In the eye of an Emu
Life on land
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Life on land
Here is a snapshot of our approach to this Victorian Government inquiry written in 2021. Things have deteriorated significantly since then. I will let Hansard publish my commentary during the inquiry. The issues discussed here are a few among many. We can conclude that, for each and every dimension discussed here, there has been no improvement in the circumstances for Australia’s wildlife in Victoria since we wrote this submission, if anything, despite the efforts of many, the shocking decline in standards and duty of care have continued at pace. This work also formed the basis of the submission by the Australian wildlife charity, the Australian Wildlife Protection Council Inc (AWPC) at the time.
What appears to happen is that Australian native animals are continually pushed towards the brink, with all sorts of claims about why they should be exterminated. Claims by the Victoria Government, even for animals like Koalas, were that they were overabundant. Prior to the 2020 fires the Victorian Government was suggesting that young Koalas should not be rescued from fire grounds.
The killing of native Australian wildlife is now so entrenched, and the sense of entitlement of governments promoting this behaviour and the individuals carrying it out, that poor standards are applied. Just one example of many is that in Victoria and following an extensive trial (from 2014) to turn Victoria’s Kangaroos into pet food, the Government continued to claim increasing populations of Kangaroos in the state despite the industrial scale killing that had occurred since commercial exploitation of Kangaroos was introduced.
So when Australian species have made that journey to the brink, many have gone over the edge, they become endangered, and then perhaps, if they are lucky, some attention and belated compassion is directed towards them. By then it is really too late.
So the trick is to stop endangering the native species that still remain and actually look after their habitat instead of ripping it down when every little bit of common sense provides a thousand reasons why the destruction should stop.
Learning about, and living with Australian wildlife, is an extraordinary privilege that must also be the right of future generations to enjoy.
The Victorian Government understands the importance of reducing greenhouse gas (GHG) emissions while Australia’s overall performance remains poor, good in some sectors, bad in others. There are many issues relating to climate change in Victoria that need urgent action. While climate change is a key driver of biodiversity loss, in the submission we wished to concentrate on a range of other threatening processes of which the public have far less awareness. So in relation to climate change we make some top line comments only.
Performance is strongly driven by policies, in Australia’s case these policies, driven by vested interests, have been inconsistent and can be described as generally poor. These shortcomings have a significant impact on wildlife and the natural infrastructure that sustains us all. Recent droughts, floods, heat and fire intensity describes the outcomes.
At the time we said that such poor policies meant that there continued to be limited action in transport, existing buildings, industrial processes, wastes and agriculture National Greenhouse Gas Inventory (NGGI) sectors. The Climate Change Performance Index, used by Climate Change Tracker, found that the best performing countries are Sweden, Denmark and Morocco, and the worst performing are Taiwan, Saudi Arabia and the US. New Zealand was ranked 34 and Australia 53 of the 58 countries assessed. If Australian fossil fuel exports had been embedded into emissions it was likely that Australia’s global share of emissions is somewhere in the region of 3.3 per cent.
Flying Foxes are a group of species that show extreme vulnerability to climate change because of mass die offs in heat events. This group of species is also harassed and still shot ‘legally’ in other regions of Australia. Populations of Flying Foxes are declining very quickly.
The Little Red Flying Fox and the Grey-headed Flying Fox are important to the local ecology of Victoria. Grey-headed Flying Foxes are permanent residents of Southern Victoria. Little Red Flying Foxes are migratory residents to northern Victoria. The Grey-headed Flying Fox is listed as threatened under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 and under the Victorian Flora and Fauna Guarantee Act 1988.
Flying Fox species are at risk of extinction in Victoria and face a series of threats, including:
Flying Foxes are pivotal species in the ecology of Victoria, dispersing seeds during a night of foraging activity. Flying Foxes play a major role in the regeneration of hardwood forests and rainforests.
“The combination of extreme weather due to climate change and the particular heat sensitivity of these species mean that a pro-active management and support plans are essential to ensure the survival of Victoria’s Flying Foxes into the future (cross border planning is also required). This work should be undertaken in collaboration with the extensive knowledge and skills of the Friends of Bats and Bushcare, the organisation led by Lawrence Pope”. Peter Hylands
Conclusion: Key threatening process with poor remedial performance, driving questionable policies at Federal level, which impact circumstances in the State of Victoria.
