes”, “clearing has made things better” and “more water points” etc is completely inadequate.
This final submission must therefore take the form of an unstructured discussion paper, as time constraints in preparing this paper limited my capacity to properly and carefully construct my arguments. I have not had time to chase up all the citations I have referred to, and I have not included a reference list. If the Committee is serious about engaging with my concerns in good faith and requires more information, please provide the courtesy of negotiating a professional services contract, to enable me to provide a more detailed and considered response.
I have only been able to attend to this “project” between paid contracts, with serious time only being available in the last week before the Committee required the submission. It does seem incredible to me that the fate of Australia’s most recognisable and iconic species rests with the capacity of a single and unfunded independent researcher to persuade the Committee that things are not as fantastic as industry sector “researchers” have been making out, as 1M kangaroos continue to be shot annually across the nation.
My reading of the Criteria
To the NSW Scientific Committee
PO Box 1967
HURSTVILLE NSW 2220
Dear NSW Scientific Committee,
Thank you for your invitation to submit additional “new” information to the Committee in support of my 2011 Nomination to List the 4 Large Macropods as VULNERABLE under the TSCA 1995.
It is fair to place the “new” information (below) within the context of the Scientific Committee’s response to the 200 page nomination I submitted in December 2011, and the 70 page supplement I submitted in December 2012:
The Committee has found that these species do not meet any of the criteria for listing as threatened species…
In the first place the Committee in their response have so far failed to acknowledge a very important criteria for listing: the fact of severe decline in simple abundance, in 200 years of European settlement.
There has so far been no attempt to contest my suggested reductions of 90-98% in large macropod numbers (based on the departments own data, as well as on historic and contemporary situations) by either the Committee or the kangaroo “experts” who support the harvest industry and the widely promulgated theories of so-called “over-abundance”.
That the Committee has acknowledged that the data showed decline, but was followed by recovery (based on Payne 2013) and again simplistically suggesting there are more than there ever were on account of “no aborigines or dingoes”, “clearing has made things better” and “more water points” etc is completely inadequate.
This final submission must therefore take the form of an unstructured discussion paper, as time constraints in preparing this paper limited my capacity to properly and carefully construct my arguments. I have not had time to chase up all the citations I have referred to, and I have not included a reference list. If the Committee is serious about engaging with my concerns in good faith and requires more information, please provide the courtesy of negotiating a professional services contract, to enable me to provide a more detailed and considered response.
I have only been able to attend to this “project” between paid contracts, with serious time only being available in the last week before the Committee required the submission. It does seem incredible to me that the fate of Australia’s most recognisable and iconic species rests with the capacity of a single and unfunded independent researcher to persuade the Committee that things are not as fantastic as industry sector “researchers” have been making out, as 1M kangaroos continue to be shot annually across the nation.
My reading of the Criteria
(3) For Vulnerable Species
For the purposes of section 10(4) of the Act, a species is facing a high risk of extinction in NSW in the medium-term future if, in the opinion of the Scientific Committee, it meets the criteria specified for vulnerable species in one or more of the other clauses in this Division.
6 Reduction in population size of species
The species has undergone, is observed, estimated, inferred or reasonably suspected to have undergone or is likely to undergo within a time frame appropriate to the life cycle and habitat characteristics of the taxon:
(c) for vulnerable species – a moderate reduction in population size, based on either of the key indicators
4 Definition
Key indicators in relation to a species or population means either:
(a) An index of abundance appropriate to the taxon
For the purposes of section 10(4) of the Act, a species is facing a high risk of extinction in NSW in the medium-term future if, in the opinion of the Scientific Committee, it meets the criteria specified for vulnerable species in one or more of the other clauses in this Division.
6 Reduction in population size of species
The species has undergone, is observed, estimated, inferred or reasonably suspected to have undergone or is likely to undergo within a time frame appropriate to the life cycle and habitat characteristics of the taxon:
(c) for vulnerable species – a moderate reduction in population size, based on either of the key indicators
4 Definition
Key indicators in relation to a species or population means either:
(a) An index of abundance appropriate to the taxon
On the basis of no attempt being made by either the industry-based scientists nor the Department, nor in fact the Committee, to contest the simple fact of widespread and obvious decline in abundance of the large macropods (see Wallaroos in the Northern Tablelands KMZ, for example, or historical references to abundant wildlife of all kinds), the Committee is left in a position where the species obviously do meet this criteria, and must be listed at least as VULNERABLE under the TSCA 1995, if not as a higher category of threatened species. For example ENDANGERED may be appropriate for the Wallaroo (see below).
Can the Committee please clearly enunciate in their expected final rejection of the nomination the details and workings of how I have got this so wrong? Questions that will need to be addressed by the Committee are enumerated at the end of this submission.
Can the Committee please clearly enunciate in their expected final rejection of the nomination the details and workings of how I have got this so wrong? Questions that will need to be addressed by the Committee are enumerated at the end of this submission.
Reference to the guidelines
While there are guidelines for the preparation of nominations under the Act, this obviously presents problems for anyone seeking to make a nomination. In the first place they need to be aware that the guidelines exist. Further, as individuals, people will rarely be able to provide the detail required. This would mean that in real terms the only organisations that would be capable of making formal nominations would be institutions such as universities, however they generally do not do things unless there is incentive (funding). The intent of the Act, to allow and even encourage people to take on this important role in conservation (flag issues with species in decline and potential KTPs, for example), would be curtailed by enforcing the guidelines, which would make it almost impossible for individuals to effectively nominate.
In 2002 I wrote a nomination to list subsidence from longwall mining as a KTP in NSW, by simply stating the facts. Longwall mining causes subsidence, related cracking drains swamps and other water dependent ecosystems, and threatened species are affected (for example the Blue Mountains Water Skink and Grevillea acanthifolia in the swamps I had studied). The industry’s preferred consultants were (and are) failing to monitor or properly report rather obvious and severe impacts. I wrote that nomination in a very basic form (12 pages, including several pages of maps and pictures of impacted swamps, cracks etc) with not a guideline in sight. It took over 2 years, but finally the Committee accepted that my findings of severe subsidence impact were factual, and the KTP was rightly listed.
In 2002 I wrote a nomination to list subsidence from longwall mining as a KTP in NSW, by simply stating the facts. Longwall mining causes subsidence, related cracking drains swamps and other water dependent ecosystems, and threatened species are affected (for example the Blue Mountains Water Skink and Grevillea acanthifolia in the swamps I had studied). The industry’s preferred consultants were (and are) failing to monitor or properly report rather obvious and severe impacts. I wrote that nomination in a very basic form (12 pages, including several pages of maps and pictures of impacted swamps, cracks etc) with not a guideline in sight. It took over 2 years, but finally the Committee accepted that my findings of severe subsidence impact were factual, and the KTP was rightly listed.
More recently I nominated Caladenia attenuata as ENDANGERED under the TSCA 1995, again without any reference to the guidelines. The Committee sent someone to have a look for the species, they did not find it, and (rather illogically and indeed even confusingly) the Committee then wrote to me (letter dated 28th November 2011) to suggest I withdraw the nomination! The Committee may remember I responded that instead of withdrawing the nomination, given that the species could not be found even by presumably highly expert and targeted survey, I would prefer to upgrade the nomination to CRITICALLY ENDANGERED or EXTINCT, again without any reference to any guidelines or criteria.
On the 7th October 2013 the Committee advised that preliminary determination had been made to list the orchid in question as CRITICALLY ENDANGERED, after a second year of survey had located a single individual plant which may be the species in question (identification is pending confirmation).
My point is that guidelines are just that, guidelines. There is no regulatory enforcement requiring adherence to such guidelines, and the Committee has made determinations in the past based on nominations which were written outside any formal guideline framework. I could write an essay on how the nomination and supplements in their present form do meet the requirements for provision of information required to support listing of the large macropods as VULNERABLE, as nominated. If the Committee is going to insist on nominations complying with the guidelines in form and every particular of their content, this will be the end of community nominations, and a departure from precedent.
Even more importantly, as an unfunded project, I was not and am not in a position where I can spend several additional months re-writing the macropod nomination to conform to the guidelines, and given the situation kangaroos can’t afford this time either. Given that the latest version of the guidelines are actually dated January 2012 (after I submitted the nomination in December 2011), the Committee will surely concede that suggesting that the nomination must comply with the latest iteration of the guidelines could be seen as something of a goal-post shifting exercise, or an obstruction to getting the serious issues I have raised considered and appropriately addressed.
On the 7th October 2013 the Committee advised that preliminary determination had been made to list the orchid in question as CRITICALLY ENDANGERED, after a second year of survey had located a single individual plant which may be the species in question (identification is pending confirmation).
My point is that guidelines are just that, guidelines. There is no regulatory enforcement requiring adherence to such guidelines, and the Committee has made determinations in the past based on nominations which were written outside any formal guideline framework. I could write an essay on how the nomination and supplements in their present form do meet the requirements for provision of information required to support listing of the large macropods as VULNERABLE, as nominated. If the Committee is going to insist on nominations complying with the guidelines in form and every particular of their content, this will be the end of community nominations, and a departure from precedent.
Even more importantly, as an unfunded project, I was not and am not in a position where I can spend several additional months re-writing the macropod nomination to conform to the guidelines, and given the situation kangaroos can’t afford this time either. Given that the latest version of the guidelines are actually dated January 2012 (after I submitted the nomination in December 2011), the Committee will surely concede that suggesting that the nomination must comply with the latest iteration of the guidelines could be seen as something of a goal-post shifting exercise, or an obstruction to getting the serious issues I have raised considered and appropriately addressed.
The Committee’s Preliminary Response
The Committee has responded in part by talking about how changes in abundance may vary between populations, with species thereby (and theoretically) meeting criteria according to large reductions in one population while other populations may be stable or increasing, without providing any details of how this situation may be applicable to kangaroos.
In fact kangaroos formerly existed as a continuous population across their range in NSW (probably with island exclusions where habitat was unsuitable, such as sandstone escarpment country, swamps and water bodies etc). The Committee even discussing sub-populations with regard to kangaroos may be interpreted as an acknowledgement, perhaps unwittingly, to the widespread but as yet unacknowledged fragmentation of the former meta-populations of the species. At some stage someone is going to have to concede that the original meta-populations must therefore have experienced a corresponding, widespread and ongoing decline, in its now fractured state.
Indeed the Committee goes on to suggest for the species in question, that consideration of decline over a period of 21-30 years is appropriate when assessing their current conservation status, while seeming intent on ignoring the decline shown over the 200 year time frame discussed in the 2011 nomination.
In addition to a clear decline over 200 years due to European transformation of the Australian landscape, the nomination also discusses macropod decline over the exact time frame specified by the Committee (21-30 years). This decline is demonstrated using the department’s own data sets, clearly showing declines of up to and exceeding 80-90% over the 10 years leading up to lodgement of the nomination (see the nomination and supplementary submission). The Committee describes and obviously accepts the decline over this period shown in the data, but then refer to “increases” since the breaking of drought to assure us that everything is just fine:
With the breaking of the drought in 2010/11 a subsequent increase in [kangaroo] abundance had occurred (Payne 2013)
This convenient “increase” is discussed in some detail below, and in the supplementary submission to the original nomination (Mjadwesch 2012). I have referred also to Professor Gordon Grigg’s “populations increase albeit slowly” (Brisbane Radio 4BC 17.7.2012; audio is available if required) reiterating the limited biological capacity of kangaroo populations to increase.
Payne’s “data” does not show anything like a “slow” increase. A 249% increase in kangaroo survey data must be discarded and indeed condemned by all rational scientists and wildlife/ conservation biologists.
Similarly the problems with surveys by Cairns in the Central Tablelands invalidate any results showing “increase” in this KMZ. Flying over even more national parks and other non-shooting areas in 2011 than in 2008 (while saying they didn’t fly over any), and applying kangaroos counted therein to surrounding farmland (where kangaroos are shot) is not a valid methodology for detecting changes in kangaroo populations in the “shot” regions. Further clearly incorrect habitat stratifications apply “high” and “medium” kangaroo densities to habitats where there are no kangaroos (see the first supplement, page 16). This non-science makes a mockery of the purported purpose of kangaroo “management” in NSW, which is supposed to be “scientific” and “sustainable”.
In fact kangaroos formerly existed as a continuous population across their range in NSW (probably with island exclusions where habitat was unsuitable, such as sandstone escarpment country, swamps and water bodies etc). The Committee even discussing sub-populations with regard to kangaroos may be interpreted as an acknowledgement, perhaps unwittingly, to the widespread but as yet unacknowledged fragmentation of the former meta-populations of the species. At some stage someone is going to have to concede that the original meta-populations must therefore have experienced a corresponding, widespread and ongoing decline, in its now fractured state.
