supplementary submission 3
Review of western NSW survey data and methodology
To The NSW Scientific Committee
C/O OEH-PWS
PO Box 1967
HURSTVILLE NSW 2220
By email to the Secretary
[email protected]
Dear Scientific Committee,
Find below and attached a summary of GIPA327 information release (received 2nd December 2013), referred to in my previous submission on the 4 large macropods nomination (Mjadwesch 2013)[1], as well as supporting documents and a partial analysis.
Re:
GIPA1: Survey data sheets for western NSW, 2000 (135 pages, raw data) and
GIPA2: Survey data sheets for western NSW, 2010 (147 pages / 4 files, raw data).
C/O OEH-PWS
PO Box 1967
HURSTVILLE NSW 2220
By email to the Secretary
[email protected]
Dear Scientific Committee,
Find below and attached a summary of GIPA327 information release (received 2nd December 2013), referred to in my previous submission on the 4 large macropods nomination (Mjadwesch 2013)[1], as well as supporting documents and a partial analysis.
Re:
GIPA1: Survey data sheets for western NSW, 2000 (135 pages, raw data) and
GIPA2: Survey data sheets for western NSW, 2010 (147 pages / 4 files, raw data).
Methodology
Transects sample 1° blocks (from 141°-150° longitude), which are broken up into 90 second segments. Flying at 185km/hr each segment is equivalent to a distance of 5km; there are 17 transect segments per degree surveyed.
Three species are targeted by survey, Red Kangaroos, “grey” kangaroos (including both Eastern and Western Grey Kangaroos) and goats.
In 2000 200m wide strips were surveyed. In 2010 100m wide strips were surveyed. There is no “distance” data recorded (an alternative survey methodology often used to develop more sophisticated models of wildlife populations, but having its own problems); all of the far-western NSW kangaroo survey data is simple “area” data.
Other critical fields on the transect survey proformas include date, time start and finish, temperature, conditions (sun/shade, sometimes other weather notes) and lat/longs identifying the 1° survey block and the line along which the counts were conducted.
Three species are targeted by survey, Red Kangaroos, “grey” kangaroos (including both Eastern and Western Grey Kangaroos) and goats.
In 2000 200m wide strips were surveyed. In 2010 100m wide strips were surveyed. There is no “distance” data recorded (an alternative survey methodology often used to develop more sophisticated models of wildlife populations, but having its own problems); all of the far-western NSW kangaroo survey data is simple “area” data.
Other critical fields on the transect survey proformas include date, time start and finish, temperature, conditions (sun/shade, sometimes other weather notes) and lat/longs identifying the 1° survey block and the line along which the counts were conducted.
Absence & Decline
The thing that is immediately noticeable on the data sheets is all the zeros. Any wildlife manager obtaining monitoring data for target species such as the kangaroo monitoring data sets being collected should have been extremely concerned, even in 2000. Attachment 1 is the smallest of the 5 files provided under GIPA327 (part of the 2010 data set), provided so that the Committee can independently review the subject material.
When I received the files, the first sheet I looked at (2000 data set) had more than half of the transect segments as zeros: Red Kangaroo (LHS) 9 zeros (RHS) 11 zeros (out of a total 34 samples); grey kangaroos (LHS) 13 zeros (RHS) 11 zeros (again out of 34 samples).
It is clear on preliminary review of the top 4 transects (designated Transects A-D herein) that there is high correlation between presence and absence data in the 2000 and 2010 data sets, indicating that the counts do intersect and provide a measure of density – a “snapshot”, according to Payne (2008) – across persistent populations.
In its rawest form (one’s and zero’s) the data illustrates patterns of extinction across the landscape; processing the data provides a measure of the relative densities within persisting populations, over time. These results reflect in large part my impression of much of western NSW as now having few or no remaining kangaroos.
The images on the following pages illustrate the expansion and consolidation of extinction zones (zero counts are indicated in black), increasing fragmentation of populations, and decreasing kangaroo densities along the northern-most far-western transects in NSW between 2000 and 2010.
Zeros for the same transect segments over the long term provide compelling evidence of absence, and are strong indicators for land-uses which have effectively removed the species.
With consideration for unknown limits of error, colour-coding results from 2000 and 2010 provide an indication of the rate and extent of decline between the 2 sampling dates.
When I received the files, the first sheet I looked at (2000 data set) had more than half of the transect segments as zeros: Red Kangaroo (LHS) 9 zeros (RHS) 11 zeros (out of a total 34 samples); grey kangaroos (LHS) 13 zeros (RHS) 11 zeros (again out of 34 samples).
It is clear on preliminary review of the top 4 transects (designated Transects A-D herein) that there is high correlation between presence and absence data in the 2000 and 2010 data sets, indicating that the counts do intersect and provide a measure of density – a “snapshot”, according to Payne (2008) – across persistent populations.