Major concern: 2019-20 Australian wildfires may have accounted for one billion tons (US estimate) of greenhouse emissions. Full recovery of plant life remains unlikely, partly for political reasons. COVID-19 lockdowns would have had some offsetting effect in 2020. But current trends and the patterns of fire in the landscape, including both wildfires and hazard reduction burns, increase the likelihood that the decline of plant life will impact the capacity of plants to capture carbon in the atmosphere.
Recommendation: Accelerate GHG emissions policies and review hazard reduction policies in Victoria based on scientific research. Apply pressure on Commonwealth Government to improve its performance. Key features here include questioning and moving beyond the idea that gas is a transitional energy source and improving governance and compliance (an active testing regime was required) in relation to building standards and energy codes in Victoria.
Like it or not, exports shape economic performance. It is the type of exports that matter in shaping the outcomes for the natural world, as they do in shaping the kinds of employment available.
Pre COVID, nothing has changed, the Harvard Economic Complexity Index 2019 noted:
“Compared to a decade ago Australia’s economy has become less complex, worsening 22 positions to 93rd. This situation was driven by a lack of diversification of exports. Australia is less complex than expected for its income level. As a result, its economy is projected to grow slowly. The Growth Lab's 2027 Growth Projections foresee growth in Australia of 2.2% annually over the coming decade, ranking in the bottom half of countries globally”.
What the above statement from Harvard tells us is that, given current economic structures, Australia’s balance sheet can only be maintained by exploiting and degrading the environment.
As gas, coal and iron ore and other primary production dominate exports, instead of working towards diversification, the status quo had the strong support of the Commonwealth Government and this inevitably flows on to partly shape state policies. This lack of economic diversity puts the economy at increasing risk and charts a pathway to further destruction of the natural environment in order to maintain current levels of affluence. This in turn bodes ill for the future of biodiversity in Victoria and Australia generally. It reflects a way of thinking about place and this in turn is reflected in the other building blocks of extinction discussed in the submission.
Conclusion: The structure of the Victorian and Australian economies are therefore found to be a key driver of extinction and biodiversity loss.
Major concern: Given the way regional economic development is currently understood there were significant concerns about the ongoing likelihood of policies that further endanger biodiversity in an attempt to create the types of jobs and skills that politicians in Australia understand. In this way, regional communities are wedged into unsustainable industries that damage the environment with few plans from government to chart a different future. Events surrounding the most recent Federal election in Queensland and the recent history (last 30 years) of the Latrobe Valley are just two such examples of many. Last minute attempts at economic fixes are very bad for communities, particularly so for regional communities, instead long-term planning is required.
Recommendation: Within Victoria, urgently review those industries and activities that pose a significant threat to biodiversity in Victoria, the worst of all can either be replaced (coal), creating more jobs in renewables sector, are subsidised by the tax payer (many forestry practices) or are activities with no future that should cease with immediate effect, such as commercial harvesting of wildlife (Kangaroos) or hunting for recreation (Duck shooting) which contribute little to economic activity in the state and are significant actors in blocking out more beneficial knowledge based economic activity.
The environmental impact v productivity of current farming methods in Victoria needs review, the Victorian Government should actively encourage farmers to learn to live with wildlife and more generally the natural world, the opposite is currently occurring.
“Of wild animals there are not a great many in Egypt, but such as there are, are without exception held to be sacred. Anyone who deliberately kills one of these animals is punished with death. Should one be killed accidently, the penalty is whatever the priests chose to impose. But for killing an Ibis or a Falcon, whether deliberately or not, the penalty is inevitably death”. Herodotus
ATCWs / commercial permits / duck shooting / rescue of wildlife from public fire grounds against a backdrop of international funding / culling of wildlife in state and national parks even as the fires burned / too many and too frequent reduction burns
The combined result of all the above is catastrophic. Labor in Victoria have escalated or allowed the assault on Victoria’s wildlife, near doubling the number of ATCWs when compared to the previous Liberal government, a trade in wildlife has been introduced for Macropods, duck shooting continues despite environmental conditions and rescues of wildlife have been blocked from state and national parks and other public lands. Despite the fires, the killing of wildlife continued at scale.
Here was an example of the unrelenting use of ATCWs, despite the dire circumstances for a particular species. There was no understanding, or indeed empathy, in relation to knowing when to stop the killing. The history of Wombat species in Victoria is a terrible one.