Indeed the Committee goes on to suggest for the species in question, that consideration of decline over a period of 21-30 years is appropriate when assessing their current conservation status, while seeming intent on ignoring the decline shown over the 200 year time frame discussed in the 2011 nomination.
In addition to a clear decline over 200 years due to European transformation of the Australian landscape, the nomination also discusses macropod decline over the exact time frame specified by the Committee (21-30 years). This decline is demonstrated using the department’s own data sets, clearly showing declines of up to and exceeding 80-90% over the 10 years leading up to lodgement of the nomination (see the nomination and supplementary submission). The Committee describes and obviously accepts the decline over this period shown in the data, but then refer to “increases” since the breaking of drought to assure us that everything is just fine:
With the breaking of the drought in 2010/11 a subsequent increase in [kangaroo] abundance had occurred (Payne 2013)
This convenient “increase” is discussed in some detail below, and in the supplementary submission to the original nomination (Mjadwesch 2012). I have referred also to Professor Gordon Grigg’s “populations increase albeit slowly” (Brisbane Radio 4BC 17.7.2012; audio is available if required) reiterating the limited biological capacity of kangaroo populations to increase.
Payne’s “data” does not show anything like a “slow” increase. A 249% increase in kangaroo survey data must be discarded and indeed condemned by all rational scientists and wildlife/ conservation biologists.
Similarly the problems with surveys by Cairns in the Central Tablelands invalidate any results showing “increase” in this KMZ. Flying over even more national parks and other non-shooting areas in 2011 than in 2008 (while saying they didn’t fly over any), and applying kangaroos counted therein to surrounding farmland (where kangaroos are shot) is not a valid methodology for detecting changes in kangaroo populations in the “shot” regions. Further clearly incorrect habitat stratifications apply “high” and “medium” kangaroo densities to habitats where there are no kangaroos (see the first supplement, page 16). This non-science makes a mockery of the purported purpose of kangaroo “management” in NSW, which is supposed to be “scientific” and “sustainable”.
Area Of Extent (AOE) and Extent Of Occupancy (EOO)
On the basis of the Committee’s own calculations for Area Of Extent (AOE) and Extent Of Occupancy (EOO), based on the complete data set of observations included as Atlas of Living Australia data points, and assuming occurrence throughout their range in varying densities prior to the advent of white man and farming, indicates the following tiny remainder may persist:
There are simple errors in the Committee’s maps of AOE, not least of which are areas of extent including (in the case of the Eastern Grey Kangaroo and the Wallaroo) hundreds of square kilometres of ocean, not to mention large chunks of Victoria and southern Queensland. According to the NSW Scientific Committee’s most recent response the Eastern Grey Kangaroo and Wallaroos AOE in NSW exceeds the area of NSW! (800,628 km2)
In the case of the Western Grey Kangaroo the Scientific Committee’s polygon cuts across the top of NSW, rather than extending into Queensland (see Strahan etc). This is another curious error, as the species distribution is mapped everywhere (for example Strahan (Ed) 2008) as extending through north-western NSW into south-western Queensland.
It is however true that Queensland’s DERM no longer reports estimates of the Western Grey Kangaroo population in the state (a review of Queensland survey data is in prep, as part of a case study discussing the conservation and status of the large macropods nationally), and they ran out of them to shoot at Narrabri (see page 76 of the nomination). It may be that the Western Grey Kangaroo is now extinct in the Sunshine State (or maybe persists as a disjunct and isolated population in Currawinya NP), possibly making the Committee’s map of AOE (omitting northern NSW indicating a discontinuity with Queensland) presciently correct, though they do still occur in Ledknapper Nature Reserve (Mjadwesch 2006 and Mjadwesch 2009, illustrated below) and their range is likely to extend in NSW to the Queensland border, in the author’s opinion.
In the case of the Western Grey Kangaroo the Scientific Committee’s polygon cuts across the top of NSW, rather than extending into Queensland (see Strahan etc). This is another curious error, as the species distribution is mapped everywhere (for example Strahan (Ed) 2008) as extending through north-western NSW into south-western Queensland.
It is however true that Queensland’s DERM no longer reports estimates of the Western Grey Kangaroo population in the state (a review of Queensland survey data is in prep, as part of a case study discussing the conservation and status of the large macropods nationally), and they ran out of them to shoot at Narrabri (see page 76 of the nomination). It may be that the Western Grey Kangaroo is now extinct in the Sunshine State (or maybe persists as a disjunct and isolated population in Currawinya NP), possibly making the Committee’s map of AOE (omitting northern NSW indicating a discontinuity with Queensland) presciently correct, though they do still occur in Ledknapper Nature Reserve (Mjadwesch 2006 and Mjadwesch 2009, illustrated below) and their range is likely to extend in NSW to the Queensland border, in the author’s opinion.
Notice how it’s hanging out near some trees? Trees are actually pretty important for kangaroos during hot weather; this photo was taken towards the end of the drought, and the kangaroos that were observed during survey were frequently observed sheltering under trees during the day.
With regard to EOO the Committee suggest their approach in estimating this was conservative, because “the species will also occur on areas between known records”. This may be true but there is no evidence for this, and this cheese can be cut two ways.
The Committee have relied on records which date back to the first observations and collections of kangaroos in NSW (Atlas of Living Australia records for NSW), being:
Eastern Grey Kangaroo: 1788-1800 (few records); 1900 onwards (many records)
Western Grey Kangaroo: 1954 (first collections)
Wallaroo: collections started in 1912
Red Kangaroo: 1922 (first specimen record in the Living Atlas)
It is extremely optimistic of the Committee (and also rather unscientific) to presume that the nominated species persist today everywhere that they have ever been observed / collected. In fact the whole point of the nomination is that this does not seem to be the case, so perhaps this means the Committee’s EOO is an over-estimate.
Further, for the Committee to suggest that they tried to use the data from the Atlas of Living Australia to determine if there has been a decline in the last 30 years, simply by splitting the data into pre- and post- 1982 records was disingenuous to say the least, and it is no wonder that this approach was not helpful.
What the Committee should have done (and what I have been doing) is to go through the records, one by one, and determine whether kangaroos continue to persist at each location historically logged as having had kangaroos present. It does not take a lot of review to find instead of a 4km2 area of continuing occupancy around an historic collection / observation location, that the opposite is true, and absence is the norm.
The Eastern Grey Kangaroo map on page 14 of the Committee’s response best exemplifies the problem with the approach the Committee has taken with regard to EOO. Red dots (indicating presence) occur throughout the entire Sydney basin and right along the NSW coastline, where development has severely fragmented the species’ distribution and reduced their abundance (a Sydney Basin Bioregion Eastern Grey Kangaroo ENDANGERED POPULATION nomination is in prep).
The Committee actually states for the Eastern Grey Kangaroo that “Some habitat, especially in the coastal zone…has been lost… to urbanisation”, then the Committee provides an EOO map which covers the entire coastline in red dots (indicating occupancy), based on historic records. This self-contradictory position is untenable in a scientific sense.
Not only does this mean that the Committee have estimated current EOO for the species based on records from locations where kangaroos clearly no longer occur, the Committee have also applied 1km square radii around these locations (every Living Atlas record has been used to predict 4km2 of occurrence). In addition to this, when this methodology is applied to areas where kangaroos do still occur (for example at the bottom of sandstone escarpment country), the EOO calculation extends their supposed range into locations and habitats where they simply do not occur. Vertebrate fauna surveys have demonstrated absence from many habitats throughout the Sydney Basin Bioregion (see the first submission, last page of attachments – the tiny blue dots represent systematic fauna quadrats), into which areas the Committee have incorrectly inferred presence.
In addition the Committee’s simplistic calculation of the various species EOO fails to consider what is happening at a finer scale, where a single record does not necessarily mean occupancy of the surrounding 4km². Additionally when points indicating factually isolated populations fall close to each other, the 4km2 EOO units may actually meet in the middle, significantly increasing the theoretical “area of occupancy”, while the populations themselves may be effectively isolated and discontinuous.
For example in and around Bathurst the Boundary Road population is clearly separated (by roads and ever increasing urban development) from the Mt Panorama population. Eastern Grey Kangaroos do not have a continuous EOO as indicated by the Committee (Figure below); Wallaroos even less so. Needless to say the observation in Bathurst and at Marsden Lane (black EOO squares) are no longer valid (kangaroos no longer occur at these locations).
The Committee have relied on records which date back to the first observations and collections of kangaroos in NSW (Atlas of Living Australia records for NSW), being:
Eastern Grey Kangaroo: 1788-1800 (few records); 1900 onwards (many records)
Western Grey Kangaroo: 1954 (first collections)
Wallaroo: collections started in 1912
Red Kangaroo: 1922 (first specimen record in the Living Atlas)
It is extremely optimistic of the Committee (and also rather unscientific) to presume that the nominated species persist today everywhere that they have ever been observed / collected. In fact the whole point of the nomination is that this does not seem to be the case, so perhaps this means the Committee’s EOO is an over-estimate.
Further, for the Committee to suggest that they tried to use the data from the Atlas of Living Australia to determine if there has been a decline in the last 30 years, simply by splitting the data into pre- and post- 1982 records was disingenuous to say the least, and it is no wonder that this approach was not helpful.
What the Committee should have done (and what I have been doing) is to go through the records, one by one, and determine whether kangaroos continue to persist at each location historically logged as having had kangaroos present. It does not take a lot of review to find instead of a 4km2 area of continuing occupancy around an historic collection / observation location, that the opposite is true, and absence is the norm.
The Eastern Grey Kangaroo map on page 14 of the Committee’s response best exemplifies the problem with the approach the Committee has taken with regard to EOO. Red dots (indicating presence) occur throughout the entire Sydney basin and right along the NSW coastline, where development has severely fragmented the species’ distribution and reduced their abundance (a Sydney Basin Bioregion Eastern Grey Kangaroo ENDANGERED POPULATION nomination is in prep).
The Committee actually states for the Eastern Grey Kangaroo that “Some habitat, especially in the coastal zone…has been lost… to urbanisation”, then the Committee provides an EOO map which covers the entire coastline in red dots (indicating occupancy), based on historic records. This self-contradictory position is untenable in a scientific sense.
Not only does this mean that the Committee have estimated current EOO for the species based on records from locations where kangaroos clearly no longer occur, the Committee have also applied 1km square radii around these locations (every Living Atlas record has been used to predict 4km2 of occurrence). In addition to this, when this methodology is applied to areas where kangaroos do still occur (for example at the bottom of sandstone escarpment country), the EOO calculation extends their supposed range into locations and habitats where they simply do not occur. Vertebrate fauna surveys have demonstrated absence from many habitats throughout the Sydney Basin Bioregion (see the first submission, last page of attachments – the tiny blue dots represent systematic fauna quadrats), into which areas the Committee have incorrectly inferred presence.
In addition the Committee’s simplistic calculation of the various species EOO fails to consider what is happening at a finer scale, where a single record does not necessarily mean occupancy of the surrounding 4km². Additionally when points indicating factually isolated populations fall close to each other, the 4km2 EOO units may actually meet in the middle, significantly increasing the theoretical “area of occupancy”, while the populations themselves may be effectively isolated and discontinuous.
For example in and around Bathurst the Boundary Road population is clearly separated (by roads and ever increasing urban development) from the Mt Panorama population. Eastern Grey Kangaroos do not have a continuous EOO as indicated by the Committee (Figure below); Wallaroos even less so. Needless to say the observation in Bathurst and at Marsden Lane (black EOO squares) are no longer valid (kangaroos no longer occur at these locations).
The Bathurst map (see the first submission) and ACT map (from my expert witness statement to the ACAT in the ACT earlier this year, available if required), the Mandurama & Central Tablelands maps (see below), and the Sydney Basin map (in production) clearly suggest that the actual EOO for the Eastern Grey Kangaroo (for example) may be far less than indicated by the Committee, and certainly illustrate an extremely dire situation (fragmented populations persisting at often extremely low densities, with no safe refugia).
For example Eastern Grey Kangaroos occur and are protected at Junction Reef Reserve, where there has been little or no shooting in this locked reserve (closed for mining) for about 30 years. However the kangaroos do not penetrate very far into surrounding farmland (pic below), with the Junction Reef Reserve population only occupying roughly 2km², and with even a fair percentage of the habitat here being too steep / unsuitable for them. Wallaroos occur in the steeper sections instead.
According to this representation, across the Mandurama landscape the Eastern Grey Kangaroo has declined in EOO by some 66.6%, in terms of simple abundance they have declined in the order of 95%, while scientists and the industry report plagues of them (see frequent media reports), and the department allocates a quota for over 50,000 kangaroos per annum (CT-South, see below).
