Key points explained:
Unsustainability of commercial killing:
The Plan incorrectly asserts that the commercial kangaroo shooting is ecologically sustainable. This claim does not hold up under scrutiny. Kill quotas take no account of compounding pressures on kangaroo populations, including drought, bushfires and other extreme weather events, which can severely impact what local populations can sustain, and risk local extinctions. Without better, more robust independent ecological monitoring and modelling of these pressures, claims of ‘sustainability’ remain unproven.
In your own words:
Overall, commercial kangaroo shooting should not be permitted because of the risk it poses to Australia’s biodiversity. If the government permits the wildlife trade to continue, at a bare minimum it should account for climate, drought and bushfire impacts in every kill quota decision, and demonstrate — through independent and more robust ecological monitoring — that the industry is not pushing local kangaroo populations into decline.
Lack of independent monitoring:
There is no independent monitoring of what occurs at the point of kill. A 2019 departmental audit [2] found it was “impossible” to confirm whether kangaroo carcass numbers reported across the industry were true or accurate. The industry is left to report on itself, with no independent supervision, no routine field inspections and no reliable way to verify what actually happens when kangaroos are shot.
In your own words:
Overall, commercial kangaroo shooting should not be permitted because it is impossible to effectively regulate. If the government permits the industry to continue, at a bare minimum, the Plan should require body-worn or vehicle-mounted cameras for all commercial shooters, with footage made available to an independent regulator and commission genuinely independent audits rather than relying on industry self-reporting.
Issues with annual kill quota setting:
Kill quotas are set using flawed and inaccurate population estimates. A 2023 review [3] (commissioned by the department) found that current methods rely on adjustment factors more than 20 years old, and are applied through survey methods that may never have been properly designed. Independent statisticians reviewing population data have found individual estimates that defy biological plausibility — in one instance, a population estimate could not be reconciled with the number of animals actually observed, using any method attempted. One biostatistician described the underlying data as the worst population-based data she had seen.
In your own words:
Overall, commercial kangaroo shooting should not be permitted because annual kill quotas are set using flawed and inaccurate methods. If the government permits the industry to continue, at a minimum the Department must immediately update its adjustment factors and survey methods using a truly independent ecologist, and every population estimate should be checked for biological plausibility by independent ecologists before it is used to set a kill quota.
Licensing regime:
Compliance with licence conditions is impossible to enforce as shooting occurs at night time with no supervision. When complaints and reports of noncompliance are made, they do not result in prosecution. Between 2015 and 2019, not a single licence was suspended and no shooter was prosecuted, despite repeated reported breaches. In one year, 785 reporting breaches were logged internally and only one penalty was issued [4]. Shooters are not required to notify authorities in advance of when or where they intend to shoot, and there is no properly staffed emergency line to report or follow up welfare breaches as they happen.
In your own words:
Overall, commercial kangaroo shooting should not be permitted because of the complete lack of effective regulation of the industry. If the government permits the trade to continue, at a bare minimum, the Plan should require shooters to notify authorities in advance of every shoot, establish a properly staffed 24-hour reporting and response line for welfare breaches, establish an independent body to supervise shooting activity in the field, and take real enforcement action, including licence suspension, when breaches are confirmed. The Plan should also require shooters to gain permission from all bordering neighbours before a permit is approved.
Animal Cruelty:
The Code underpinning the Plan [5] permits joeys to be killed by blunt force trauma or decapitation — methods the Code itself acknowledges can cause suffering. Wounding rates of shot adult kangaroos have been estimated at between 4 and over 40 per cent [6], and wounded animals that escape are never counted in official figures. Even at the low end of that range, this equates to tens of thousands of kangaroos being mis shot and suffering slow and painful deaths every year. This is completely unacceptable and does not align with community expectations or modern animal welfare science.
In your own words:
Overall, commercial kangaroo shooting should not be permitted because of the cruelty that is inherent to the trade. If the government permits the trade to continue, at a bare minimum the Plan must prohibit shooting of female kangaroos, commit to immediately prohibit the killing of joeys by blunt force trauma or decapitation and require shooters to report every dependent joey they encounter, kill or leave behind. The plan must also establish an independent method of monitoring shooters in the field in real time, to supervise shooting activities, respond in real time, to wounded and mis shot kangaroos, and investigate and prosecute when the Code isn’t followed.
Disrespectful to First Nations culture and lore:
The industry is often defended by pointing to Indigenous traditional use of kangaroos, but this conflates subsistence use under Aboriginal law and custom with a profit-driven export industry run largely by and for non-Indigenous interests. Many First Nation’s people find this justification offensive, and the Yuin Declaration for Kangaroos calls for kangaroos to be protected as part of a living cultural and spiritual relationship spanning more than 80,000 years.
In your own words:
NSW should listen to First Nation’s voices, including the Yuin Declaration for Kangaroos, and stop allowing this industry to misuse cultural heritage as justification for commercial killing.
Other feedback:
This is the place to make your submission personal. Decision-makers pay particular attention to submissions that go beyond the standard points, so use this section to add whatever is relevant to you.
You might include:
- If you are a wildlife carer or rescuer, and what that work involves
- If you live in an area where shooters kill kangaroos and what that experience is like
- How you feel, more broadly, about the lack of protection kangaroos and other wildlife receive in your community and how you value their welfare, protection, and peaceful co-existence.