Until a few months ago Wombats in a very large part of Victoria were not protected, and where they were protected in Victoria, in the period 2009-2018, Wombats were subject to numerous ATCWs (2,044 permits) covering the control of 26,507 animals.
All this despite the desperate need for a statewide intervention for Sarcoptic Mange devastating the Bare-nosed Wombat population in Victoria.
“We need proper research to understand the threat level to Wombats in Victoria, concurrently with a well-resourced support plan for active treatment now. Wombat deaths from Sarcoptic Mange in Tasmania and in some places indicate as much as a 95 per cent reduction in Wombat populations”. Peter Hylands
In Victoria in the years 2014 – 2018, 750,000 Kangaroos were authorised to be killed by ATCW / KPFT permits. The number of Kangaroos authorised roughly doubled once the pet food trial really got underway despite government statements that there would be no increase in killing rates once the trial commenced. 390,886 of these animals were authorised under KPFT of which around 212,000 were actually processed. Since that time the increase in the killing rate when compared to the pre-commercial period has continued.
The reality, forget the spin, is that Kangaroo populations are being decimated across the State of Victoria, as are the family structures of these wonderful animals. The Kangaroos that remain are getting smaller, the larger animals are killed first, and the pouch dependent young are either killed in the most brutal of ways or die of starvation and trauma. And that takes out much of the next generation.
In the 10-year period between 2009 and 2018 the Victorian Government issued permits to kill 49,141 Red Kangaroos in the State. That is more than 8 times their year 2000 population estimate. In 2010 the Victorian Government issued permits to kill a modest 15 Red Kangaroos, in 2017 they issued permits to kill a whopping 15,187 Red Kangaroos.
In the 2017 in the first Victorian Government Kangaroo survey, they counted 23 Red Kangaroos (at vast expense) and this was then turned into a population estimate of 13,000 for that year. Having found very few Kangaroos at all in 2017, so desperate were the Victorian Government to turn Kangaroos into pet food, they had another go at a survey, this time they came up with a Red Kangaroo population of 44,000, having counted just 91.
The numbers become even more puzzling when we included young Red Kangaroos (joeys) which are killed by whacking them over the head with a bit of iron (that is if they are lucky). Young Kangaroos are not counted in the massacre. So let’s say the permits the Victorian Government issued would be responsible for an additional 22,113 Red Kangaroos being massacred over the 10- year period described.
To summarise, from a Victorian Government population estimate of 6,000 Red Kangaroos in the year 2000, permits were issued covering 71,254 Red Kangaroos including young. Add another, say, 6,000 Red Kangaroos for the permits issued in the years 2000 to 2008 plus young at 2,700. So all up the permits (estimate) issued to kill Red Kangaroos in the period since 2000 cover 79,954 animals. This killing also takes out the next breeding generation, as the Victorian Government requires that all dependent young must be killed.
So in 2018 we still end up with a Victorian Government population estimate of 44,000 Red Kangaroos. This means there are still plenty more to kill? So given the evident inflation of the probable population, in 2019, the Red Kangaroo was not included in the full commercial ‘harvest’ species list in Victoria.
Given the extensive exploitation of the Western Grey Kangaroo in Victoria in the last six years, the situation for this species is likely to be similar to the one described for the Red Kangaroo in Victoria.
Along with the commercial industry exploiting wildlife come expensive aerial surveys, additional staff at tax payers’ expense to ‘manage’ this exploitation and a great deal of anxiety from residents living in the places where Kangaroos are butchered. Quotas are issued based on the survey numbers (which are extrapolated numbers analysed above for the case of the Red Kangaroo). This leaves two so called ‘harvest’ species in Victoria, the Western Grey Kangaroo and the Eastern Grey Kangaroo. The inaccuracy of the population estimates, which are inflated, pave the road to extermination of species. The Victorian Government has been warned of these matters over and over again.
So six years after the commercial Kangaroo trade commenced in Victoria this time around, the following footnote appears in the commercially killed Kangaroo reports for 2020:
“Note: Note that the Western Grey (Kangaroo) figure is considered highly inflated, as the reporting tool only allows ‘harvesters’ to identify Western Greys which is creating user error – enhancements to the reporting tool will be implemented in 2020”.