Further, the Committee’s use of data points for their calculations of present day extent includes (in the case of Eastern Grey Kangaroos) all records back to the 1800s, when clearly many of the records are from locations where kangaroos are no longer present, or where records themselves are sometimes of out-of-habitat, injured, dead or dying animals (for example WIRES observations).
According to the Committee’s EOO methodology, a record of a kangaroo run over at the edge of the ADI site in western Sydney will be plotted as part of a healthy population extending 1km out into adjacent fully developed urban /residential zones, as well as in the ADI site itself, where their persecution has been unrelenting since developers decided to develop the site. Here the population has so far been reduced from 3200 animals to only perhaps 800, many of which have been sterilised (Sydney Basin EGK study in prep).
Further, the Committee’s use of data points for their calculations of present day extent includes (in the case of Eastern Grey Kangaroos) all records back to the 1800s, when clearly many of the records are from locations where kangaroos are no longer present, or where records themselves are sometimes of out-of-habitat, injured, dead or dying animals (for example WIRES observations).
According to the Committee’s EOO methodology, a record of a kangaroo run over at the edge of the ADI site in western Sydney will be plotted as part of a healthy population extending 1km out into adjacent fully developed urban /residential zones, as well as in the ADI site itself, where their persecution has been unrelenting since developers decided to develop the site. Here the population has so far been reduced from 3200 animals to only perhaps 800, many of which have been sterilised (Sydney Basin EGK study in prep).
The Committee’s methodology for calculating AOE and EOO is simply not valid, however it is irrelevant to the nomination anyway.
I am not arguing reduced AOE (see page 14 of the nomination “It’s Not Range Reduction…”), nor am I arguing that the species occupy such small areas today that they would qualify as threatened species under the EOO criteria. I am arguing severe decline since European settlement, >90% overall, and in many regions up to and exceeding 98% reductions, even to local extinction, with clearing of habitat and unrelenting persecution being the principle drivers of this decline. From Jackson & Vernes (2010):
Macropods are often considered a nuisance by the agricultural community, and enormous numbers have been killed as pests. More recently, recognition of their commercial potential has led to many more being “harvested”…
I have come across no reference that has suggested that there has been any letup in this persecution, and the processes operating against kangaroos continue unchecked, indeed the commercial harvest is supported by both tiers of government.
The Committee needs to re-focus on the content of the nomination and supplements, rather than constructing straw men and knocking them down.
I am not arguing reduced AOE (see page 14 of the nomination “It’s Not Range Reduction…”), nor am I arguing that the species occupy such small areas today that they would qualify as threatened species under the EOO criteria. I am arguing severe decline since European settlement, >90% overall, and in many regions up to and exceeding 98% reductions, even to local extinction, with clearing of habitat and unrelenting persecution being the principle drivers of this decline. From Jackson & Vernes (2010):
Macropods are often considered a nuisance by the agricultural community, and enormous numbers have been killed as pests. More recently, recognition of their commercial potential has led to many more being “harvested”…
I have come across no reference that has suggested that there has been any letup in this persecution, and the processes operating against kangaroos continue unchecked, indeed the commercial harvest is supported by both tiers of government.
The Committee needs to re-focus on the content of the nomination and supplements, rather than constructing straw men and knocking them down.
"New" reviews
The Committee makes repeated reference to Payne (2013), being the annual kangaroo “harvest” quota report.
Directly comparable data exist for 0.4-0.6 of the 3 generation length, from 2001 to 2012 (Payne 2013). Over this time period these data appear to show a decline and then an increase in [kangaroo] abundance (Payne 2013).
The “increase” referred to by Payne was one subject discussed in the supplementary submission to the Committee, in which a maximum population growth rate of 249% was reported by Payne in an early release of their 2012 survey results. Will the Committee reject the nomination on the basis of this convenient and extremely favourable “evidence”, showing an improbable (biologically impossible) strong increase following the break of drought, which was provided by someone with a clear conflict of interest in maintaining the status quo? If so the Committee will be on the record as accepting that kangaroo populations can increase at this rate, while in fact breeding females produce a single young per annum. This is another scientifically untenable position.
A document such as Reassessing the spatial and temporal dynamics of kangaroo populations (Pople et al 2010) should have reset the understanding of kangaroos nationally, to allow more refined models for distribution to accurately provide up to date information on factors such as the various species’ extent of occupancy, for example.
It is alarming that this paper is instead seeking to come up with yet another indirect mechanism (NDVI) for the modelling of kangaroo populations, after increased rainfall following the break of drought did not result in even lagged super-abundant populations, as the researchers had rather optimistically expected would occur.
This fact of non-response in kangaroo populations following the break of drought (other than responses as a consequence of changing variables such as correction factors, or flying over national parks to fluff-up the numbers a bit) is simply a result of low reproductive rates for the species. Perhaps the researchers need to revisit the basics of kangaroo reproduction, for a possible alternative explanation of why kangaroos have not exploded across the landscape, following the break of the most recent drought.
Archer, Flannery and Grigg (1985) are on the record (note their position does not make reference to any source documents), stating what they considered to be a typical population growth rate for the species:
In good conditions an annual rate of increase of at least 25 per cent can be maintained.
While this rate of growth has never been actually measured in any detailed field studies, and while it is roughly double the maximum population growth rate that has been measured (eg: Arnold, Bilton & Croft etc), as well as being roughly double the modelled maximum growth rates (based on biological factors – see Mjadwesch 2011/2012), it is a long way shy of Payne’s 249% growth per annum.
The Committee, in publicly supporting Payne’s biologically impossible “data”, and the existing frameworks for management of the species (with harvest rates equalling or far exceeding potential growth rates for the species, under variable conditions) will be in serious danger of losing scientific credibility.
Archer et al (1985) continues:
Drought may cause precipitous falls in density…
The Committee should take the time to review the harvest model, which does not reduce harvest rates even during drought when populations crash (according to every paper ever written). This situation has been ongoing for 30 years, and the only logical conclusion must be that the populations have declined, which is demonstrated in the nomination using the departments own data.
These facts simply mean that heavily reduced populations will struggle to recover, particularly when many processes continue to operate against the survivors (including ongoing persecution, competition with stock for the little remaining feed and water, roads, fences, disease, catastrophe etc).
No-one, the Committee included, has attempted to contest the fact of low macropod reproductive rate to date. After initially stating that PGR could be “much more than 73%” (pers comm, email available if required), even Dr Don Fletcher in Tribunal in the ACT in 2013 only went so far as to suggest a maximum birth rate of 55% per annum. At the time Dr Fletcher was a bit confused, as he referred to this as if he thought he was providing PGR (audio is available if required), but he stated “maximum growth rate, without mortality”. This figure corresponds quite closely with my own modelled maximum population growth rates of around 10% per annum, which does take into account c. 73% juvenile and other mortality.
Beyond incredible is the fact that despite the evidence of absolutely no capacity for high rates of population growth, that the extreme rates of increase reported by Payne 2013 (up to 249% in a single year) have been accepted by the Committee.
Further, given the extremely strong site attachment of the Eastern Grey Kangaroo (numerous papers, such as Viggers & Hearn 2005, Coulson (Anglesea) and Fletcher (radio tracking program in the ACT)), the “sedentary” nature of Western Grey Kangaroos (Priddel 1987) and Morgan & Peglers (2010) “there is likely to be little migration”, and the fact that no-one has ever suggested, much less reported, mass movements in populations of the Wallaroo (for example), the statement in the Committee’s letter:
“It is well established that numbers of large kangaroos fluctuate widely as a consequence of seasonal conditions (1), animal movements (2) and other factors (3)”
is inexplicable, other than to again give (1) Committee support for the OEH / Payne (2013) position (characterised by biologically impossible growth rates in the 2012 data set) suggesting population explosions in response to optimal seasonal conditions, and (2) to support Cairn’s statement suggesting movement of c. 200,000 kangaroos between the southern and northern sections of the Central Tablelands KMZ between 2008 and 2011. The Committee’s “other factors” (3) is a bit too vague and unscientific for me. Can the Committee please provide details of what “other factors” could be responsible for population growth rates of up to 249% per annum?
Of course Ms Payne is going to report massive increases in abundance – the OEH-KMU of which Ms Payne has been manager (until recently) is implicated by the nomination and the first supplementary submission in gross mismanagement and negligence. Ms Payne must be considered to have had a serious conflict of interest in forming any response or position statement for the OEH with regard to kangaroo management post-nomination, and yet her reported “increase”, instead of being treated with caution, is being referred to as critical evidence, on which the Committee is relying.
Directly comparable data exist for 0.4-0.6 of the 3 generation length, from 2001 to 2012 (Payne 2013). Over this time period these data appear to show a decline and then an increase in [kangaroo] abundance (Payne 2013).
The “increase” referred to by Payne was one subject discussed in the supplementary submission to the Committee, in which a maximum population growth rate of 249% was reported by Payne in an early release of their 2012 survey results. Will the Committee reject the nomination on the basis of this convenient and extremely favourable “evidence”, showing an improbable (biologically impossible) strong increase following the break of drought, which was provided by someone with a clear conflict of interest in maintaining the status quo? If so the Committee will be on the record as accepting that kangaroo populations can increase at this rate, while in fact breeding females produce a single young per annum. This is another scientifically untenable position.
A document such as Reassessing the spatial and temporal dynamics of kangaroo populations (Pople et al 2010) should have reset the understanding of kangaroos nationally, to allow more refined models for distribution to accurately provide up to date information on factors such as the various species’ extent of occupancy, for example.
It is alarming that this paper is instead seeking to come up with yet another indirect mechanism (NDVI) for the modelling of kangaroo populations, after increased rainfall following the break of drought did not result in even lagged super-abundant populations, as the researchers had rather optimistically expected would occur.
This fact of non-response in kangaroo populations following the break of drought (other than responses as a consequence of changing variables such as correction factors, or flying over national parks to fluff-up the numbers a bit) is simply a result of low reproductive rates for the species. Perhaps the researchers need to revisit the basics of kangaroo reproduction, for a possible alternative explanation of why kangaroos have not exploded across the landscape, following the break of the most recent drought.
Archer, Flannery and Grigg (1985) are on the record (note their position does not make reference to any source documents), stating what they considered to be a typical population growth rate for the species:
In good conditions an annual rate of increase of at least 25 per cent can be maintained.
While this rate of growth has never been actually measured in any detailed field studies, and while it is roughly double the maximum population growth rate that has been measured (eg: Arnold, Bilton & Croft etc), as well as being roughly double the modelled maximum growth rates (based on biological factors – see Mjadwesch 2011/2012), it is a long way shy of Payne’s 249% growth per annum.
The Committee, in publicly supporting Payne’s biologically impossible “data”, and the existing frameworks for management of the species (with harvest rates equalling or far exceeding potential growth rates for the species, under variable conditions) will be in serious danger of losing scientific credibility.
Archer et al (1985) continues:
Drought may cause precipitous falls in density…
The Committee should take the time to review the harvest model, which does not reduce harvest rates even during drought when populations crash (according to every paper ever written). This situation has been ongoing for 30 years, and the only logical conclusion must be that the populations have declined, which is demonstrated in the nomination using the departments own data.
These facts simply mean that heavily reduced populations will struggle to recover, particularly when many processes continue to operate against the survivors (including ongoing persecution, competition with stock for the little remaining feed and water, roads, fences, disease, catastrophe etc).
No-one, the Committee included, has attempted to contest the fact of low macropod reproductive rate to date. After initially stating that PGR could be “much more than 73%” (pers comm, email available if required), even Dr Don Fletcher in Tribunal in the ACT in 2013 only went so far as to suggest a maximum birth rate of 55% per annum. At the time Dr Fletcher was a bit confused, as he referred to this as if he thought he was providing PGR (audio is available if required), but he stated “maximum growth rate, without mortality”. This figure corresponds quite closely with my own modelled maximum population growth rates of around 10% per annum, which does take into account c. 73% juvenile and other mortality.
Beyond incredible is the fact that despite the evidence of absolutely no capacity for high rates of population growth, that the extreme rates of increase reported by Payne 2013 (up to 249% in a single year) have been accepted by the Committee.