In its rawest form (one’s and zero’s) the data illustrates patterns of extinction across the landscape; processing the data provides a measure of the relative densities within persisting populations, over time. These results reflect in large part my impression of much of western NSW as now having few or no remaining kangaroos.
The images on the following pages illustrate the expansion and consolidation of extinction zones (zero counts are indicated in black), increasing fragmentation of populations, and decreasing kangaroo densities along the northern-most far-western transects in NSW between 2000 and 2010.
Zeros for the same transect segments over the long term provide compelling evidence of absence, and are strong indicators for land-uses which have effectively removed the species.
With consideration for unknown limits of error, colour-coding results from 2000 and 2010 provide an indication of the rate and extent of decline between the 2 sampling dates.
NB: Vertical is not to scale
2000: NW NSW Red Kangaroos raw count/km2
2010: NW NSW Red Kangaroos raw count/km2
2000: NW NSW Grey Kangaroos raw count/km2
2010: NW NSW Grey Kangaroos raw count/km2
Black (zero counts) is obviously consolidating and increasingly fragmenting remaining red and grey kangaroo populations.
Transect A
For Red Kangaroos, black (zero counts) increased from 16 out of 34 cell counts in 2000, to 20 out of 34 cells in 2010 (from 47% to 59% of the transect, ie: nearly 60% absence).
For grey kangaroos, black (zero counts) increased from 12 out of 34 cell counts in 2000, to 18 out of 34 cells in 2010 (a 50% increase in absence, and taking the total from 35% to 53% of the transect).
Transect B
Transect A
For Red Kangaroos, black (zero counts) increased from 16 out of 34 cell counts in 2000, to 20 out of 34 cells in 2010 (from 47% to 59% of the transect, ie: nearly 60% absence).
For grey kangaroos, black (zero counts) increased from 12 out of 34 cell counts in 2000, to 18 out of 34 cells in 2010 (a 50% increase in absence, and taking the total from 35% to 53% of the transect).
Transect B
Increases indicated for the Red Kangaroo in the far west (in and around Sturt National Park) and at Ledknapper Nature Reserve (column 146º) are obviously outweighed by declines for the species outside of the states conservation reserves. A 12% reduction in Extent of Occurrence (EOO) between surveys in 2000 and 2010 takes Red Kangaroos to nearly 60% absence across the north of the state.
Note that even though grey kangaroos appear “steady” in the 142º column, they persist there in only 1 out of the 34 sample areas (only 3% of their former EOO), and at extremely low density (2 kangaroos / km2, or roughly 1 or 2% of “natural” densities). In the 143º column greys occupy only 18% of the transect in 2010 (82% absence), and are again “steady”.
Transect C
Note that even though grey kangaroos appear “steady” in the 142º column, they persist there in only 1 out of the 34 sample areas (only 3% of their former EOO), and at extremely low density (2 kangaroos / km2, or roughly 1 or 2% of “natural” densities). In the 143º column greys occupy only 18% of the transect in 2010 (82% absence), and are again “steady”.
Transect C
Once again Red Kangaroo increases in columns 142º, 143º and 145º offset reductions across the rest of the transect so that they appear steady across the block, however in the majority of the transect (5 segments) Red Kangaroos declined. Processing and analysing the data for Transect C2 (column 142º above) may provide insights into the seeming increase in Red Kangaroo EOO here.
Grey kangaroo data for Transect C does not look good, with seeming extinction from the western-most degree block and most of the next (160km reduction in western range limit) and uniform and generally heavy increase in absence (reducing by 2/3 overall in just 10 years). These factors combine to suggest extirpation from 56% of the transect in 2000 has increased to eradication from 85% of the transect in 2010.
Transect D
Grey kangaroo data for Transect C does not look good, with seeming extinction from the western-most degree block and most of the next (160km reduction in western range limit) and uniform and generally heavy increase in absence (reducing by 2/3 overall in just 10 years). These factors combine to suggest extirpation from 56% of the transect in 2000 has increased to eradication from 85% of the transect in 2010.
Transect D
Despite having the highest single count of kangaroos in the data set in 2000 (up to this point of data-processing the maximum recorded is 116 Red Kangaroos at D1S5), overall Red Kangaroo EOO declined along this transect by around 1/3 in the 10 years between surveys.
As in Transect C, grey kangaroos seem to have contracted out of the western-most degree of the state (a 120km reduction in western range limit), and declined in EOO by 70%. Implied absence increased from 54% in 2000 to 86% of the transect in 2010.
Skimming through the rest of the data sets it is clear that there are even entire 1 degree mapsheep / survey areas in which there seem to be no kangaroos – ie: 10,000 or so km² of contiguous absence. The 2010 data is much worse than the 2000 data, at a glance.
