Submission to : Review of the proposed Land Protection (Pest and Stock Route Management) Regulation 2002 |
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SUBMISSIONSubmission to : Review of the proposed Land Protection (Pest and Stock Route Management) Regulation 2002 From: Foundation for a Rabbit – Free Australia Inc. Prepared by: F Bartholomaeus and W Morgan Date: 3rd June 2002 |
Abstract: The Foundation is opposed to :
and believes that this position is strongly supported by the available scientific evidence, including information from the introduction of the myxoma virus and the more recent release of RCD. Background The Foundation for a Rabbit-Free Australia is an independent body, which was set up in 1991 to support rabbit research and to promote community awareness of the rabbit problem. Through the RFA, concerned people can donate money directly to rabbit research. Although based in South Australia, we are a national organisation. Accordingly we are stakeholders to this review, as outlined in the issues paper. Cost of rabbit damage to primary production and the environment A first step in justifying legislative restrictions on rabbit keeping and breeding is to briefly quantify the costs of rabbit damage and rabbit control as a whole. The annual cost of rabbit damage in Australia has been estimated to be at least $200 m (Bomford and Hart, 2001) or even up to $600m (Acil Economics1996). Rabbit costs to the environment continue when rabbit numbers are very low; regeneration can be prevented by rabbits few enough to go undetected (Lange and Graham 1983, Henzell pers. comm.). Rabbit farming is characterised by large capital outlay, small returns and endemic disease problems. At the moment most rabbit farms are run by part-time or hobby farmers, with a small proportion of full-time rabbit farmers (Hubbard pers. comm.). Margins are so slim that a rabbit grower requires at least 200 breeding does to make a profit, even when returns are maximised by good management and feed costs minimised (O'Brien 2001). Returns from breeding rabbits for meat may also be restricted by the current meat hygiene regulations, which make it very expensive to set up a processing plant. Use of a permit system for rabbit farms would restrict viability even further. Throughout Australia, farmed rabbit production in 1998-99 was 106t of meat from 84,000 rabbits, after about 500 permits had been issued. Only about a quarter of these were classified as commercial. The wild rabbit trade was valued at approximately $2.5m in the early ‘90s before the advent of RCD (McInnes, 2001). The export market for all rabbit products in 1999 (Saunders and Kay) was valued at less than $50,000 per annum. Even if the rabbit industry were to grow significantly, and the wild rabbit population recover from RCD, benefits of the rabbit trade are far outweighed by the costs of the rabbit to Australia. Biological control and vaccination of rabbits Disease is very costly to a commercial venture, and distressing to pet owners. Relaxation of the regulations would surely lead to agitation for the use of live vaccines such as Shope’s fibroma, which could escape into the wild rabbit population. Vaccination of rabbits is very expensive; in 1999 a single RCD vaccine cost between $3 - $5 in 1999, without vet fees. Such costs make it a certainty that commercial rabbit breeders and pet owners will oppose the introduction of any new or modified biological control for the rabbit. The Pest Animal Control CRC is currently working on modified viruses to transmit immunocontraception. Future biological control agents for the rabbit are anticipated. Relaxation of regulatory control could contribute to a public & business perception that rabbit control threatens a valuable industry, although it may be small compared to the industries damaged by the rabbit. To specifically address the restrictions to trade cited in the issues paper: Restriction 1. Prevents the breeding, selling and keeping of domestic varieties of rabbits as pets and entry into the ancillary business activities. Comments on arguments supporting restriction: We agree that allowing pet rabbits is likely to jeopardise biological control programs. Likely examples include the use of live myxoma vaccine, which could confer resistance to wild rabbits. Breeders may try to breed immune rabbits, which if successful could spread into wild population. Pet rabbit owners are also likely to be a vocal and emotional opposition to any new biological controls, in particular the immunocontraceptive controls already under investigation. The establishment of feral rabbit populations from accidental or deliberate releases has occurred in the past, with domestic breeds surviving and reverting to wild type. Allowing rabbits as pets promotes, in our opinion, the wrong attitude towards rabbits. Public perceptions of rabbits still err on the "cute and cuddly" side, despite campaigns such as the Easter Bilby, and many recent appearances of native Australian animals in popular culture. Comments on arguments supporting deregulation: The expected increase in the pet trade could bear investigation. The increase may not be very great, particularly if an illegal trade already exists as in South Australia before deregulation, where some very expensive cages were apparently sold with free rabbits inside. Alternative pets can be found for most circumstances. For example, dogs are far more responsive than rabbits, and guinea pigs are as easy to keep. While the keeping of domestic pigs and goats is permitted, these animals are larger and more conspicuous than rabbits, and would be easier to contain and recapture. Wild, feral and domestic cats cause enough environmental damage that using them as a justification for keeping rabbits is illogical. Using a permit system based on real costs as an alternative to the current prohibition would be hard to administer, and would impose extra costs on small businesses. Restriction 2: Prevents the breeding, selling and keeping of rabbits for commercial purposes including meat or fur production. The same arguments apply to commercial rabbit farming as to the keeping of rabbits as pets. Accidental release of commercially farmed rabbits is unlikely (Williams et al, 1995), but is still a risk, particularly in local eradication areas. Deliberate release from a failed enterprise has occurred before, leading to the presence of feral turkeys on Kangaroo Island. As mentioned previously, commercial rabbit farmers are likely to form pressure groups to protest the release of novel biological controls, and to agitate for vaccines and resistance breeding. Restrictions 3 & 4: Limitations on which exotic animals are allowed in Queensland in comparison with other jurisdictions, for example, in theme parks, zoos and circuses, and on who is allowed exotic animals in Queensland, other than in theme or wildlife parks, zoos and circuses. The Foundation opposes the keeping of rabbits in zoos, theme parks and circuses, chiefly due to the same public perception issues relevant to the keeping of rabbits as pets. Conclusion We believe that the potential benefits of deregulating the keeping, breeding and trading of rabbits are far outweighed by the potential economic and environmental costs of any increase in rabbit numbers or decrease in rabbit control efforts. References Acil Economics and Policy Pty Ltd (1996). The economic importance of rabbits on agriculture production in Australia. Report prepared for the International Wool Secretariat. Bomford, M. and Hart, Q. (2001). Non-indigenous vertebrates in Australia. In Pimental, D. (ed.) Environmental and Economic Costs of Alien Plant, Animal and Microbe Invasions. CRC Press. Hubbard, D. PIRSA Rural Solutions, SA. Lange, R.T. and Graham, C.R. (1983). Rabbits and the failure of regeneration in Australian arid zone Acacia. Aust. J. Ecol. 8:377-81. McInnes, P. (2001). Farmed rabbit – the industry and research. In: Proceedings of Rabbit Control Forum – the next 50 years. BRS/ CSIRO/ Pest Animal CRC. Saunders, G and Kay. B (1999). Rabbit Calicivirus Disease Program Report 5: Implications for Agricultural Production in Australia. Prepared for the RCD Management Group. Bureau of Rural Sciences, Canberra. Williams, C.K., Parer, I., Coman, B.J., Burley, J. and Braysher, M.L. (1995). Managing vertebrate pests: Rabbits. Bureau of Resource Sciences/CSIRO Division of Wildlife and Ecology, Australian Government Publishing Service, Canberra, p99. |