An open letter to Field & Game members from Chief Executive Officer Richard Light.
23rd February 2018
I am writing to inform you of some disturbing changes in and interpretation of regulations to the Wildlife Act in Victoria and to update you about what we are doing about it.
On Tuesday evening, 20th Feb, the Game Management Authority (GMA) posted a fact sheet on their website (read the detail here) relating to two additional regulations that were inserted by the Wildlife (Game) Amendment Regulations 2018 (Gazetted on the 31st January 2018) with the expressed purpose of regulating the collection of game birds and the retention of game meat:
The regulations are as follows:
51A Downed game birds to be recovered
A person who hunts, takes or destroys a game bird must make all reasonable efforts to recover the downed game bird immediately after the bird is struck.
Penalty: 20 penalty units.
51B Breast meat of game bird to be kept in possession
(1) Subject to subregulation (2), a person who hunts, takes or destroys a game bird must keep the meat of both breasts of the game bird
in the person's possession until —
(a) immediately prior to cooking; or
(b) that game bird has been taken to the person's place of residence.
Field & Game has no qualms with a requirement to make a reasonable effort to recover game birds and to retain at least the breast meat; it is what we do anyway. This is an extract from our own Code of Ethics:
Every hunter’s objective is to achieve the instantaneous death and efficient recovery of every targeted animal or bird. Where possible, and wherever regulations allow, every animal or bird that is taken should be put to good use.
However, the proposed compliance regime, for 51A is an overreach which will be impossible to follow and as such will put our members in the untenable position of breaching the regulation in normal hunting situations.
We are dismayed that the real world experience of FGA and its members was not canvassed in the drafting and interpretation of the fact sheet.
On Wed 21st Feb, I contacted Minister Jaala Pulford’s office and the GMA seeking immediate modification so the regulations are practical, realistic and do not leave members open to criminal prosecutions.
The key concerns for us are that their interpretation of the regulations as stated on the GMA fact sheet is severe over-reach and place our members in an untenable situation in normal hunting scenarios.
I was subsequently contacted by the CEO of the GMA – Greg Hyam, on Wednesday afternoon, to inform me that they have modified their fact sheet as follows:
- If a pair of birds present, they can both be taken (a "double") as long as one of the birds has not been downed. However, to minimise the possibility of wounding, it is recommended to focus on one bird only. If one bird is struck, reserve the second shot to immediately dispatch it if wounded.
- If my gundog is half-way through a retrieve, can I shoot at passing or decoying birds?
If your dog has retrieved the bird and is on its way back to you, you have made a reasonable effort to recover the downed bird. However, it is recommended that the retrieval be completed and the bird returned to you before taking any further shots.
- What if I unintentionally down multiple birds in a single shot?
Avoid shooting into a flock of birds as this increases the chances of wounding multiple birds. Always focus on shooting trailing, side or single birds. If you do strike more than one bird, focus on recovering the easiest bird first and try to make a mental picture of where the other bird went down in order to search for it once you have recovered and dispatched the first bird.
While this addresses the majority of our concerns with the specific fact sheet, the lack of consultation on the interpretation of the regulations is deeply troubling.
The same day, hunters received a GMA letter, outlining the 2018 duck season details and changes. This letter stated that the modified opening times is now a 2 year trial. This was never mentioned in any meetings we had with the Minister or the Government. It is our understanding that the modified opening times were to be evaluated after this season. It was quite a shock to be informed of the 2 year trial for the first time via letter from the GMA.
I am meeting with the Minister’s office on Monday with the express intent to have this unworkable 9am opening trial applied for only the 2018 season.
It is our understanding that the fact sheet and letter from the GMA were not written by the GMA, but by bureaucrats in the Department of Economic Development, Jobs, Transport and Resources (DEDJTR). A super-department in the Victorian Government, which is one of at least eight departments that has some say about duck hunting.
We have stated repeatedly in all of our conversations with the government and authorities that our members are law abiding hunters and the solution to stop illegal behaviour is the enforcement of the law and prosecution of illegal shooters.
We are also concerned that the regulation designed to keep protestors out of wetlands until after 10am has not been extended in line with the later opening time for hunting, which creates a safety risk.
We are continuing to fight for fair and reasonable regulations relating to duck season but we need your help.
Please call the Minister’s Office, the GMA and your local politician to express you dismay at the continued victimisation of law abiding hunters by having regulations that are impractical, impossible to follow and that make no practical sense, imposed on you.
The Hon. Jaala Pulford
Minister for Agriculture and Regional Development
Ph: (03) 8392 6000
Game Management Authority (GMA)
Ph: 131 186
Richard Light | Chief Executive Officer
Field & Game Australia
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