What levels of reduction in a species EOO are acceptable, for a wildlife exploitation program which is supposed to be sustainable? Is grey kangaroo EOO halving in the last 10 years (Transect B) indicative that continuing to shoot them is a good long-term option for conservation of the species? What about if they slump by 66% in a 10 year period (Transect C), or by 70%? (Transect D)
Such questions are important in the context that shooting is occurring tonight (and every night); hundreds or perhaps even thousands of animals and their joeys will be killed across NSW by tomorrow morning.
If the data is good enough for the department and its contracted researchers to manipulate in such a way as to generate highly inflated population estimates so that massive over-allocations of quotas can be given to unscrupulous industry partners, then the data is good enough to suggest, in its raw form, and with consideration for the fact that there is a large number of zeros in the data set, that populations are in severe decline, and all species have been badly affected by farming practices and heavy shooting in western NSW.
When three people see no kangaroos, this generally means there are no kangaroos. A zero count does not mean that there are kangaroos. The landscapes in which the zeros are counted are often widely open landscapes in which kangaroos are often clearly visible. The surveyors describe themselves as expert, with “50hrs training”.
A reported zero in this situation is an indicator of absence, particularly in the context of long-term (and ongoing) land-use and management practices in production landscapes with a focus on kangaroo suppression, to the point of eliminating them as “competition” for sometimes scarce resources, particularly during drought.
This data should be a matter of serious concern for anyone involved in wildlife management and conservation in Australia.
Indeed in 2011 quotas for “grey kangaroos” were temporarily suspended at Tibooburra, Broken Hill and Bourke, after shooting greys had been suspended in 2010 in the Narrabri and Griffith KMZs.
In 2012 quotas were re-instated (Payne 2011)[2], but being reduced to 10% for Western Grey Kangaroos in the Tibooburra, Broken Hill, Cobar, Bourke and Griffith harvest zones; WGK shooting was suspended in the Central Darling KMZ. Eastern Grey Kangaroo quotas were also reduced to 10% of the population in the Broken Hill and Bourke KMZs.
In 2012 populations were reported to have returned to well above the density thresholds for KMZ closures, and all restrictions were lifted, except for the 10% limit on the Western Grey Kangaroo quota in the Broken Hill KMZ, according to The Manager (2012)[3].
As in Transect C, grey kangaroos seem to have contracted out of the western-most degree of the state (a 120km reduction in western range limit), and declined in EOO by 70%. Implied absence increased from 54% in 2000 to 86% of the transect in 2010.
Skimming through the rest of the data sets it is clear that there are even entire 1 degree mapsheep / survey areas in which there seem to be no kangaroos – ie: 10,000 or so km² of contiguous absence. The 2010 data is much worse than the 2000 data, at a glance.
What levels of reduction in a species EOO are acceptable, for a wildlife exploitation program which is supposed to be sustainable? Is grey kangaroo EOO halving in the last 10 years (Transect B) indicative that continuing to shoot them is a good long-term option for conservation of the species? What about if they slump by 66% in a 10 year period (Transect C), or by 70%? (Transect D)
Such questions are important in the context that shooting is occurring tonight (and every night); hundreds or perhaps even thousands of animals and their joeys will be killed across NSW by tomorrow morning.
If the data is good enough for the department and its contracted researchers to manipulate in such a way as to generate highly inflated population estimates so that massive over-allocations of quotas can be given to unscrupulous industry partners, then the data is good enough to suggest, in its raw form, and with consideration for the fact that there is a large number of zeros in the data set, that populations are in severe decline, and all species have been badly affected by farming practices and heavy shooting in western NSW.
When three people see no kangaroos, this generally means there are no kangaroos. A zero count does not mean that there are kangaroos. The landscapes in which the zeros are counted are often widely open landscapes in which kangaroos are often clearly visible. The surveyors describe themselves as expert, with “50hrs training”.
A reported zero in this situation is an indicator of absence, particularly in the context of long-term (and ongoing) land-use and management practices in production landscapes with a focus on kangaroo suppression, to the point of eliminating them as “competition” for sometimes scarce resources, particularly during drought.
This data should be a matter of serious concern for anyone involved in wildlife management and conservation in Australia.
Indeed in 2011 quotas for “grey kangaroos” were temporarily suspended at Tibooburra, Broken Hill and Bourke, after shooting greys had been suspended in 2010 in the Narrabri and Griffith KMZs.
In 2012 quotas were re-instated (Payne 2011)[2], but being reduced to 10% for Western Grey Kangaroos in the Tibooburra, Broken Hill, Cobar, Bourke and Griffith harvest zones; WGK shooting was suspended in the Central Darling KMZ. Eastern Grey Kangaroo quotas were also reduced to 10% of the population in the Broken Hill and Bourke KMZs.