Further, given the extremely strong site attachment of the Eastern Grey Kangaroo (numerous papers, such as Viggers & Hearn 2005, Coulson (Anglesea) and Fletcher (radio tracking program in the ACT)), the “sedentary” nature of Western Grey Kangaroos (Priddel 1987) and Morgan & Peglers (2010) “there is likely to be little migration”, and the fact that no-one has ever suggested, much less reported, mass movements in populations of the Wallaroo (for example), the statement in the Committee’s letter:
“It is well established that numbers of large kangaroos fluctuate widely as a consequence of seasonal conditions (1), animal movements (2) and other factors (3)”
is inexplicable, other than to again give (1) Committee support for the OEH / Payne (2013) position (characterised by biologically impossible growth rates in the 2012 data set) suggesting population explosions in response to optimal seasonal conditions, and (2) to support Cairn’s statement suggesting movement of c. 200,000 kangaroos between the southern and northern sections of the Central Tablelands KMZ between 2008 and 2011. The Committee’s “other factors” (3) is a bit too vague and unscientific for me. Can the Committee please provide details of what “other factors” could be responsible for population growth rates of up to 249% per annum?
Of course Ms Payne is going to report massive increases in abundance – the OEH-KMU of which Ms Payne has been manager (until recently) is implicated by the nomination and the first supplementary submission in gross mismanagement and negligence. Ms Payne must be considered to have had a serious conflict of interest in forming any response or position statement for the OEH with regard to kangaroo management post-nomination, and yet her reported “increase”, instead of being treated with caution, is being referred to as critical evidence, on which the Committee is relying.
Another "new" review
Wyperfeld NP is described by Morgan & Pegler (2006) as having “no water” prior to the advent of Europeans (obviously except for Wonga Lake), however despite “thousands” of wild dogs it was “swarming” with kangaroos when white man arrived. Settlement saw “heavy grazing” (20,000 sheep by the 1870s) and rabbit incursions, and subsequently, faced with “poor hunting” (farmers shot the kangaroos) and “the destruction of their wells by stock” (so much for the “no water” theory) the Wotjobaluk people “left” in the 1860s. “The Wonga Lake run itself was eventually in such poor condition that it was abandoned in 1880”.
Trapping and shooting of dingos has been ongoing in the region, however there is no evidence to suggest the “swarms” of kangaroos are returning. 4.5 kangaroos/ha (the maximum reported in 1994 according to Morgan & Peglers Figure 30.2) does not equate to a “swarm”, and by the time they started culling, the population was only 2 kangaroos / ha (see their Figure 30.5).
Further the floodplain has not flooded since 1917-18, as “thousands” of kilometres of channels have taken the water for irrigation. “The progressive death of older trees continues”.
Nonetheless Morgan & Pegler suggested that “kangaroo numbers seemed to become particularly high” (the 4/ha reported is “overabundant” according to the authors), and kangaroos were blamed for the poor recovery of the vegetation in landscapes still not recovered from 160 years of degradation as a consequence of overgrazing by stock animals.
A program of kangaroo monitoring and “management” was devised and implemented in the park:
This involved a culling program to substitute for the effects of natural predation and human hunting of former years.
Paradoxically the paper states “In addition to dingo predation, human hunting would have reduced the kangaroo population, but the likely scale of predation is again unknown”.
Consider again the earlier assertion in the paper: there were “swarms” of kangaroos when white settlers arrived. Clearly dingo predation and aboriginal hunting had not done much to “reduce” populations, however this seems to have been conveniently ignored (or forgotten) by the authors. It was destruction of water points and kangaroo persecution (resulting in poor hunting) which caused the original human inhabitants to “leave” their former hunting grounds.
In fact the paper states that “predation is no longer a factor; following near-complete removal of the dingo and the end of human hunting, the kangaroo population was effectively without predators”.
Curiously the paper makes no mention of foxes, and fails to consider fox predation. Are there really no foxes at Wyperfeld, or was this just a gross oversight on behalf of these researchers? For the Committee’s information foxes occur across the mainland, apart from the tropical north, including in Wyperfeld NP and probably abundantly across Victoria, despite Victoria’s seeming paucity of records lodged with the Atlas of Living Australia (figure below).
Trapping and shooting of dingos has been ongoing in the region, however there is no evidence to suggest the “swarms” of kangaroos are returning. 4.5 kangaroos/ha (the maximum reported in 1994 according to Morgan & Peglers Figure 30.2) does not equate to a “swarm”, and by the time they started culling, the population was only 2 kangaroos / ha (see their Figure 30.5).
Further the floodplain has not flooded since 1917-18, as “thousands” of kilometres of channels have taken the water for irrigation. “The progressive death of older trees continues”.
Nonetheless Morgan & Pegler suggested that “kangaroo numbers seemed to become particularly high” (the 4/ha reported is “overabundant” according to the authors), and kangaroos were blamed for the poor recovery of the vegetation in landscapes still not recovered from 160 years of degradation as a consequence of overgrazing by stock animals.
A program of kangaroo monitoring and “management” was devised and implemented in the park:
This involved a culling program to substitute for the effects of natural predation and human hunting of former years.
Paradoxically the paper states “In addition to dingo predation, human hunting would have reduced the kangaroo population, but the likely scale of predation is again unknown”.
Consider again the earlier assertion in the paper: there were “swarms” of kangaroos when white settlers arrived. Clearly dingo predation and aboriginal hunting had not done much to “reduce” populations, however this seems to have been conveniently ignored (or forgotten) by the authors. It was destruction of water points and kangaroo persecution (resulting in poor hunting) which caused the original human inhabitants to “leave” their former hunting grounds.
In fact the paper states that “predation is no longer a factor; following near-complete removal of the dingo and the end of human hunting, the kangaroo population was effectively without predators”.
Curiously the paper makes no mention of foxes, and fails to consider fox predation. Are there really no foxes at Wyperfeld, or was this just a gross oversight on behalf of these researchers? For the Committee’s information foxes occur across the mainland, apart from the tropical north, including in Wyperfeld NP and probably abundantly across Victoria, despite Victoria’s seeming paucity of records lodged with the Atlas of Living Australia (figure below).
Morgan & Pegler describe their surveys using a line transect methodology, however the increase between 1992 and 1993 (from 21/km2 to 45/km2, or a 114% increase) is a biological impossibility, casting doubt on the veracity of the survey methodology and resultant data. Nonetheless and despite the non-questioning approach taken to the data itself (many kangaroo researchers do actually seem to believe that kangaroo populations can increase at rates of up to and exceeding 100% per annum), the authors then used this data to calculate annual population growth rates, which after being correlated to rainfall, informed their calculations of the numbers that needed to be shot every year.
After shooting kangaroos for 8 years (the actual numbers shot are not provided in the paper), they reviewed the program in 2006. You can see what happened (their figure 30.5): the population crashed. The “researchers” ponder the situation: “One possible explanation of the discrepancy lies in setting too high a cull target as a result of over-estimating the number of kangaroos using adjacent mallee as shelter”. Or perhaps using virtual populations and predicting growth based on biologically impossible population growth rates was not a sound basis on which to calculate the numbers to shoot? Or maybe changing their survey methodology halfway through somehow provided invalid data?
Reproductive/population growth rates are in actual fact a lot lower than the researchers understand the case to be, and the cause of decline is not so difficult to understand if one considers the biological capacity of the species to produce and raise their young, instead of basing numbers to shoot on rainfall (itself a highly variable parameter from one year to the next) and an “arbitrary” target density based on half of observed “natural” densities, plus an unspecified number of “extra” kangaroos which the researchers suggested would come in from the nearby mallee (despite their statement “there is likely to be little migration”).
The program is a success apparently. Since enacting the shooting program instead of a possible “mass starvation”, there has been mass-slaughter instead. Even though in 2006 it looks like the program had already reduced densities from 20 kangaroos / km2 to only 4 kangaroos / km2, to reduce the risk of possible high grazing impacts in the future, the plan was to increase the proportion of animals shot during years of declining rainfall.
In my view it was extremely dishonest of these researchers to suggest their program was a “predator simulation”. In the first place, no natural predator would cause the crash shown in Morgan & Pegler’s Figure 30.5. In the second place setting “arbitrary” targets based on virtual models is pseudo-scientific, as predator populations respond (follow) simple abundance in their prey species, while even as the population crashed the shooting continued regardless. In the third place, the researchers themselves operated as predators, there was nothing simulated about it.
After shooting kangaroos for 8 years (the actual numbers shot are not provided in the paper), they reviewed the program in 2006. You can see what happened (their figure 30.5): the population crashed. The “researchers” ponder the situation: “One possible explanation of the discrepancy lies in setting too high a cull target as a result of over-estimating the number of kangaroos using adjacent mallee as shelter”. Or perhaps using virtual populations and predicting growth based on biologically impossible population growth rates was not a sound basis on which to calculate the numbers to shoot? Or maybe changing their survey methodology halfway through somehow provided invalid data?
Reproductive/population growth rates are in actual fact a lot lower than the researchers understand the case to be, and the cause of decline is not so difficult to understand if one considers the biological capacity of the species to produce and raise their young, instead of basing numbers to shoot on rainfall (itself a highly variable parameter from one year to the next) and an “arbitrary” target density based on half of observed “natural” densities, plus an unspecified number of “extra” kangaroos which the researchers suggested would come in from the nearby mallee (despite their statement “there is likely to be little migration”).
The program is a success apparently. Since enacting the shooting program instead of a possible “mass starvation”, there has been mass-slaughter instead. Even though in 2006 it looks like the program had already reduced densities from 20 kangaroos / km2 to only 4 kangaroos / km2, to reduce the risk of possible high grazing impacts in the future, the plan was to increase the proportion of animals shot during years of declining rainfall.
In my view it was extremely dishonest of these researchers to suggest their program was a “predator simulation”. In the first place, no natural predator would cause the crash shown in Morgan & Pegler’s Figure 30.5. In the second place setting “arbitrary” targets based on virtual models is pseudo-scientific, as predator populations respond (follow) simple abundance in their prey species, while even as the population crashed the shooting continued regardless. In the third place, the researchers themselves operated as predators, there was nothing simulated about it.
A conservation parable
Box-Gum Woodlands are listed as an Endangered Ecological Community in NSW, the community is listed as Critically Endangered nationally, on account of farming and agriculture having removed / modified a significant proportion of the community (>95%).
Box-Gum Woodland continues to occur across its former range (with a massive AOE), albeit in fragmented and often heavily modified forms. The listing was made on the basis of the remnants which remain often being small and degraded (a bit like the remaining kangaroo populations), and subject to continuing erosion, both in terms of size and structural integrity (a bit like the remaining kangaroo populations).
Literally thousands or even tens of thousands of box-gum woodland remnants remain, nonetheless Box-Gum Woodlands are recognised as endangered, even critically endangered according to the federal listing. Interestingly a species which formerly favoured Box-Gum Woodland, the Eastern Grey Kangaroo, is now absent from the vast majority of the remnants which remain (for example see Mjadwesch 2007, being a technical report describing systematic vegetation surveys of woodland remnants from Goulburn to Gulgong). This suggests that kangaroos have declined and even disappeared even out of this endangered ecological community in many instances, across much of its distribution. Kangaroo populations in an intact state (large mobs numbering hundreds of animals) are today rarer than the critically endangered ecological community they once inhabited.
If only the Committee would take the same approach to assessment of the status of the large macropods as they have to the communities / habitats they formerly occupied, there would be some hope for the longer term conservation of the species. If not it will be up to someone else to re-nominate the species some time down the track, by which time things will be even worse.
Box-Gum Woodland continues to occur across its former range (with a massive AOE), albeit in fragmented and often heavily modified forms. The listing was made on the basis of the remnants which remain often being small and degraded (a bit like the remaining kangaroo populations), and subject to continuing erosion, both in terms of size and structural integrity (a bit like the remaining kangaroo populations).
Literally thousands or even tens of thousands of box-gum woodland remnants remain, nonetheless Box-Gum Woodlands are recognised as endangered, even critically endangered according to the federal listing. Interestingly a species which formerly favoured Box-Gum Woodland, the Eastern Grey Kangaroo, is now absent from the vast majority of the remnants which remain (for example see Mjadwesch 2007, being a technical report describing systematic vegetation surveys of woodland remnants from Goulburn to Gulgong). This suggests that kangaroos have declined and even disappeared even out of this endangered ecological community in many instances, across much of its distribution. Kangaroo populations in an intact state (large mobs numbering hundreds of animals) are today rarer than the critically endangered ecological community they once inhabited.
If only the Committee would take the same approach to assessment of the status of the large macropods as they have to the communities / habitats they formerly occupied, there would be some hope for the longer term conservation of the species. If not it will be up to someone else to re-nominate the species some time down the track, by which time things will be even worse.
Repetition of Refuted Theories
The Committee prefers (and states) that:
The addition of water points for domestic stock and the suppression of dingoes is also likely to have increased the carrying capacity of western NSW for [kangaroos] (Olsen & Braysher 2000; Letnic & Crowther 2013); with the NSW sheep rangelands now supporting the highest densities of [Red Kangaroos] in Australia (Van Dyck & Strahan 2008).
