GMA CEO, Graeme Ford, has responded to SSAA Victoria’s correspondence regarding the 2022 duck season setting arrangements. See below.
SSAA Victoria appreciates the response but would still expect to see greater transparency around the GMA Board’s decision-making process. It remains unclear to stakeholders how the guiding principles are considered in relation to each other and the relative weighting each principle is given. It is unclear how the triple bottom-line assessment is conducted, assessed and then reflected in the Board’s recommendations to the Minister.
The Association continues to advocate strongly for its members on duck hunting issues and remains committed to the effective introduction of objective, science-based season setting arrangements. It will work co-operatively with the GMA, Government, other hunting organisations and relevant stakeholders to achieve that objective.
It will also continue to work co-operatively and in good faith to improve processes around the season setting arrangements.
Hi David
Thank you for your email outlining SSAA’s position on the duck season consultation process. I understand that SSAA Victoria chose to not make a submission regarding the 2022 duck season setting arrangements, due to your concerns about the process.
We are committed to ensuring that the GMA’s process for making a recommendation on duck season arrangements is clearly communicated and that the best available data is considered.
The GMA makes available all information that is considered during the process, including a copy of the briefing that the GMA provides to the Minister for Agriculture. While the process for setting duck season arrangements is available on the GMA website, under Duck Season considerations, I have provided some more detailed information in this email that I hope you find useful.
Various data sets are used in developing the GMA’s recommendation on duck season arrangements, and these data sets are considered in accordance with the GMA Board’s Guiding Principles, as set out in Section 8A of the Game Management Authority Act (2014). The Act was amended in 2019 to incorporate these principles –
8A Guiding principles
The Authority must have regard to the following principles when exercising its powers or performing its functions under this Act—
(a) the principle of integrated decision-making, which means seeking to achieve government policy objectives through coordination between all levels of government and government agencies;
(b) the principle of triple bottom-line assessment, which means an assessment of all the economic, social and environmental costs and benefits, taking into account externalities;
(c) the principle of equity, which means—
(i) equity between persons irrespective of their—
(A) personal attributes including age, physical ability, ethnicity, culture, gender and financial situation; and
(B) location, including whether in a growth, urban, regional, rural or remote area; and
(ii) equity between generations by not compromising the ability of future generations to meet their needs;
(d) the principle of an evidence-based approach, which means considering the best available information when making decisions;
(e) the principle of stakeholder engagement and community participation, which means taking into account the interests of stakeholders and members of the local community in implementing appropriate processes for stakeholder engagement;
(f) the principle of transparency, which means that members of the public should have access to reliable and relevant information in appropriate forms to facilitate a good understanding of game management issues and the process by which decisions in relation to game management are made.
I have attached a simple flow chart as requested, which outlines the data that is considered at each stage of the process. Click here to view.
In relation to the interim decision process, as the Adaptive Harvest Management system is being developed, Professors Kingsford and Klaasen were engaged by the Department of Jobs, Precinct and Regions (DJPR) to develop an interim model. Professors Kingsford and Klaasen delivered the paper; Relationships among duck population indices and abiotic drivers to guide annual duck harvest arrangements (KKM). The fundamental change to the duck season considerations process, compared to previous years, is that the KKM model provides the starting analysis of the data.
As has been the practice in recent years, all data sets used by the GMA are provided to stakeholders as early as possible in the process, stakeholders are invited to provide comment and in particular any additional data that would inform the decision process. All stakeholder submissions are then made available on the GMA website.
This KKM model is built on the recommendation from the Expert Panel report. I have provided the relevant extract below for your quick reference:
“… consideration should be given to a simple, transparent process for setting harvest regulations which could then be modified or augmented to include modelling results as appropriate at a later date. Given the constraints in currently available scientific information, the panel therefore recommends that, in the short-term, appropriate and adequate information for management can be generated by a conceptually simple and defensible harvest management framework which combines appropriate measures of spring wetland abundance/rainfall, summer abundance/rainfall, and available waterbird monitoring data to annually generate an abundance ranking for the coming season.
This could take a range of forms, such as a “traffic light” system reflecting risk levels (i.e. red light = Low abundance/High risk; orange = Medium abundance/Medium risk; Green light = High abundance/Low risk). The number of abundance/risk levels could be extended as appropriate, and this categorisation could be linked to appropriate management measures.
The proposed modelling of historical datasets could evaluate and test the capacity of various indices of rainfall/wetland availability to predict waterfowl population growth rates, and thereby recommend categories of harvesting with definitions based on these indices.”
Please note that the expert panel process and the delivery against recommendations is the responsibility of DJPR. The interim harvest model has been developed following stakeholder consultation and now sets the basis for setting seasons while the AHM is developed and ultimately implemented.
Professors Kingsford and Klaasen, in their report, also stated:
We also encourage the use of the model as an “adaptive interim harvest model”, where the model is (annually) updated when additional data or even completely new sets of data (e.g. helicopter counts) become available.
In line with this statement, I will recommend to DJPR that a workshop with stakeholders is conducted later this year to discuss the model after its first year in operation. This would be a valuable opportunity to explore possible options for new data inclusions that may further build the foundation of the model output. Any ideas could then be provided to the model’s developers for assessment on whether particular data sets can be added to improve the reliability of the model.
In regards to the GMA Board’s decision process I would refer you to the comment in the report:
We advocate that the model here presented be used as a tool to inform decision making for hunting arrangements; it should not be used to set hunting arrangements without due diligence.
The GMA Board accepted this report and in accordance with this advice, the GMA will conduct a due diligence approach to utilising the output of the KKM. This will entail the Board assessing all reliable data sets, including any provided by stakeholders, to test the model’s output. Key to this assessment will be considering whether the weight of data supports the output of the model.
In the move to an AHM, it is important to understand the GMA’s role. Action 3.2 of the Victorian Government’s Sustainable Hunting Action Plan 2021-2024 (SHAP) commits to identifying a sustainable harvest window (ceiling and floor) and the development of a harvest framework and strategy. The DJPR will lead these processes and once harvest objectives have been established, the GMA will be responsible for data collection, analysis and oversight of the population model (with the guidance of an expert technical panel). The GMA does not set the policy framework.
I understand that DJPR will establish a stakeholder working group to progress these processes. Through this approach, a clear understanding will emerge of the harvest objectives, mechanics of AHM, the data sets to be used and the timeframes required to collate sufficient data. Sufficient data is critical to ensuring that the AHM is ready to be implemented.
Please let me know if you have any further questions.
Kind regards,
Graeme Ford | CEO
Game Management Authority