In 2012 populations were reported to have returned to well above the density thresholds for KMZ closures, and all restrictions were lifted, except for the 10% limit on the Western Grey Kangaroo quota in the Broken Hill KMZ, according to The Manager (2012)[3].
Overflying national parks & reserves
Overlaying the transect segment locations onto NSW once again clearly reveals that segments with the highest raw densities uniformly overfly or lie proximate to national parks and nature reserves, state forests and other nominally non-shooting areas. For example Sturt National Park (green outline) and the first (western) 140kms of Transect B (red dashes) are illustrated below, being also discussed in Attachment B.
Sturt National Park and transect segments B1S1 - B2S11
It is not appropriate to count kangaroos in national parks and other non-shooting areas, to then subtract the park and reserve / non-shooting areas from the area of the KMZ, and apply calculated “densities” (based on utilising numbers counted in the national parks and non-shooting areas) to the remainder of the KMZ.
The survey data clearly shows low density, and even wide regional extinction outside of parks and other conservation areas (Transects A-D illustrated above). The methodology for the calculation of densities and subsequent “estimation” of kangaroo populations to inform quota “allocations” is scientifically indefensible.
Surveys which exclude national parks and state forests (eg: Armidale / Glen Innes) show clear declines in populations (see 2011 Nomination, pages 53-56), yet even then shooting in the Northern Tablelands KMZ continues relentlessly.
The survey data clearly shows low density, and even wide regional extinction outside of parks and other conservation areas (Transects A-D illustrated above). The methodology for the calculation of densities and subsequent “estimation” of kangaroo populations to inform quota “allocations” is scientifically indefensible.
Surveys which exclude national parks and state forests (eg: Armidale / Glen Innes) show clear declines in populations (see 2011 Nomination, pages 53-56), yet even then shooting in the Northern Tablelands KMZ continues relentlessly.
Selective transect sampling
The survey transects themselves actually target better vegetation in far-western NSW, rather than overflying population centres and intensively developed regions.
In the first place this was subtly achieved by flying along the ¼ and ¾ degree latitudes, as early laying-out of the colony tended to place cities and towns on or close to degree or half-degree lat/long intersects.
Selectivity was further, and perhaps less subtly, achieved by stopping transects before they hit major population centres, for example:
In the first place this was subtly achieved by flying along the ¼ and ¾ degree latitudes, as early laying-out of the colony tended to place cities and towns on or close to degree or half-degree lat/long intersects.
Selectivity was further, and perhaps less subtly, achieved by stopping transects before they hit major population centres, for example:
- Transect F (latitude 31.25º) stops before hitting Coonabarabran;
- Transect H (latitude 32.25º) stops before hitting Dubbo; and
- Transect M (latitude 34.75º) stops before hitting Narrandera
GIPA3: Far-Western NSW Kangaroo Survey Transects
Nonetheless the kangaroos counted in the national parks and reserves, state forests and other non-shooting areas (discussed above) were again used to calculate densities, which were then applied to the 1º map grid areas and more widely to entire KMZs in which these (zero-count) major population centres are located.
Deletion of survey transects
2000 data is included in the GIPA327 release for the transect along latitude 32.25º (designated here as Transect H) extending past Dubbo, and the transect along latitude 32.75º (designated here as Transect I) which extends past Peak Hill - both transects were sampled in 2000 east to 149º longitude.
Both surveyors (left and right-hand side of the plane) reported no Red Kangaroos at Dubbo and no kangaroos at all for the entire transect at Peakhill. These data sets clearly show that settlement and ensuing agriculture, coupled with heavy shooting, can affect populations across entire 1º blocks.
Transect D also shows what happens to kangaroos near population centres, as the transect approaches Narrabri at the transects eastern terminus (both red and grey kangaroos have been effectively wiped out since 2000, to a distance of about 70kms).
In 2010 data has been collected from all of the transects illustrated in the GIPA3 map above (2010 data set seems to be complete). Inexplicably Transects H & I have been shortened by 100km each.
Furthermore it is anomalous that the Payne (2008) map of survey Transect J (latitude 33.25º) and Transect K (latitude 33.75º) does not extend past longitude 146º. Taking the time to compare the map above with Payne’s (2008) Map 1 shows that a further 400km of survey transect is missing from the Payne (2008) map.
Has data for these transects not been included in the database / density / population calculations for Griffith KMZ11, because transect segments have been returning too many zero counts here?
Instead of continuing to survey these blocks as examples of land-system-wide destruction of kangaroo habitat, these survey transects have been either dropped from the monitoring program (data for the Dubbo & Peak Hill degree blocks does not appear in the 2010 data set), or dropped from the analysis (Payne 2008 transects omit Lake Cargelligo, Condobolin, Rankin Spring & Wyalong degree mapsheet areas).