The Committee re-stating these points as if this is the last word, when these points have been refuted in the original nomination, is frustrating, to say the least.
Additional water points having made things better for kangaroos is simply not true. Montague-Drake 2004 shows that kangaroo distribution is not related to location of water points. Degradation of pre-existing water points, competition with stock, and aggressive persecution of kangaroos coming to water points have clearly made things much worse for kangaroos (see pages 110-114 of the nomination). I often see dams dotted across the landscape, but no kangaroos – try going for a drive some time and open your eyes - simply building dams everywhere does not cause the spontaneous generation of kangaroos.
With regard to dingo suppression, let’s talk about foxes and predation, again. Banks (2000) shows 50% of joeys are killed by foxes, contributing significantly to juvenile mortality which typically runs to around 73%.
Several additional papers discuss fox predation as well. Short & Kinnear (2002) discusses the phenomenon of “surplus killing” in Australian carnivores, and the examples are striking. Foxes surplus-kill native animals; dingo’s surplus kill stock animals. The conclusion made in this CSIRO paper is that this occurs because of ineffective anti-predator behaviour when animals are faced with a “novel and efficient” predator.
With regard to dingoes regulating macropod numbers, Morgan & Pegler’s’ statement that thousands of dingoes co-existed historically with swarms of kangaroos is supported by Short & Kinnear’s’ thoughts on the dingoes’ impact on macropod numbers in pre-settlement conditions:
Active persecution of non-commensal dingoes by Aborigines, the lack of free-water, and the absence of European rabbits as an alternative food supply would have limited their numbers and their impact on native mammals.
Further Hornsby (1982) clearly shows (with photos) and describes a fox killing a young Wallaroo, which it then did not eat, demonstrating 3 things; the fox’s capacity to kill large prey, the poor defensive capacity of a macropod, and the fox’s approach to ensuring they can have a feed “later” (it did not need to be hungry to make the kill, this is “surplus killing”).
It is quite astonishing that the Committee, with an expert such as Dr Eldridge to advise them, should again regurgitate a nonsense theory such as the “no Aboriginal hunting and no dingo predation has led to increased macropod numbers” hypothesis.
Clearly kangaroos continue to be subject to predation from foxes, which occur in great abundance across the continent, so the Committee’s statement suggesting that control of dingoes has made everything fantastic for kangaroos (no predation) is simply not correct. Indeed the research suggests that foxes are more efficient predators of kangaroos than are dingoes.
Incredibly I do not notice throughout the Committee’s preliminary response to the nomination any mention of Banks (2000), or fox predation either generally or specifically, despite it being featured in the nomination. The Committee in this sense could stand accused of cherry picking its favourite theories and authors in support of the idea that kangaroos are more numerous today than they ever have been. This is a fantastic example of confirmation bias in action, where easily found and directly pertinent reference material has been ignored or omitted from the Committee’s considerations, in favour of theories which support the position of the industry, which has influenced public (and scientific) perceptions through strategic and long-running media campaigns and “research” programs.
Further I consider that unceasing and even escalating shooting for over 200 years will also have served effectively as a “predator” function, indeed this must far outweigh the pressure that dingoes and Aboriginal hunting previously exerted on kangaroo populations. “Professional” shooting, both the historic roo-shooter and the contemporary kangaroo harvester, could be seen as super-predation, with high mobility and a long range (4x4 vehicles), super capacity (mobile killing units and chiller boxes) and extreme lethality (high powered and repeating rifles used with spotlights).
In Jackson & Vernes (2010) Professor Johnson “concluded that overhunting was indeed the most likely cause of the megafaunal extinctions”; Professor Flannery is given as calling it a “blitzkrieg”, with “massive overhunting” (ie: by at most a few tens-of-thousands of Aborigines with spears).
But when someone suggests the large macropods are at risk principally on account of the scale of slaughter escalating with arrival of Europeans and guns in Australia (and massive habitat loss), instead of arguments being considered on their merits, these views are casually discounted as “misguided concerns” (Jackson & Vernes 2010 page 172).
With regard to the Eastern Grey Kangaroo, from the Committee’s letter (page 13):
…large areas have also been converted from forest and woodland to more open and grassy habitats which are highly favoured by Eastern Grey Kangaroos.
This is also untrue – please refer back to Archer et al (1985) which describes the habitat for this species (open forests and woodlands), and even the Committee’s own letter (which accepts there has been loss of habitat in coastal and tablelands regions). Indeed and specifically Archer et al (1985) only suggests that clearing has made things better for Red Kangaroos. It is unclear how this “clearing has made things better” nice sounding but ultimately untrue theory has been conflated to include all of the large macropods in recent years.
The situations in Tasmania (clearing and hunting reduced populations by 90% by the 1970’s) and Victoria (intensive cropping across 85% of the state reduced EGK populations to <1 kangaroo/km) are clear. The Committee members have been misled or are themselves in error with regard to the theory that conversion of forest and woodland to more open and grassy habitats has made things better for the Eastern Grey Kangaroo (or the other species subject to the nomination, for that matter).
The addition of water points for domestic stock and the suppression of dingoes is also likely to have increased the carrying capacity of western NSW for [kangaroos] (Olsen & Braysher 2000; Letnic & Crowther 2013); with the NSW sheep rangelands now supporting the highest densities of [Red Kangaroos] in Australia (Van Dyck & Strahan 2008).
The Committee re-stating these points as if this is the last word, when these points have been refuted in the original nomination, is frustrating, to say the least.
Additional water points having made things better for kangaroos is simply not true. Montague-Drake 2004 shows that kangaroo distribution is not related to location of water points. Degradation of pre-existing water points, competition with stock, and aggressive persecution of kangaroos coming to water points have clearly made things much worse for kangaroos (see pages 110-114 of the nomination). I often see dams dotted across the landscape, but no kangaroos – try going for a drive some time and open your eyes - simply building dams everywhere does not cause the spontaneous generation of kangaroos.
With regard to dingo suppression, let’s talk about foxes and predation, again. Banks (2000) shows 50% of joeys are killed by foxes, contributing significantly to juvenile mortality which typically runs to around 73%.
Several additional papers discuss fox predation as well. Short & Kinnear (2002) discusses the phenomenon of “surplus killing” in Australian carnivores, and the examples are striking. Foxes surplus-kill native animals; dingo’s surplus kill stock animals. The conclusion made in this CSIRO paper is that this occurs because of ineffective anti-predator behaviour when animals are faced with a “novel and efficient” predator.
With regard to dingoes regulating macropod numbers, Morgan & Pegler’s’ statement that thousands of dingoes co-existed historically with swarms of kangaroos is supported by Short & Kinnear’s’ thoughts on the dingoes’ impact on macropod numbers in pre-settlement conditions:
Active persecution of non-commensal dingoes by Aborigines, the lack of free-water, and the absence of European rabbits as an alternative food supply would have limited their numbers and their impact on native mammals.
Further Hornsby (1982) clearly shows (with photos) and describes a fox killing a young Wallaroo, which it then did not eat, demonstrating 3 things; the fox’s capacity to kill large prey, the poor defensive capacity of a macropod, and the fox’s approach to ensuring they can have a feed “later” (it did not need to be hungry to make the kill, this is “surplus killing”).
It is quite astonishing that the Committee, with an expert such as Dr Eldridge to advise them, should again regurgitate a nonsense theory such as the “no Aboriginal hunting and no dingo predation has led to increased macropod numbers” hypothesis.
Clearly kangaroos continue to be subject to predation from foxes, which occur in great abundance across the continent, so the Committee’s statement suggesting that control of dingoes has made everything fantastic for kangaroos (no predation) is simply not correct. Indeed the research suggests that foxes are more efficient predators of kangaroos than are dingoes.
Incredibly I do not notice throughout the Committee’s preliminary response to the nomination any mention of Banks (2000), or fox predation either generally or specifically, despite it being featured in the nomination. The Committee in this sense could stand accused of cherry picking its favourite theories and authors in support of the idea that kangaroos are more numerous today than they ever have been. This is a fantastic example of confirmation bias in action, where easily found and directly pertinent reference material has been ignored or omitted from the Committee’s considerations, in favour of theories which support the position of the industry, which has influenced public (and scientific) perceptions through strategic and long-running media campaigns and “research” programs.
Further I consider that unceasing and even escalating shooting for over 200 years will also have served effectively as a “predator” function, indeed this must far outweigh the pressure that dingoes and Aboriginal hunting previously exerted on kangaroo populations. “Professional” shooting, both the historic roo-shooter and the contemporary kangaroo harvester, could be seen as super-predation, with high mobility and a long range (4x4 vehicles), super capacity (mobile killing units and chiller boxes) and extreme lethality (high powered and repeating rifles used with spotlights).
In Jackson & Vernes (2010) Professor Johnson “concluded that overhunting was indeed the most likely cause of the megafaunal extinctions”; Professor Flannery is given as calling it a “blitzkrieg”, with “massive overhunting” (ie: by at most a few tens-of-thousands of Aborigines with spears).
But when someone suggests the large macropods are at risk principally on account of the scale of slaughter escalating with arrival of Europeans and guns in Australia (and massive habitat loss), instead of arguments being considered on their merits, these views are casually discounted as “misguided concerns” (Jackson & Vernes 2010 page 172).
With regard to the Eastern Grey Kangaroo, from the Committee’s letter (page 13):
…large areas have also been converted from forest and woodland to more open and grassy habitats which are highly favoured by Eastern Grey Kangaroos.
This is also untrue – please refer back to Archer et al (1985) which describes the habitat for this species (open forests and woodlands), and even the Committee’s own letter (which accepts there has been loss of habitat in coastal and tablelands regions). Indeed and specifically Archer et al (1985) only suggests that clearing has made things better for Red Kangaroos. It is unclear how this “clearing has made things better” nice sounding but ultimately untrue theory has been conflated to include all of the large macropods in recent years.
The situations in Tasmania (clearing and hunting reduced populations by 90% by the 1970’s) and Victoria (intensive cropping across 85% of the state reduced EGK populations to <1 kangaroo/km) are clear. The Committee members have been misled or are themselves in error with regard to the theory that conversion of forest and woodland to more open and grassy habitats has made things better for the Eastern Grey Kangaroo (or the other species subject to the nomination, for that matter).
The Central Tablelands – What Scientific Merit?
From the Committee's letter:
Some habitat, especially in the coastal zone and tablelands, has been lost to cropping, urbanisation and other infrastructure.
For the first time in the literature, the NSW Scientific Committee has here acknowledged that there have indeed been impacts on the Eastern Grey Kangaroo, and its habitat, in the tablelands!
Nonetheless commercial shooting occurs in the tablelands, and the position of the OEH and their consultants in authorising and facilitating this (notably Cairns 2009 and 2012 CT reports, and Cairns’ reports on the Northern Tablelands) is based on the belief that there are more kangaroos than there were before Europeans came along and “improved” habitat for kangaroos.
Cairns (2012) has been discussed previously; something of the deficiencies in Cairns reports which were detailed in the supplement to the nomination are summarised here.
All three of these process errors will have resulted in compounding positive bias in the population estimates. Cairns’ calculations of the total Eastern Grey Kangaroo population for the Central Tablelands in 2012, based on these incorrectly mapped and wrongly applied methodologies, were provided as:
CT-North: 612,509
CT-South: 347,830
These figures indicate a 13% increase in the Eastern Grey Kangaroo population per annum in the northern zone over the 3 years since the last survey. In the southern zone Eastern Grey Kangaroos are given to have declined by 34% over the 3 years since last survey.
Given the numbers shot in the northern zone during this period (Table below), and maximum growth rates of only 9% having been measured in detailed field studies, consistent growth at 13% per annum seems improbable to say the least.
With regard to possible decline, instead of any concern about a dramatic reduction in the numbers in the southern zone during a period when conditions were optimal (following the break of drought) and populations should have been increasing (according to the scientists), Cairns instead casually posits that some 200K kangaroos had moved north, crudely attempting to level out the big plus in the northern sub-zone with the big minus in the southern sub-zone.
Some habitat, especially in the coastal zone and tablelands, has been lost to cropping, urbanisation and other infrastructure.
For the first time in the literature, the NSW Scientific Committee has here acknowledged that there have indeed been impacts on the Eastern Grey Kangaroo, and its habitat, in the tablelands!
Nonetheless commercial shooting occurs in the tablelands, and the position of the OEH and their consultants in authorising and facilitating this (notably Cairns 2009 and 2012 CT reports, and Cairns’ reports on the Northern Tablelands) is based on the belief that there are more kangaroos than there were before Europeans came along and “improved” habitat for kangaroos.
Cairns (2012) has been discussed previously; something of the deficiencies in Cairns reports which were detailed in the supplement to the nomination are summarised here.