Note: Peter Hylands had already advised the Environment Minister (on several occasions) about his concerns regarding the decline in Western Grey Kangaroo populations. No specific response has ever been received.
Status of Kangaroo, Wallaby, Potoroo and Bettong species and their relatives in Victoria following the catastrophic bushfires in Victoria is 2020. Even the fires and climate change have not stopped the ever growing number of animals being killed.
The conduct of DELWP was both secretive and misleading. The culture is a killing culture without responsibility and accountability. All matters relating to the care of biodiversity in the state must be the responsibility of a newly formed department with the care of and protection of biodiversity at its core. The Victorian Government was responsible for propaganda activities defaming wildlife in order to benefit cruel and out-dated commercial activities, which disrupt other forms of economic development.
“In early March 2020 I was working in the desert country to the west of Alice Springs, a remote place where I often stay. Coming in to see our friends in Hermannsburg I rang the Victorian ecodev number 136 186 to enquire how the latest Kangaroo harvest quotas had been calculated for each Victorian region. I was put through to a staff member in Ballarat and initially told there had been surveys in both 2019 and 2020. I knew this to be incorrect so when I queried the response, I was given a lecture about how terrible these animals are and told that people (like me) living in cities do not understand the issues. Given that I have owned two significant rural properties, one in Central Victoria over many decades and another near the Endeavour River in Far North Queensland and I spend time working in the remotest places in Australia and I know a lot about numbers, these claims seemed pretty outrageous”. Peter Hylands
Victorian Government numbers provided under FOI showed that the number of native animals rescued from public lands as a result of the catastrophic fires in Victoria was 350 of which 257 (74 per cent) were Koalas. Of the 342 animals euthanised 293 (86 per cent) were Kangaroos and Wallabies.
Selective extraction of species already in dire trouble, the Victorian Government is saying they will spend $2.4 million of the emergency fund of $17.5 million on this program, perhaps covering some 34 species. 15 Eastern Bristlebirds have already been extracted from the bushland near Mallacoota.
What we did not need or want to see are the large amounts of money donated by the general public (for fire impacted wildlife rescue and rehabilitation) and by governments, because relatively so few animals have been rescued, being syphoned off to fund threatened species research in universities and in infrastructure developments at zoos, which is occurring anyway, and given the catastrophic loss and decline in species in Australia, has had little impact on the overall situation. A proper state plan needs to be developed that addresses cross border issues, the interaction of native species with each other and their environments and the long-term goals and outcomes of such a plan. Ad hoc conservation does not and has not worked and that is clearly demonstrated in the circumstances at the time.
There was a danger here that at least some of these funds will have had precisely the opposite impact the gifters of the money intended. Keeping wildlife alive, feeding and preparing release sites, should have been the priorities.
To get an understanding of the culture of state government environment departments here are three extracts from the Victorian Government’s wildlife fire response plan. There was controversy over the plans to kill pouch / milk dependent young even if the animals are uninjured. Milk dependent young can be quite large and up to around 18 months old.
Despite claims from the government in 2021 that these plans were no longer current (some staff still claiming they were) this appeared to have occurred by default. To date there is little evidence of the rescue of young animals across the species the government claim to be overabundant (that includes Koalas). DELWP quotes follow:
“The most common species that may be seen in the Victorian fire context are Koalas, Brushtail and Ringtail possums, echidnas, and joeys of large kangaroo species (Eastern, Western Grey Kangaroos). Small macropods, adult wombats and reptiles are less frequently seen. Conservation and population status of affected wildlife needs to be understood as these may also impact decision making about triage. For example, an over abundant population with established health issues may require a closer consideration for euthanasia of compromised animals over treatment”.
“All euthanised animals must be thoroughly examined for pouch young or the immediate area should be searched for young at foot (where applicable) after euthanasia. Where young are found, a decision must then be made on the appropriate course of action depending on the age of the young (either euthanised or transferred to an appropriately qualified carer for rehabilitation)”.
“Rehabilitation of orphaned milk-dependent pouch young of common species such as Macropods and Koalas is not supported as these animals require significant long term care and cannot be successfully returned to the wild”.
“The public and the media should receive accurate and timely information in order to maintain good public relations and prevent people from attempting to obtain the information from other sources”.