Nonetheless densities based on counting kangaroos where they do occur (national parks and reserves, state forests etc elsewhere along the transects) have been applied to these regions in order to calculate populations in the total KMZ “harvest” areas in 2010, even though the data itself suggests these areas should be mapped as kangaroos absent.
Why have these transect sections have been deleted from the monitoring program or the analysis? Do these deletions indicate that those responsible for the survey and management programs are aware of the issue of disappearing kangaroos, as their survey transects retreat ahead of the decline?
Both surveyors (left and right-hand side of the plane) reported no Red Kangaroos at Dubbo and no kangaroos at all for the entire transect at Peakhill. These data sets clearly show that settlement and ensuing agriculture, coupled with heavy shooting, can affect populations across entire 1º blocks.
Transect D also shows what happens to kangaroos near population centres, as the transect approaches Narrabri at the transects eastern terminus (both red and grey kangaroos have been effectively wiped out since 2000, to a distance of about 70kms).
In 2010 data has been collected from all of the transects illustrated in the GIPA3 map above (2010 data set seems to be complete). Inexplicably Transects H & I have been shortened by 100km each.
Furthermore it is anomalous that the Payne (2008) map of survey Transect J (latitude 33.25º) and Transect K (latitude 33.75º) does not extend past longitude 146º. Taking the time to compare the map above with Payne’s (2008) Map 1 shows that a further 400km of survey transect is missing from the Payne (2008) map.
Has data for these transects not been included in the database / density / population calculations for Griffith KMZ11, because transect segments have been returning too many zero counts here?
Instead of continuing to survey these blocks as examples of land-system-wide destruction of kangaroo habitat, these survey transects have been either dropped from the monitoring program (data for the Dubbo & Peak Hill degree blocks does not appear in the 2010 data set), or dropped from the analysis (Payne 2008 transects omit Lake Cargelligo, Condobolin, Rankin Spring & Wyalong degree mapsheet areas).
Nonetheless densities based on counting kangaroos where they do occur (national parks and reserves, state forests etc elsewhere along the transects) have been applied to these regions in order to calculate populations in the total KMZ “harvest” areas in 2010, even though the data itself suggests these areas should be mapped as kangaroos absent.
Why have these transect sections have been deleted from the monitoring program or the analysis? Do these deletions indicate that those responsible for the survey and management programs are aware of the issue of disappearing kangaroos, as their survey transects retreat ahead of the decline?
Land-use & impacts on Kangaroo populations
Processing the data by land-use (Attachment B) makes clear that management practices in heavily developed areas have often seen the total extermination of kangaroos, and that problems with population fragmentation for all species may be becoming insurmountable. Local extinction is a dominant pattern through vast regions, and effective dispersal, for the purposes of maintaining genetic flows at a meta-population level for example, across these landscapes, is not possible.
Wallaroos/Euros
Perhaps the most worrying factor revealed by the raw data provided for western NSW by the OEH is the complete absence of Euros in western NSW. The data for the entire west of NSW reports zero Euros. By comparison, QLD surveys provide records of the species right across the state, albeit generally at very low density or sporadically.
Are there really no Euros left in western NSW? If so (and this is the departments own data) then the Committee has no option but to list subspecies erubescens on threatened species schedules immediately.
If there are Euros in western NSW, what species are they being attributed to in the red and grey kangaroo totals being reported by the OEH, given that Euros can be red or grey?
This is another epic fail by the department to provide anything like sustainable outcomes for any of the species involved in the monitoring programs.
Animals are being committed in their hundreds of thousands to the commercial roo-meat industry annually, with no valid scientific support or even any actual and verifiable data for any of the species subject to commercial exploitation in western NSW.
Given that Euros do persist in western NSW, for example at Scotia at the western end of the transect along latitude 33°15’ (designated Transect I herein), red and grey totals need to have Euros subtracted, to provide a true measure of numbers, and on which basis quotas for these species should have been correctly calculated.
Are there really no Euros left in western NSW? If so (and this is the departments own data) then the Committee has no option but to list subspecies erubescens on threatened species schedules immediately.
If there are Euros in western NSW, what species are they being attributed to in the red and grey kangaroo totals being reported by the OEH, given that Euros can be red or grey?
This is another epic fail by the department to provide anything like sustainable outcomes for any of the species involved in the monitoring programs.
Animals are being committed in their hundreds of thousands to the commercial roo-meat industry annually, with no valid scientific support or even any actual and verifiable data for any of the species subject to commercial exploitation in western NSW.
Given that Euros do persist in western NSW, for example at Scotia at the western end of the transect along latitude 33°15’ (designated Transect I herein), red and grey totals need to have Euros subtracted, to provide a true measure of numbers, and on which basis quotas for these species should have been correctly calculated.