- Cairns maps extensive sections of escarpment and sandstone habitats as “medium” density areas, even though these habitats do not have any kangaroos at all, and even Cairns did not bother to survey the designated transects. He went on to calculate “medium” densities for the areas based on counting kangaroos where they do occur (in national parks and state forests across the KMZ), then applied those densities to uninhabited areas in order to “calculate” a total population for the KMZ (briefly discussed in the first supplement to the nomination on page 16, Mjadwesch 2012).
- Cairns’ maps of “high” and “medium” density habitats do not in any way reflect the actual densities of kangaroos observed (as per the transect data records). Huge regions have extremely low densities (<10 observed along 10km transects), and local extinctions have also already occurred (see below), but they are not mapped as such. For example the Bathurst Basin is mapped as “high” density habitat on account of being a highly fertile and productive landscape, even though most of the Bathurst plains are completely devoid of kangaroos (Bathurst Eastern Grey Kangaroo density distribution was illustrated as Attachment 1 in the first supplement to the nomination, Mjadwesch 2012).
- Cairns states on page 13 of his 2012 report that the surveys did not overfly any national parks or state forests, however nearly half of his transects did sample from these non-shooting areas. Animals counted in these areas were then used to calculate densities which were applied to the surrounding farming (shooting) landscapes (discussed on pages 57-59 of the first supplement to the nomination) and non-habitat areas (discussed above).
All three of these process errors will have resulted in compounding positive bias in the population estimates. Cairns’ calculations of the total Eastern Grey Kangaroo population for the Central Tablelands in 2012, based on these incorrectly mapped and wrongly applied methodologies, were provided as:
CT-North: 612,509
CT-South: 347,830
These figures indicate a 13% increase in the Eastern Grey Kangaroo population per annum in the northern zone over the 3 years since the last survey. In the southern zone Eastern Grey Kangaroos are given to have declined by 34% over the 3 years since last survey.
Given the numbers shot in the northern zone during this period (Table below), and maximum growth rates of only 9% having been measured in detailed field studies, consistent growth at 13% per annum seems improbable to say the least.
With regard to possible decline, instead of any concern about a dramatic reduction in the numbers in the southern zone during a period when conditions were optimal (following the break of drought) and populations should have been increasing (according to the scientists), Cairns instead casually posits that some 200K kangaroos had moved north, crudely attempting to level out the big plus in the northern sub-zone with the big minus in the southern sub-zone.
Notice that this data is another example of a failing harvest model, where the crash will be based on over-inflated initial population estimates, over-allocation based on this over-estimation, and harvest rates exceeding population growth rates for the species.
Year 1: Build capacity, establish networks
Year 2: Exploit resource
Year 3: Exploit resource
Year 4: Exploit resource (decline is already apparent in take)
Year 5: Exploit resource (decline in take continues)
What will happen next - suspension of the harvest once densities fall below “critical” thresholds?
Alarmingly in 2011 Cairns found more kangaroos than he did in 2008 across the KMZ (by surveying more national parks, see the first supplement to the nomination, pages 57-59), and the quota was increased. With surveys only once every 3 years, a reprieve for the kangaroos in the Central Tablelands KMZ is a long way off (14 more months of shooting). The sad situation of Wallaroos in the NT KMZ seems to be repeating itself, where triennial survey is completely unable to detect decline before it is too late.
This all follows exactly the same path as what the data shows has occurred in harvest zones across NSW and South Australia (growth as industry builds capacity, peak production, then collapse in take as the resource is over-exploited). I have not yet processed all of the QLD and WA data that I have, but a pattern is definitely developing.
Year 1: Build capacity, establish networks
Year 2: Exploit resource
Year 3: Exploit resource
Year 4: Exploit resource (decline is already apparent in take)
Year 5: Exploit resource (decline in take continues)
What will happen next - suspension of the harvest once densities fall below “critical” thresholds?
Alarmingly in 2011 Cairns found more kangaroos than he did in 2008 across the KMZ (by surveying more national parks, see the first supplement to the nomination, pages 57-59), and the quota was increased. With surveys only once every 3 years, a reprieve for the kangaroos in the Central Tablelands KMZ is a long way off (14 more months of shooting). The sad situation of Wallaroos in the NT KMZ seems to be repeating itself, where triennial survey is completely unable to detect decline before it is too late.
This all follows exactly the same path as what the data shows has occurred in harvest zones across NSW and South Australia (growth as industry builds capacity, peak production, then collapse in take as the resource is over-exploited). I have not yet processed all of the QLD and WA data that I have, but a pattern is definitely developing.
What is the point of having two sub-zones in this KMZ, if researchers just bundle their results anyway, in an attempt to explain improbably high rates of growth and apparent decline in adjacent regions? Please remember that studies have shown the species to be site attached / sedentary (Viggers & Hearn 2005, Fletcher and Coulson radio-tracking programs, and numerous “home range” studies for all species, by researchers including Croft, Walters, etc (having a home range means the species is non-migratory / sedentary)). Nonetheless the Committee has stated its preference for the “large fluctuation” theory, which has no actual basis in evidence, even if written about widely by the pro-shooting sector of the kangaroo research industry.
On this basis a 15% quota means that the OEH are permitting the shooting of 144,000 kangaroo per annum in the region, for the period 2012-2014. The question must be asked, if this shooting program satisfies any proper and rigorous scientific consideration and analysis of the situation in the Central Tablelands, given that the Committee have stated that they consider that human impact has affected kangaroos (via loss of habitat) in the region?
I have not done any science here, I am simply conducting an independent and professional review of the existing “science” (I am a practicing consulting ecologist, specialising in wildlife survey and management). In the case of Cairns’ work, there is considerable concern about the lack of scientific merit. The expectation is that the Scientific Committee should be doing the same, instead of stating a business-as-usual and partisan approach to supporting the roo-meat industry, at the expense of Australian wildlife. It is neither correct nor appropriate, as a scientist, to say you did not conduct surveys over national parks and state forests, but to have actually done exactly that, then use those animals to calculate densities which are then applied to surrounding farmland, where often very few or no kangaroos were observed.
The situation is the same in western NSW, where 7% of survey transects sample from national parks and forest reserves (pers comm Nicole Payne), as well as in SA and Queensland. Industry focused scientists have performed the same trick in all of the harvest jurisdictions I have reviewed to date.
On this basis a 15% quota means that the OEH are permitting the shooting of 144,000 kangaroo per annum in the region, for the period 2012-2014. The question must be asked, if this shooting program satisfies any proper and rigorous scientific consideration and analysis of the situation in the Central Tablelands, given that the Committee have stated that they consider that human impact has affected kangaroos (via loss of habitat) in the region?
I have not done any science here, I am simply conducting an independent and professional review of the existing “science” (I am a practicing consulting ecologist, specialising in wildlife survey and management). In the case of Cairns’ work, there is considerable concern about the lack of scientific merit. The expectation is that the Scientific Committee should be doing the same, instead of stating a business-as-usual and partisan approach to supporting the roo-meat industry, at the expense of Australian wildlife. It is neither correct nor appropriate, as a scientist, to say you did not conduct surveys over national parks and state forests, but to have actually done exactly that, then use those animals to calculate densities which are then applied to surrounding farmland, where often very few or no kangaroos were observed.
The situation is the same in western NSW, where 7% of survey transects sample from national parks and forest reserves (pers comm Nicole Payne), as well as in SA and Queensland. Industry focused scientists have performed the same trick in all of the harvest jurisdictions I have reviewed to date.
A new analysis
Cairns used his data to generate population estimates. I don’t know how permissible it is, but given low counts seem to form clusters, I have used Cairns’ data for the Central Tablelands to create a density distribution map (see below). Based on a fairly rudimentary calculation (assuming that all of the non-white/occupied habitats would have been mapped as “green” 200 years ago) I estimate the magnitude of decline in terms of simple abundance since European settlement to be in the order of 82.5% across the KMZ.
This figure assumes a few things.
Queensland’s DERM considers that helicopter survey is “accurate and precise”, and the OEH and Cairns consider that they are very good at counting kangaroos and differentiating species using this methodology. These factors taken together suggest that the range of numbers reported by Cairns (from 0-200 kangaroos along c. 10km long transects, spread spatially across the region, and sampling all land systems) probably represent something of the gradation between “extinct” (no kangaroos observed) to “normal” densities (maximum of c. 200 counted at Goulburn River NP).
The model produced at least corresponds with the NSW Scientific Committee's view that there have in fact been impacts on kangaroos and their habitat in the tablelands, and with readily observable low-density and locally extinct situations across the region.
Queensland’s DERM considers that helicopter survey is “accurate and precise”, and the OEH and Cairns consider that they are very good at counting kangaroos and differentiating species using this methodology. These factors taken together suggest that the range of numbers reported by Cairns (from 0-200 kangaroos along c. 10km long transects, spread spatially across the region, and sampling all land systems) probably represent something of the gradation between “extinct” (no kangaroos observed) to “normal” densities (maximum of c. 200 counted at Goulburn River NP).
The model produced at least corresponds with the NSW Scientific Committee's view that there have in fact been impacts on kangaroos and their habitat in the tablelands, and with readily observable low-density and locally extinct situations across the region.
The Wallaroo in the Central Tablelands KMZ
When I made the density distribution map below, and again reviewed Cairns (2009), I finally understood why so many extra transects targeted non-shooting areas (national parks and reserves, and state forests) during survey in the Central Tablelands in 2011 (Cairns 2012).
So few Wallaroos were observed in 2008 (yellow numerals - click to magnify above image) that Cairns was not even able to make a population estimate for the species in either the Central Tablelands or the SE KMZs (discussed in Cairns (2009) on page 23). This incontrovertible decline has occurred even without commercial shooting of the species in these regions, just as a consequence of habitat loss, persecution via the “damage mitigation” process and illegal shooting, and through processes such as roadkill, incidental deaths in fences, fox predation etc.
Incredibly even with the inclusion of many more transects targeting conservation and other non-shooting areas in 2011 (white numerals), vast landscapes still returned zero counts. The species appears to be pretty well extinct across most of the western half of the KMZ.
There is one final “new” issue with regard to Cairns I have noticed, which again brings into question the merit of the Cairns/UNE survey work in the Central Tablelands (and elsewhere). KMZs are stratified into “high”, “medium” and “low” density stratum, which are used to calculate populations of two species, the Eastern Grey Kangaroo and the Wallaroo.
The Committee will not find any argument that these two species actually occupy different habitats (with a degree of overlap), so it defies understanding that reports purporting to be expert should calculate populations for two dissimilar species, based on the same maps/habitat stratifications.
Competent scientific modelling of “high”, “medium” and “low” density habitats to be used to estimate populations should surely be different for each species? The lack of precision sought by the department (Nicole Payne), and the failure on behalf of Cairns/UNE to deliver reports and analysis which stand up to independent scrutiny speaks volumes about the level of complacency in the kangaroo “management” sector.
Given these examples from the Central Tablelands (the only region for which I have been so far able to obtain data from the department), can we imagine that Wallaroos (or the other species) are doing as fantastically as the Department tells us they are doing elsewhere across NSW?
What qualified and competent oversight has there been of the surveys? Given the difficulty I am experiencing in gaining access to the data and details of survey for western NSW, I can only surmise that the department are seeking to conceal more of the same.
Incredibly even with the inclusion of many more transects targeting conservation and other non-shooting areas in 2011 (white numerals), vast landscapes still returned zero counts. The species appears to be pretty well extinct across most of the western half of the KMZ.
There is one final “new” issue with regard to Cairns I have noticed, which again brings into question the merit of the Cairns/UNE survey work in the Central Tablelands (and elsewhere). KMZs are stratified into “high”, “medium” and “low” density stratum, which are used to calculate populations of two species, the Eastern Grey Kangaroo and the Wallaroo.
The Committee will not find any argument that these two species actually occupy different habitats (with a degree of overlap), so it defies understanding that reports purporting to be expert should calculate populations for two dissimilar species, based on the same maps/habitat stratifications.
Competent scientific modelling of “high”, “medium” and “low” density habitats to be used to estimate populations should surely be different for each species? The lack of precision sought by the department (Nicole Payne), and the failure on behalf of Cairns/UNE to deliver reports and analysis which stand up to independent scrutiny speaks volumes about the level of complacency in the kangaroo “management” sector.
Given these examples from the Central Tablelands (the only region for which I have been so far able to obtain data from the department), can we imagine that Wallaroos (or the other species) are doing as fantastically as the Department tells us they are doing elsewhere across NSW?
What qualified and competent oversight has there been of the surveys? Given the difficulty I am experiencing in gaining access to the data and details of survey for western NSW, I can only surmise that the department are seeking to conceal more of the same.