One of the most concerning matters and an indicator for the contempt shown for the nature of Australia is the use of Kangaroo meat for 1080 baits. These are government funded programs where 1080 poison is dropped from aircraft across the Australian environment – this is occurring in fire grounds in both New South Wales and Victoria (I am told Kangaroo meat is NOT used for this purpose in Victoria). Despite pretence otherwise, the poisoned bait is indiscriminate and a threat to native carnivores including reptiles, birds and mammals. The poison persists in the carcasses of dead animals, which in turn are fed upon by other species of wildlife.
The question in relation to these matters were how much additional Kangaroo meat was being used as a result of programs and additional government funding that was meant to assist wildlife in the fire grounds and was any of the money donated by the general public from around the world found its way into any of these disgraceful programs?
Places such as Victoria’s RAMSAR sites should be places of education as they are in many other parts of the world and NOT places of violence, abuse and destruction, even engaging young children in the cruelty and killing of birdlife.
Conclusion: Government conduct, including standards of governance, in relation to the management and supervision of the ATCW system, the commercial trade in wildlife, protection of forests and other habitats and the conduct on Victoria’s Ramsar sites, including the hunting of waterbirds, could only be described as extremely poor and a major threat to the state’s remaining biodiversity. Communication of information from DELWP and government generally is a construct to attempt to defend the clear shortcomings in these matters. This in itself is damaging to good government and breeds an unwholesome culture of no accountability or responsibility for outcomes that were evident even before an activity to damage wildlife populations commences. The inquiry should have paid attention to its own reports in relation to duck shooting, the commercial trade in Kangaroos and the associated pet food trial and to forestry in Victoria.
Major concern: Despite the carnage of the fires (2019-2020) and the drastic decline in birdlife more generally, the Victorian Government called both a full Quail shooting season and a modified duck shooting season, these terrible events, which continue for many weeks each year, are a major slaughter of birdlife (in a ‘normal’ season this equals hundreds of thousands of birds including the death and suffering of protected species). Despite the fires and the terrible climate conditions, the staggering loss of biodiversity in the state and the exaggerated population numbers of these wonderful animals, the slaughter of Kangaroos continued, both for commercial and other reasons as expressed in the large number of Authorities to Control Wildlife permits, issued so readily by the Victorian Government. Taxpayers' money is being spent in Victoria in promoting and facilitating the mass destruction of wildlife (including ATCW system, duck shooting and the commercial trade in Kangaroos) while at the same time, once species are endangered, taxpayers’ money is spent in an attempt to conserve species. The two opposite processes showing no signs of co-ordination.
Recommendation: A long and deteriorating history of government conduct in relation to wildlife conservation clearly indicates that action is now required. In Victoria, that action is a restructuring of DELWP with the precise goal of extracting any responsibility for the care of biodiversity from this department and placing this vital task into the hands of a new department with the sole purpose of protecting Victoria’s environment and the plants and animals that live in it.
One of the key threatening processes for wildlife and the environment more generally - and this goes for all states and territories are the cultures within government. That is politicians, who either don’t know or don’t care, and departments who endlessly defend and facilitate the mass killing of wildlife. This reflects on governance and management standards and process. All this leaves the people in our communities who care about their wildlife without rights and that extends to even defending their own livelihoods and investments from the kind of behaviours that are commonplace in regional Victoria.
Among our concerns are people and their treatment by government departments. In some states, the treatment of wildlife carers, who are mostly self-funded volunteers, is abysmal. Also, the level of or the lack of support, including financial support, from governments who see some of our carer community as a nuisance and an obstacle to the agenda of mass scale killing of wildlife, needs to change. Greater respect for carers is essential and this is also a matter of governance.
The pattern of turning a blind eye to the most horrific crimes, particularly cruelty, and the entitlement of the perpetrators that results, while prosecuting and intimidating those that care about, rescue and rehabilitate wildlife, is not and cannot be acceptable. These contradictions reflect very poorly on the Victorian Government.
Also of concern are those Australians living in regional Australia who witness and are often harassed by the killing activities conducted by governments and industry. Because of state based legislation there are almost no avenues to complain about these horrendous acts occurring on their doorstep. We have heard many such stories from individuals, including whose houses and children have been hit by shot from hunting activities and from those witnessing the shooting and butchering of Kangaroos from their properties. These are the animals that they have come to love.
FOI requests are played with and answers are hard to extract.