Lack of independent review
Why has no-one ever independently reviewed this data? How have domestic and international scientific communities come to accept that the contracted monitoring and management program has any scientific merit whatsoever?
The errors in the program are clear to see. The data itself is good and clearly shows absence and decline, however the analysis and interpretation of the data (from biologically impossible population “explosions” through to the setting of quotas) misrepresents and manipulates results, creating a position that favours the roo-meat industry.
The reported outcomes from implementation of the Commercial Kangaroo Harvest Management Plan 2012-2016 in NSW (summarised in yearly quota reports) assert that the industry is sustainable and that kangaroo numbers are increasing. This is clearly not a true reflection of what has happened to kangaroos across 93% of western NSW.
Take graphs (revised in Mjadwesch 2012[4], Appendix 1) are a true reflection of the situation, showing upwards of 90% and continuing decline in abundance over the last 10 years, a finding supported by actual observed declining densities from surveys (discussed here and in Attachment 2).
I have not been selective in any way in my approach to data acquisition or analysis, to the extent my GIPA request for data sheets gave the department the option of providing sheets for 2000 and 2010, or 2001 and 2011. I have simply and independently graphed the government’s own data, and have conducted an impartial review of the scientific merit of the program, and have found it to be fundamentally and critically flawed in its logic, application and analysis.
The simple and unfortunate fact is that the shooting of kangaroos in NSW for commercial purposes has had no valid baseline data for NSW population estimates in commercial / shooting zones. Reported population densities and estimates are based on pseudo-scientific and error-ridden methodologies, and the department’s data acquisition processes and analysis has been selective and distorted.
The errors in the program are clear to see. The data itself is good and clearly shows absence and decline, however the analysis and interpretation of the data (from biologically impossible population “explosions” through to the setting of quotas) misrepresents and manipulates results, creating a position that favours the roo-meat industry.
The reported outcomes from implementation of the Commercial Kangaroo Harvest Management Plan 2012-2016 in NSW (summarised in yearly quota reports) assert that the industry is sustainable and that kangaroo numbers are increasing. This is clearly not a true reflection of what has happened to kangaroos across 93% of western NSW.
Take graphs (revised in Mjadwesch 2012[4], Appendix 1) are a true reflection of the situation, showing upwards of 90% and continuing decline in abundance over the last 10 years, a finding supported by actual observed declining densities from surveys (discussed here and in Attachment 2).
I have not been selective in any way in my approach to data acquisition or analysis, to the extent my GIPA request for data sheets gave the department the option of providing sheets for 2000 and 2010, or 2001 and 2011. I have simply and independently graphed the government’s own data, and have conducted an impartial review of the scientific merit of the program, and have found it to be fundamentally and critically flawed in its logic, application and analysis.
The simple and unfortunate fact is that the shooting of kangaroos in NSW for commercial purposes has had no valid baseline data for NSW population estimates in commercial / shooting zones. Reported population densities and estimates are based on pseudo-scientific and error-ridden methodologies, and the department’s data acquisition processes and analysis has been selective and distorted.
Increased level of threat
Given the evidence of severe decline, the steepness of the trajectories and the level of complacency within the department, I would like to increase the nominated level of threat to:
GIPA5-7: Chiller box locations and fill / load-out rates
This information release includes three large databases, with enough information to link chiller box locations spatially to kangaroo presence / absence meta-data (GIPA1 and 2 discussed above), proximity to parks / non-shooting areas, etc. This will be used to enable the categorisation of the landscapes in which the harvest has been operating.
Processing and analysis of this data will be a long-term research project, providing the final and forensic breakdown of on-ground shooting activities in NSW. It would logically be expected that there will be a correlation between harvest rates along population monitoring transects with the trajectories the raw population data illustrates along the transects.
GIPA8: Occupier Permits by LGA
The initial request to the OEH-KMU in August 2013, and the subsequent referral of this request through the GIPA process, specifically described the data required as “all other shooting data (occupier licence)”. For some reason the OEH-KMU only provided commercial harvest data (which I already had, albeit not by LGA), and did not provide the Occupier Permit (non-commercial) data by LGA, as requested.
On again requesting that the information stipulated in GIPA327 be provided I received the following reply (Lowe S pers comm 11.12.2013):
“In relation to your request for the total number of kangaroos shot for the purposes of damage mitigation by LGA for the period 2000-2013, I am advised there is no one system, database or unit in the Office of Environment and Heritage that would centrally hold the State-wide information you seek. Accordingly, many National Parks and Wildlife Service Area offices would need to gather and compile the information for their respective Areas which would take an unreasonable and significant amount of time and resources.”
“Under section 60(1)(a) of the Government Information (Public Access) Act 2009, an agency may refuse to deal with an application if dealing with the application would require an unreasonable and substantial diversion of the agency’s resources. This would be the situation here.”