Slowly changing mindsets
For the first time ever on August 13th 2013 the OEH made a statement suggesting that perhaps kangaroos may not be doing so well after all
It is easy to believe that common native animals like kangaroos, brush-tailed possums, lyrebirds and wombats will always be around. However, these animals are as vulnerable as threatened species are to changes in the environment (http://www.environment.nsw.gov.au/animals/wildcount.htm).
Victoria’s reported 85% of the state having <1 kangaroo/km2 in 1982 (according to Short and Grigg) and Tasmania’s 90% decline in the Forester by the 1970s suddenly seems to make sense in the context of what has happened in NSW. However the Committee has stated instead:
There have been changes to the habitat quality for [Eastern Grey Kangaroos] in NSW since European settlement (reviewed in Calaby & Grigg 1989; Olsen & Braysher 2000). Some habitat, especially in the coastal zone and tablelands, has been lost to cropping, urbanisation and other infrastructure. However large areas have also been converted from forest and woodland to more open and grassy habitats which are highly favoured by [Eastern Grey Kangaroos].
We’ll leave Calaby & Grigg aside, a paper discussing kangaroos from over 20 years ago, as it has little relevance today after such a long period of continued and increasingly intensive shooting. With regard to Olsen & Braysher (and most recently the Committee itself) regurgitating this idea, has the Committee actually gone and had a look through the harvest zones of NSW in order to come to a position supporting this conclusion? Perhaps the Committee assumes my personal observations and experience has been limited to “the tablelands”.
My offer of a few days touring NSW to discuss the issue remains open – my understanding is that the Committee’s trip to the Newnes Plateau in 2004 was pivotal in making the determination listing longwall mining subsidence as a KTP, yet here we have a similar situation where independent research is challenging the establishment (entrenched mindsets of managers, and scientists supporting an industry sector).
Multi-regional declines and local extinctions are fact, while researchers misrepresent the situation with regard to kangaroo ecology and the history of their management and provide scientifically unsupported and misleading testimony and invalid survey “results” in support of the multi-million dollar commercial roo-meat industry.
It is a nice theory if you want to pitch the idea that there are more kangaroos than there ever were - that clearing forests makes habitat for kangaroos - but where is the science? Has anyone ever actually tested this theory according to accepted scientific method? Yes they have.
Montague-Drake & Croft (2004) showed that kangaroo distribution is directly related to presence of cover in combination with grazing opportunities - the Committee referring to Calaby & Grigg 1989 and Olsen & Braysher 2000 without referring to papers which actually quantify factors affecting kangaroo distribution is “cherry picking” and unscientific. Arnold (1995) is another paper that correlated macropod occurrence with the persistence of remnant vegetation - in fact they conducted kangaroo surveys to maximise detection by actively targeting remnant units.
The historic colloquial names “The Forester” and “Scrub Kangaroo” (in the case of the Eastern Grey Kangaroo) gives us a clue too about the preferred habitat for this species. The Committee’s position on this (clearing has made things better) is also at odds with findings in Tasmania (clearing and hunting led to 90% decline) and Short and Grigg’s (1982) conclusions about how clearing for agriculture affected kangaroos in Victoria:
Such low densities seem to reflect the effects of intensive land use and the marginal nature for kangaroos of the remaining areas of natural vegetation…
Reduced forest or scrub cover exposes kangaroos in these areas to the resulting control measures mounted by farmers…
I live and work across landscapes where there are often no or few trees (perfect habitat for kangaroos, according to the Committee), however there are generally no kangaroos either. Perhaps the Committee is not aware of the truth in the farming adage “if it moves shoot it, if it doesn’t chop it down”. Simply chopping down trees does not make kangaroos spontaneously appear, particularly when the chopping-down is accompanied by shooting.
From Archer et al (1985):
Before about 1850, European contact with kangaroos probably had minimal effect on kangaroo numbers. [this seems to ignore Darwin’s observations in the 1830s of impact around the settlements, on account of hunting with guns and dogs] However, in the following hundred years the spread of agriculture and our ancestors determination to turn Australia into a “little England”, had a drastic effect on the native mammalian fauna.
Areas worst affected were the semi-arid regions, particularly in western NSW and the wheat-belt of Western Australia. By the early 1890s such areas were badly overstocked with sheep; western NSW alone harboured over 15M. Because of droughts, rabbits and permanent damage done to the soil and vegetation by overgrazing, this area has never subsequently been able to carry half that number of sheep.
Seriously, how can clearing for farming and heavy shooting have made things better for kangaroos in NSW? The Committee again:
There is insufficient data for the last 3 generations to infer changes to habitat quality or diversity across the range of [kangaroos] in NSW.
What about inference of habitat degradation beyond the 3 generation limit? There seems to be ample evidence of that! If the landscape in western NSW can no longer support half the sheep it used to, how many kangaroos did it used to support, before white man came along and made everything so much better?
However Archer et al (1985) goes on, despite the previous descriptions of the degradation of western NSW, to state:
Not every kangaroo species was adversely affected by these changes [“improvement” by agriculture]. The modification of much of Australia’s semi-arid land into suitable grazing country allowed the Red Kangaroo to go from an uncommon and rarely seen animal [note the lack of reference to historic texts, many of which described them as abundant even in the harshest environments] to one of the country’s most abundant large mammals.
Archer et al (1985) continues, describing the “Kangaroos of the Open Forests, Woodlands & Scrub”:
Australia’s woodlands and scrubs are home to the greatest diversity of kangaroos… In some areas where many forest types are found side by side, such as north-eastern NSW, ten or eleven species of kangaroos and wallabies can occur together, ranging in size from the Long-nosed Potoroo at about 1kg in weight to the Eastern Grey Kangaroo which can weigh over 80kg.
Note that it is only the Red Kangaroo which Archer et al (1985) suggested had increased as a consequence of farming making things so much better, yet somehow in the intervening 30 years this theory has been applied by dozens of “researchers” to grey kangaroos as well, and even being stated by the Committee with regard to these species. The well-known preference grey kangaroos have is for woodlands and forested habitats (see Archer description of habitat above).
The Committee has also suggested that Wallaroos have also benefited from the range of “improvements” Europeans have brought to the landscape. Provision of water (even though the species does not need to drink), forest/woodland fragmentation (clearing habitat has made things better), and pasture improvement (even though the paddocks seem to be full of cows, horses and sheep, not Wallaroos).
It is great that the OEH are starting to consider that maybe things are not exactly as they have been portrayed by the roo-meat industry-based scientists for the last 30 years (more kangaroos than there ever were).
Through Wildcount, scientists and land managers aim to detect if there is a 30% change in a species over a 10 year period.
Unfortunately Wildcount is not going to be the tool to demonstrate kangaroo decline, as the program has only commenced after much of the decline has already occurred (in the case of the large macropods), however more importantly the program is only targeting conservation areas.
If Wildcount detects a 30% decline in any species within their study areas (reserves targeted by the program), things will obviously be substantially worse in the surrounding landscapes. I would suggest the researchers set up some camera traps in the so-called “favourable” habitats created by farmland (wheat fields etc), to try to illustrate the scale of decline in the large macropods.
It is easy to believe that common native animals like kangaroos, brush-tailed possums, lyrebirds and wombats will always be around. However, these animals are as vulnerable as threatened species are to changes in the environment (http://www.environment.nsw.gov.au/animals/wildcount.htm).
Victoria’s reported 85% of the state having <1 kangaroo/km2 in 1982 (according to Short and Grigg) and Tasmania’s 90% decline in the Forester by the 1970s suddenly seems to make sense in the context of what has happened in NSW. However the Committee has stated instead:
There have been changes to the habitat quality for [Eastern Grey Kangaroos] in NSW since European settlement (reviewed in Calaby & Grigg 1989; Olsen & Braysher 2000). Some habitat, especially in the coastal zone and tablelands, has been lost to cropping, urbanisation and other infrastructure. However large areas have also been converted from forest and woodland to more open and grassy habitats which are highly favoured by [Eastern Grey Kangaroos].
We’ll leave Calaby & Grigg aside, a paper discussing kangaroos from over 20 years ago, as it has little relevance today after such a long period of continued and increasingly intensive shooting. With regard to Olsen & Braysher (and most recently the Committee itself) regurgitating this idea, has the Committee actually gone and had a look through the harvest zones of NSW in order to come to a position supporting this conclusion? Perhaps the Committee assumes my personal observations and experience has been limited to “the tablelands”.
My offer of a few days touring NSW to discuss the issue remains open – my understanding is that the Committee’s trip to the Newnes Plateau in 2004 was pivotal in making the determination listing longwall mining subsidence as a KTP, yet here we have a similar situation where independent research is challenging the establishment (entrenched mindsets of managers, and scientists supporting an industry sector).
Multi-regional declines and local extinctions are fact, while researchers misrepresent the situation with regard to kangaroo ecology and the history of their management and provide scientifically unsupported and misleading testimony and invalid survey “results” in support of the multi-million dollar commercial roo-meat industry.
It is a nice theory if you want to pitch the idea that there are more kangaroos than there ever were - that clearing forests makes habitat for kangaroos - but where is the science? Has anyone ever actually tested this theory according to accepted scientific method? Yes they have.
Montague-Drake & Croft (2004) showed that kangaroo distribution is directly related to presence of cover in combination with grazing opportunities - the Committee referring to Calaby & Grigg 1989 and Olsen & Braysher 2000 without referring to papers which actually quantify factors affecting kangaroo distribution is “cherry picking” and unscientific. Arnold (1995) is another paper that correlated macropod occurrence with the persistence of remnant vegetation - in fact they conducted kangaroo surveys to maximise detection by actively targeting remnant units.
The historic colloquial names “The Forester” and “Scrub Kangaroo” (in the case of the Eastern Grey Kangaroo) gives us a clue too about the preferred habitat for this species. The Committee’s position on this (clearing has made things better) is also at odds with findings in Tasmania (clearing and hunting led to 90% decline) and Short and Grigg’s (1982) conclusions about how clearing for agriculture affected kangaroos in Victoria:
Such low densities seem to reflect the effects of intensive land use and the marginal nature for kangaroos of the remaining areas of natural vegetation…
Reduced forest or scrub cover exposes kangaroos in these areas to the resulting control measures mounted by farmers…
I live and work across landscapes where there are often no or few trees (perfect habitat for kangaroos, according to the Committee), however there are generally no kangaroos either. Perhaps the Committee is not aware of the truth in the farming adage “if it moves shoot it, if it doesn’t chop it down”. Simply chopping down trees does not make kangaroos spontaneously appear, particularly when the chopping-down is accompanied by shooting.
From Archer et al (1985):
Before about 1850, European contact with kangaroos probably had minimal effect on kangaroo numbers. [this seems to ignore Darwin’s observations in the 1830s of impact around the settlements, on account of hunting with guns and dogs] However, in the following hundred years the spread of agriculture and our ancestors determination to turn Australia into a “little England”, had a drastic effect on the native mammalian fauna.
Areas worst affected were the semi-arid regions, particularly in western NSW and the wheat-belt of Western Australia. By the early 1890s such areas were badly overstocked with sheep; western NSW alone harboured over 15M. Because of droughts, rabbits and permanent damage done to the soil and vegetation by overgrazing, this area has never subsequently been able to carry half that number of sheep.
Seriously, how can clearing for farming and heavy shooting have made things better for kangaroos in NSW? The Committee again:
There is insufficient data for the last 3 generations to infer changes to habitat quality or diversity across the range of [kangaroos] in NSW.
What about inference of habitat degradation beyond the 3 generation limit? There seems to be ample evidence of that! If the landscape in western NSW can no longer support half the sheep it used to, how many kangaroos did it used to support, before white man came along and made everything so much better?
However Archer et al (1985) goes on, despite the previous descriptions of the degradation of western NSW, to state:
Not every kangaroo species was adversely affected by these changes [“improvement” by agriculture]. The modification of much of Australia’s semi-arid land into suitable grazing country allowed the Red Kangaroo to go from an uncommon and rarely seen animal [note the lack of reference to historic texts, many of which described them as abundant even in the harshest environments] to one of the country’s most abundant large mammals.
Archer et al (1985) continues, describing the “Kangaroos of the Open Forests, Woodlands & Scrub”:
Australia’s woodlands and scrubs are home to the greatest diversity of kangaroos… In some areas where many forest types are found side by side, such as north-eastern NSW, ten or eleven species of kangaroos and wallabies can occur together, ranging in size from the Long-nosed Potoroo at about 1kg in weight to the Eastern Grey Kangaroo which can weigh over 80kg.