Conclusion: The introduction of the commercial trade in Kangaroos has increased tension in regional communities in Victoria. High powered rifles and scenes of great cruelty have been introduced (and the Victorian Government knows this) into rural landscapes and at the edge of towns amid residential and hobby farm populations. For a growing number of people the killing and evident cruelty has become the last straw and is now a serious matter in terms of endangerment of regional populations, their investments and rights for peaceful and productive lives.
Major concern: A blatant disregard for residents in regional Victoria that do not want duck shooting or the commercial trade in Kangaroos on their doorstep. The behaviour of both politicians and public servants (including police) in relation to these matters is far from just.
What this behaviour does is to create a sense of entitlement in those doing the killing, a few benefiting financially from their actions, which further opens up residents to abuse. The small numbers of individuals involved in the Kangaroo industry and in duck shooting activities does not justify their dominance in the landscape and the extensive harm being done by these activities.
Recommendation: Free from fear and threat - a new deal for wildlife carers and rescuers and proper protection for the lands surrounding wildlife shelters. The protection of people, their human rights and their property rights - for individuals and families investing in knowledge economy and conservation based activities and businesses in regional Victoria.
In Australia there is and remains a curious disregard and disinterest for those things that are truly Australian. While this has changed since the 1950s and many more people are now engaged in speaking up for Australia’s biodiversity and environment more generally, these attitudes are still deeply entrenched, the psychology here is to turn a blind eye to what has been done and during the history of the colonial period. The way Australian wildlife is and has been treated, too many species already lost to the world in the colonial period, are just one aspect of this cultural conditioning.
When measuring and protecting biodiversity, proper account needs to be taken of the full taxonomy of life. It is critically important that all classes of life, and how they interact with each other, are considered. There is clearly a taxa bias in Victoria in the way in which the conservation of nature is both considered and conducted.
What is on the land, is in the sky and in the sea
We should not forget the sea life that inhabits Victoria’s coastline and coastal waters. There are worrying trends which include fish kills, algal blooms, declining numbers of coastal birds and bird deaths, for example, by the end of October 2019 fewer than 100 of the usual 40,000 mutton birds had arrived at Victoria's Griffiths Island. Recent seismic testing off the Victorian coast has led to reports from fishermen operating in the east of Victoria to report that their catch is down by as much as 80 per cent since the start of seismic testing in the area. This activity has an impact on the entire web of life.
“Although marine protected areas covered approximately 11 per cent of Victoria’s marine waters, their spatial extent is skewed to Corner Inlet / Nooramunga and Wilsons Promontory, indicating that the network is failing to meet the National Representative System of Marine Protected Areas principles of comprehensiveness, adequacy and representativeness across all five marine bioregions”. CES State of the Environment Report 2018.
“The sudden and unexpected death of masses of fish is known as a fish kill. In March 2017 there was a fish kill in far eastern Victoria, stretching from just south of Mallacoota up to the NSW border”. CES
“Changes to the Eastern Australian Current appear to have contributed to a stronger than usual upwelling and more dramatic changes in temperature. The East Australia Current now runs further south than it used to and is more intense. The current has been affected by climate change, and projections show that the oceans in south-eastern Australia will have the greatest increases in sea temperature in our region. This may cause further changes to the current, resulting in more frequent and intense upwellings in the future”. CES
Conclusion: There will have to be a significant effort from the Victorian Government to change the current set of attitudes towards wildlife, both within government and among the general public, many of whom have little or no understanding of what is happening to wildlife in Victoria. The lack of empathy and lack of care for wildlife that is so obvious will only be changed by leadership and education in these matters. The opportunities around wetlands and particularly Ramsar sites in Australia are just one example of how things could be done better with the consequent improvement in economic output for regions.
Major concern: The trend in Australia is towards degrading environmental laws and protections, the intent to further weaken the EPBC Act is just one example.
Recommendation: Initiate proper and structured conservation activities and a state wide assessment of the current circumstances for Victoria’s species, in doing so to build the understanding of how to avoid further endangerment of all species in Victoria. This should include state wide and cross state border plans and long term objectives for species with the resources to properly monitor the wellbeing of species against plans. We can no longer afford a situation where there is a conflict of interest between the organisations driving key threatening processes, organisations that are also the enforcer and legislator and funded by the tax payer. This conduct has been all too common in Victoria and has resulted in the poor outcomes we see today.