Given the role of the OEH-PWS includes “the preservation and protection of wildlife”, it is something of a paradox that NPWS officers are required to sign licenses to shoot kangaroos (without question), but they can’t be asked to compile an inventory of kangaroos shot under Occupier Permits (non commercial) in NSW.
Further, that a request for information relevant to the issue of ongoing decline in a native species (or even 4 native species) is deemed unreasonable, is an inversion of my own expectations, as to what perhaps should be the OEH-PWS priority in this regard.
In fact there may even be some Occupier Permit (non-commercial) data accumulated somewhere - from Olsen & Lowe (2006)[5].
“In March 2004 a four-year trial was begun of harvesting in the south-east (South-East New South Wales, Zone 16), formerly in the non-commercial zone, to facilitate commercial use of kangaroos currently shot under non-commercial licenses (Pople et al. 2005). Its success will be evaluated against impact of the kangaroo population, the level of take in relation to quota and the impact on non-commercial culling (Payne 2005).”[6]
Given that commercial shooting in SE Australia was supposed to have been a “four-year trial”, how was evaluation of the program carried out in relation to non-commercial culling? What data did Payne gather on non-commercial shooting? Given that the department do not seem to have collated any non-commercial data (according to the GIPA release), on what basis or analysis has commercial shooting in the SE KMZ been allowed to continue?
We can refer to occupier licence (damage mitigation) shooting from Questions on Notice (Shoebridge D, September 2013) for the period (financial year) 2010-2011 to 2012-2013:
2010-2011: 161,279
2011-2012: 268,023
2012-2013: 341,772
Unfortunately these figures are too non-specific to be really useful: numbers are not linked to locations, there is no species information, and the data inconsistently overlaps the financial year (above) with calendar year commercial data.
Nonetheless given the content of the nomination, supplementary submissions and this discussion paper, an additional total of over 650,000 animals being shot for the purposes of “damage mitigation” between 2010 and 2013 would surely have contributed to an expected continuing decline, rather than the population increases being reported.
A full understanding of what has happened to the large macropods under the management of the department will require a complete inventory of the numbers of animals destroyed under “damage mitigation” permits. Any responsible manager would surely acknowledge that a comprehensive accounting of a population is central to any management program for a species.
Refusal by the department to provide such an inventory raises the question of whether the department is cognisant of the fact of decline, and is seeking to minimise damage by with-holding pertinent information from public disclosure.
Populations have already been clearly shown to be in decline on account of habitat loss and commercial shooting, and over 20% of some populations have been shot as a direct consequence of over-allocation of declining populations in some years, particularly during drought. These figures already exceed anything researchers have described as a “sustainable harvest rate” (15-17%), and is even farther beyond the replacement rates for the species involved (up to 10% per annum or thereabouts, according to Mjadwesch 2011[7] and Mjadwesch 2012).
It seems likely that if damage mitigation shooting is also included in the equation, over-shooting may extend the death-toll beyond accepted “sustainable” harvest rates in even more kangaroo management zones. Exceeding the accepted “sustainable” harvest rates is obviously not sustainable.
With regard to the department’s reason for not providing this information, as “too much time and effort required”, it is ironic that I am providing quite unreasonable and significant amounts of my own time and resources (GIPA request: $285) to bring these serious issues before the department, only to see my in-good-faith submissions, requests and concerns stonewalled, ignored and obfuscated.
A comprehensive accounting of the total number of kangaroos shot in NSW since 2000 (by LGA, or KMZ, for example) still cannot be independently concluded.
Thank you for your continued attention to the 4 large macropods nomination.
Yours Sincerely
Raymond Mjadwesch
Conservation Biologist
- ENDANGERED for Red Kangaroo, Eastern and Western Grey Kangaroo, and
- for the Wallaroo / Euro to CRITICALLY ENDANGERED, on account of survey data sheets for far-western NSW not providing even a single observation of the species, and the dire situation with Wallaroos in the Northern Tablelands, the Central Tablelands and South-East NSW KMZs.
GIPA5-7: Chiller box locations and fill / load-out rates
This information release includes three large databases, with enough information to link chiller box locations spatially to kangaroo presence / absence meta-data (GIPA1 and 2 discussed above), proximity to parks / non-shooting areas, etc. This will be used to enable the categorisation of the landscapes in which the harvest has been operating.
Processing and analysis of this data will be a long-term research project, providing the final and forensic breakdown of on-ground shooting activities in NSW. It would logically be expected that there will be a correlation between harvest rates along population monitoring transects with the trajectories the raw population data illustrates along the transects.