Note that it is only the Red Kangaroo which Archer et al (1985) suggested had increased as a consequence of farming making things so much better, yet somehow in the intervening 30 years this theory has been applied by dozens of “researchers” to grey kangaroos as well, and even being stated by the Committee with regard to these species. The well-known preference grey kangaroos have is for woodlands and forested habitats (see Archer description of habitat above).
The Committee has also suggested that Wallaroos have also benefited from the range of “improvements” Europeans have brought to the landscape. Provision of water (even though the species does not need to drink), forest/woodland fragmentation (clearing habitat has made things better), and pasture improvement (even though the paddocks seem to be full of cows, horses and sheep, not Wallaroos).
It is great that the OEH are starting to consider that maybe things are not exactly as they have been portrayed by the roo-meat industry-based scientists for the last 30 years (more kangaroos than there ever were).
Through Wildcount, scientists and land managers aim to detect if there is a 30% change in a species over a 10 year period.
Unfortunately Wildcount is not going to be the tool to demonstrate kangaroo decline, as the program has only commenced after much of the decline has already occurred (in the case of the large macropods), however more importantly the program is only targeting conservation areas.
If Wildcount detects a 30% decline in any species within their study areas (reserves targeted by the program), things will obviously be substantially worse in the surrounding landscapes. I would suggest the researchers set up some camera traps in the so-called “favourable” habitats created by farmland (wheat fields etc), to try to illustrate the scale of decline in the large macropods.
The benefits of peer review
It has been suggested that my work has not been peer-reviewed, so it has little relevance to the ongoing debate about the status and management of kangaroos in Australia. I refer the Committee to Grigg's (2012) The review I might have written on the un-refereed publication by Ben-Ami et al (2010) on kangaroo harvesting.
Apparently Grigg had noticed a “serious flaw” in Ben-Ami’s logic, and the Ben-Ami paper had not been peer reviewed. From Grigg (2010):
Had it been, this flaw in scholarship should have been picked up.
In writing his opinion piece, Grigg chose “the peer review format; the review he might have written” had he been asked.
My nomination and supplementary submissions fit into the same category: they are themselves an unsolicited peer review of the large bulk of the available literature on the history of kangaroos, their management and exploitation. Much of this literature (particularly the management plans, and the quota and survey reports) do not seem to have gone through any form of formal peer review process, much less any form of critical or dissenting review.
For example Cairns' reports on the Central Tablelands (2009 and 2012) were not peer reviewed, they are simply consultant’s reports, funded by the proponent industry via tag and licensing fees.
No-one else noticed, apparently, that Cairns stated that they did not fly over national parks and state forests in the Central Tablelands in calculating populations, when in fact they did. This is a simple but fundamental and even critical error in the type of population study being conducted which peer review should have picked up (in fact my peer review did pick it up). Perhaps Cairns should have gotten his old associate Professor Grigg (eg: Cairns, Pople & Grigg 1991) to review his work. Professor Grigg, as an expert and very capable reviewer (by his own admission), would surely have noticed this gross error, and may have broken the bad news to Cairns a bit more gently.
Perhaps not though, as my understanding is that Grigg designed the South Australian surveys (and perhaps others), which have the same flaw.
No doubt it’s a bit embarrassing for the department (and Cairns) to have an independent outsider (myself, a certified and practicing professional ecologist) pointing out these mistakes, but it is incontrovertible fact that the kangaroo surveys in the Central Tablelands have been completely invalidated by the gross errors in methodology and analysis. OEH know this (from our meeting in March, see below). Shooting continues regardless.
Similarly, my independent analysis of the department’s population and monitoring data shows decline across all time scales. For the same reason no-one has done this before, and no-one has noticed that the data, which supposedly “tracks” populations, includes data which cannot be accepted in a scientific sense (biological impossibility of 249% growth, for example). This undermines 30 years of aerial survey data and the whole basis on which the supposedly “sustainable” roo-meat industry has been justified.
I personally would welcome a formal peer review of the nomination and associated papers. My submitting the paper to the Committee as it was in 2011 was really asking for an uber-review by NSW’s peak body of scientists. I would have thought the role of the Committee is to provide a scientific assessment of my submission’s discovery of the invalid data and methods that support the commercial kangaroo meat industry. Instead so far the Committee's response has been limited to simply regurgitating debunked theories, while seeming to ignore the actual content of the nomination. There has been a total lack of engagement with and discussion of the factors I have identified, and no acknowledgement of the obvious and widespread decline in the subject species, shown in the department’s own data, as well as being visibly the case.
From the Committee’s letter again, presumably based on its understanding of data being produced by the kangaroo monitoring program, as well as the cited references:
"It is well established that numbers of large kangaroos fluctuate widely primarily as a consequence of seasonal conditions”
The population survey data fluctuates wildly, that is true, but this is just indicative of enormous but as yet unacknowledged error margins in the survey methodologies. Researchers involved in large scale macropod surveys (such as Cairns) prefer to think that their data “tracks” actual populations because this conveniently gives them the supposedly scientific justification to suggest the harvest industry is sustainable, and allows claims of population “explosions” to be promulgated by an unquestioning media.
Indeed and contrary to the fact of site attachment and relatively small home ranges (numerous studies for all species), in trying to explain large fluctuations in his “data” Cairns (2012) suggested that 200,000 Eastern Grey Kangaroos moved from the southern to the northern sections of the Central Tablelands between 2008 and 2011.
If only Cairns’ work had been peer reviewed, perhaps someone could have made him aware of this error in scholarship.
Apparently Grigg had noticed a “serious flaw” in Ben-Ami’s logic, and the Ben-Ami paper had not been peer reviewed. From Grigg (2010):
Had it been, this flaw in scholarship should have been picked up.
In writing his opinion piece, Grigg chose “the peer review format; the review he might have written” had he been asked.
My nomination and supplementary submissions fit into the same category: they are themselves an unsolicited peer review of the large bulk of the available literature on the history of kangaroos, their management and exploitation. Much of this literature (particularly the management plans, and the quota and survey reports) do not seem to have gone through any form of formal peer review process, much less any form of critical or dissenting review.
For example Cairns' reports on the Central Tablelands (2009 and 2012) were not peer reviewed, they are simply consultant’s reports, funded by the proponent industry via tag and licensing fees.
No-one else noticed, apparently, that Cairns stated that they did not fly over national parks and state forests in the Central Tablelands in calculating populations, when in fact they did. This is a simple but fundamental and even critical error in the type of population study being conducted which peer review should have picked up (in fact my peer review did pick it up). Perhaps Cairns should have gotten his old associate Professor Grigg (eg: Cairns, Pople & Grigg 1991) to review his work. Professor Grigg, as an expert and very capable reviewer (by his own admission), would surely have noticed this gross error, and may have broken the bad news to Cairns a bit more gently.
Perhaps not though, as my understanding is that Grigg designed the South Australian surveys (and perhaps others), which have the same flaw.
No doubt it’s a bit embarrassing for the department (and Cairns) to have an independent outsider (myself, a certified and practicing professional ecologist) pointing out these mistakes, but it is incontrovertible fact that the kangaroo surveys in the Central Tablelands have been completely invalidated by the gross errors in methodology and analysis. OEH know this (from our meeting in March, see below). Shooting continues regardless.
Similarly, my independent analysis of the department’s population and monitoring data shows decline across all time scales. For the same reason no-one has done this before, and no-one has noticed that the data, which supposedly “tracks” populations, includes data which cannot be accepted in a scientific sense (biological impossibility of 249% growth, for example). This undermines 30 years of aerial survey data and the whole basis on which the supposedly “sustainable” roo-meat industry has been justified.
I personally would welcome a formal peer review of the nomination and associated papers. My submitting the paper to the Committee as it was in 2011 was really asking for an uber-review by NSW’s peak body of scientists. I would have thought the role of the Committee is to provide a scientific assessment of my submission’s discovery of the invalid data and methods that support the commercial kangaroo meat industry. Instead so far the Committee's response has been limited to simply regurgitating debunked theories, while seeming to ignore the actual content of the nomination. There has been a total lack of engagement with and discussion of the factors I have identified, and no acknowledgement of the obvious and widespread decline in the subject species, shown in the department’s own data, as well as being visibly the case.
From the Committee’s letter again, presumably based on its understanding of data being produced by the kangaroo monitoring program, as well as the cited references:
"It is well established that numbers of large kangaroos fluctuate widely primarily as a consequence of seasonal conditions”
The population survey data fluctuates wildly, that is true, but this is just indicative of enormous but as yet unacknowledged error margins in the survey methodologies. Researchers involved in large scale macropod surveys (such as Cairns) prefer to think that their data “tracks” actual populations because this conveniently gives them the supposedly scientific justification to suggest the harvest industry is sustainable, and allows claims of population “explosions” to be promulgated by an unquestioning media.
Indeed and contrary to the fact of site attachment and relatively small home ranges (numerous studies for all species), in trying to explain large fluctuations in his “data” Cairns (2012) suggested that 200,000 Eastern Grey Kangaroos moved from the southern to the northern sections of the Central Tablelands between 2008 and 2011.
If only Cairns’ work had been peer reviewed, perhaps someone could have made him aware of this error in scholarship.
Requests for information obfuscated & delayed by the Department
In March 2013 I met with OEH-KMU manager Nicole Payne and OEH-BCU Manager Peter Christie, part of which discussion included flagging information I would like access to (particularly survey and harvest data from western NSW), and to obtain responses from the department on some key points with regard to the harvest model and kangaroo management.
As well as discussing the gross errors in the Cairns 2009 and 2012 Central Tablelands reports (amongst other things), I pointed out seemingly critical flaws in the harvest model.
I mentioned this in the previous supplementary submission to the Committee, including providing the entire OEH data.xls file, however the Committee does not seem to have given even cursory consideration to this issue in their response.
For clarity I have imported a small sample of the pertinent data set into this response so that readers do not have to refer to multiple sources to understand the point, and so that the Committee will be on the record as providing no response if it continues to ignore these factors in making a determination on the large macropods threatened species nomination.
As well as discussing the gross errors in the Cairns 2009 and 2012 Central Tablelands reports (amongst other things), I pointed out seemingly critical flaws in the harvest model.
- Shooting rates exceed maximum population growth rates; shooting continues even during drought when populations would naturally be in decline, exacerbating the effects of drought on populations.
- Calculating a 15% quota based on the previous years population estimate will necessarily result in over-allocation if a population is declining.
I mentioned this in the previous supplementary submission to the Committee, including providing the entire OEH data.xls file, however the Committee does not seem to have given even cursory consideration to this issue in their response.
For clarity I have imported a small sample of the pertinent data set into this response so that readers do not have to refer to multiple sources to understand the point, and so that the Committee will be on the record as providing no response if it continues to ignore these factors in making a determination on the large macropods threatened species nomination.
The over-allocations are rather obvious in the data set: instead of 17% quotas for this species, in fact the OEH provided quotas to shoot up to 40% of the population; and at Tibooburra in 2006 (for example), during drought when the population would have been declining, 22.2% of the Red Kangaroo population was shot.
Leaving aside the fact that the designated harvest rate of 17% for Red Kangaroos exceeds the species’ capacity to reproduce in any event (see the body of the nomination and the first supplement), does the Committee has any response to the fact that more than the supposedly sustainable 17% of the population was shot in 2006 at Tibooburra? Is it any wonder that the graphs provided in the 2011 nomination and the 2012 supplementary submission show severe decline in the populations and “take”, given over-allocation of declining populations, leading to over-shooting?
The OEH gave an undertaking to form a response to the numerous questions I had raised in the meeting and by email, to which communications I had made the Committee privy, in the interest of transparency and to ensure that the Committee were up to date on how the OEH-KMU were dealing with some of the points I had raised in the nomination.
Leaving aside the fact that the designated harvest rate of 17% for Red Kangaroos exceeds the species’ capacity to reproduce in any event (see the body of the nomination and the first supplement), does the Committee has any response to the fact that more than the supposedly sustainable 17% of the population was shot in 2006 at Tibooburra? Is it any wonder that the graphs provided in the 2011 nomination and the 2012 supplementary submission show severe decline in the populations and “take”, given over-allocation of declining populations, leading to over-shooting?
- The “long term average” thresholds at which harvesting is suspended obviously decrease as continuing low populations necessarily reduce the long term average itself, and shooting occurs at ever lower densities.
The OEH gave an undertaking to form a response to the numerous questions I had raised in the meeting and by email, to which communications I had made the Committee privy, in the interest of transparency and to ensure that the Committee were up to date on how the OEH-KMU were dealing with some of the points I had raised in the nomination.
The following are the communications I have entered into, in order to try to obtain answers from the OEH on these issues, and seeking additional information which was supposed to inform this supplementary submission.
**Communications to be uploaded. 2021