GIPA8: Occupier Permits by LGA
The initial request to the OEH-KMU in August 2013, and the subsequent referral of this request through the GIPA process, specifically described the data required as “all other shooting data (occupier licence)”. For some reason the OEH-KMU only provided commercial harvest data (which I already had, albeit not by LGA), and did not provide the Occupier Permit (non-commercial) data by LGA, as requested.
On again requesting that the information stipulated in GIPA327 be provided I received the following reply (Lowe S pers comm 11.12.2013):
“In relation to your request for the total number of kangaroos shot for the purposes of damage mitigation by LGA for the period 2000-2013, I am advised there is no one system, database or unit in the Office of Environment and Heritage that would centrally hold the State-wide information you seek. Accordingly, many National Parks and Wildlife Service Area offices would need to gather and compile the information for their respective Areas which would take an unreasonable and significant amount of time and resources.”
“Under section 60(1)(a) of the Government Information (Public Access) Act 2009, an agency may refuse to deal with an application if dealing with the application would require an unreasonable and substantial diversion of the agency’s resources. This would be the situation here.”
Given the role of the OEH-PWS includes “the preservation and protection of wildlife”, it is something of a paradox that NPWS officers are required to sign licenses to shoot kangaroos (without question), but they can’t be asked to compile an inventory of kangaroos shot under Occupier Permits (non commercial) in NSW.
Further, that a request for information relevant to the issue of ongoing decline in a native species (or even 4 native species) is deemed unreasonable, is an inversion of my own expectations, as to what perhaps should be the OEH-PWS priority in this regard.
In fact there may even be some Occupier Permit (non-commercial) data accumulated somewhere - from Olsen & Lowe (2006)[5].
“In March 2004 a four-year trial was begun of harvesting in the south-east (South-East New South Wales, Zone 16), formerly in the non-commercial zone, to facilitate commercial use of kangaroos currently shot under non-commercial licenses (Pople et al. 2005). Its success will be evaluated against impact of the kangaroo population, the level of take in relation to quota and the impact on non-commercial culling (Payne 2005).”[6]
Given that commercial shooting in SE Australia was supposed to have been a “four-year trial”, how was evaluation of the program carried out in relation to non-commercial culling? What data did Payne gather on non-commercial shooting? Given that the department do not seem to have collated any non-commercial data (according to the GIPA release), on what basis or analysis has commercial shooting in the SE KMZ been allowed to continue?
We can refer to occupier licence (damage mitigation) shooting from Questions on Notice (Shoebridge D, September 2013) for the period (financial year) 2010-2011 to 2012-2013:
2010-2011: 161,279
2011-2012: 268,023
2012-2013: 341,772
Unfortunately these figures are too non-specific to be really useful: numbers are not linked to locations, there is no species information, and the data inconsistently overlaps the financial year (above) with calendar year commercial data.
Nonetheless given the content of the nomination, supplementary submissions and this discussion paper, an additional total of over 650,000 animals being shot for the purposes of “damage mitigation” between 2010 and 2013 would surely have contributed to an expected continuing decline, rather than the population increases being reported.
A full understanding of what has happened to the large macropods under the management of the department will require a complete inventory of the numbers of animals destroyed under “damage mitigation” permits. Any responsible manager would surely acknowledge that a comprehensive accounting of a population is central to any management program for a species.
Refusal by the department to provide such an inventory raises the question of whether the department is cognisant of the fact of decline, and is seeking to minimise damage by with-holding pertinent information from public disclosure.
Populations have already been clearly shown to be in decline on account of habitat loss and commercial shooting, and over 20% of some populations have been shot as a direct consequence of over-allocation of declining populations in some years, particularly during drought. These figures already exceed anything researchers have described as a “sustainable harvest rate” (15-17%), and is even farther beyond the replacement rates for the species involved (up to 10% per annum or thereabouts, according to Mjadwesch 2011[7] and Mjadwesch 2012).
It seems likely that if damage mitigation shooting is also included in the equation, over-shooting may extend the death-toll beyond accepted “sustainable” harvest rates in even more kangaroo management zones. Exceeding the accepted “sustainable” harvest rates is obviously not sustainable.
With regard to the department’s reason for not providing this information, as “too much time and effort required”, it is ironic that I am providing quite unreasonable and significant amounts of my own time and resources (GIPA request: $285) to bring these serious issues before the department, only to see my in-good-faith submissions, requests and concerns stonewalled, ignored and obfuscated.
A comprehensive accounting of the total number of kangaroos shot in NSW since 2000 (by LGA, or KMZ, for example) still cannot be independently concluded.
Thank you for your continued attention to the 4 large macropods nomination.
Yours Sincerely
Raymond Mjadwesch
Conservation Biologist
Attachment 1. GIPA327 original survey data sheets (one of five files, example only)
Attachment 2. Transects A & B 141° to 144°: 2000 - 2010
To be uploaded. 2021
