As we did for Victoria, here’s our submission to South Australia’s proposed changes to its ‘wild dog’ and dingo policy (organised again by the relentless and venerable Dr Kylie Cairns):
© Jason Edwards Photography
14 April 2020
The Honourable Tim Whetstone MP, Minister for Primary Industries and Regional Development, South Australia
- cc: The Honourable David Speirs MP, Minister for Environment and Water, South Australia
- cc: Primary Industries and Regions South Australia
- cc: Dr Bradley Page, PIRSA Wild Dog Program
RE: PROPOSED CHANGES TO THE SA WILD DOG AND DINGO POLICY
Dear Minister,
The undersigned welcome the opportunity to comment on the proposed changes to the South Australian (SA) Government’s ‘Wild dog and Dingo’ declared animal policy under section 10 (1)(b) of the Natural Resources Management Act 2004. The proposed changes raise serious concerns for dingoes in SA because it:
1. Requires all landholders to follow minimum baiting standards, including organic producers or those not experiencing stock predation.
- Requires dingoes within Ngarkat Conservation Park (Region 4) to be destroyed, with ground baiting to occur every 3 months.
- Requires ground baiting on land irrespective of whether stock predation is occurring or not, or evidence of dingo (wild dog) presence.
2. Allows aerial baiting of dingoes (aka wild dogs) in all NRM regions – including within National Parks.
3. Uses inappropriate and misleading language to label dingoes as “wild dogs”
We strongly urge the PIRSA to reject the proposed amendments to the SA wild dog and dingo policy. Instead the PIRSA should seek consultation with scientific experts in ecology, biodiversity and wildlife-conflict to develop a policy which considers the important ecological and cultural identity of the dingo whilst seeking to minimise their impact on livestock using best-practice and evidence-based guidelines. Key to this aim, livestock producers should be assisted with the help of PIRSA to seek alternative stock protection methodology and avoid lethal control wherever possible. On the balance of scientific evidence, protection of dingoes should be enhanced rather than diminished. Widespread aerial baiting programs are not compatible with the continued persistence of genetically intact and distinct dingoes in SA.
In this context, we strongly emphasize the following points:
- There is mounting and compelling evidence that indiscriminate baiting exacerbates livestock predation by fragmenting and destabilising dingo family groups such that remaining members intensify attacks on livestock. Baiting rarely, if ever removes all dingoes.
- The negative ecological consequences of lethal control of dingoes could seriously harm the biodiversity, resilience and health of SA’s ecosystems.
- Increased lethal control of dingoes in SA is likely to facilitate increases in mesopredator (cat and fox) and herbivore (kangaroos, feral goats, feral pigs, etc.) populations that are currently managed as pests. This will in turn threaten livestock production through the spread of disease by cats (e.g., toxoplasmosis, which can cause abortion in livestock), increased fox populations (which pose a significant risk to lambs), overgrazing by non-stock animals (e.g., kangaroos), and suppress populations of native, threatened species.
- The extent and intensity of lethal control appear disproportionate to the relatively small scale of the threat dingoes pose to farm stock in SA. Landholders should be supported to seek new measures of stock protection including electric fencing, livestock guardian animals, changes to animal husbandry, etc. before resorting to lethal control.
- Non-lethal forms of farm stock protection (e.g., the use of guardian dogs and strategic fencing) have not been adequately supported and trialled as an alternative to lethal control. Lethal control should be targeted, evidence-based, and balanced against the need to maintain ecological resilience and animal welfare. Further, there is considerable evidence that haphazard, broad-scale baiting can actually make conflict with livestock producers worse (Allen & Gonzalez 1998; Allen 2015).
- Continued use of the terminology ‘wild dog’ is not justified because wild canids in Australia are dingoes and dingo hybrids, not feral domestic dogs. In SA the dingo population is predominately pure. The proposed eradication and aerial baiting measures threatens the genetic integrity of dingoes in SA.
- Lethal control of dingoes should not be undertaken without culturally appropriate consultation with the First Peoples of Australia, some of whom consider dingoes to be a totem animal, having thousands of years of association with them.
- The use of Aerial baiting north of the dingo fence does not have any scientific justification and sets a dangerous precedent. Many of South Australia’s threatened mammals still hang on in these areas where dingoes are present and an increase in intensity and frequency of baiting is likely to trigger trophic cascades that will be detrimental to their persistence. There are no triggers listed for commencement of aerial baiting and no justification for its use.
Inappropriate use of the term “wild dog” when referring to dingoes
First, we wish to strongly highlight that the terminology “wild dog” is not appropriate when discussing wild canids in Australia. Furthermore, using the term “wild dog” misleads the public about the identity of dingoes being killed in SA. One of the main discussion points at the recent Royal Zoological Society of NSW symposium ‘Dingo Dilemma: Cull, Contain or Conserve’ was that the continued use of the terminology “wild dog” is not justified because wild canids in Australia are predominantly dingoes and dingo hybrids, and not, in fact, feral domestic dogs.
In SA, Stephens et al. (2015) observed that none of 165 wild canids sampled was a feral domestic dog. This same study determined that 82% of wild canids in SA were pure dingoes with no detectable dog ancestry and the remaining 18% of animals were estimated to be dingo hybrids with greater than 75% dingo ancestry. Ongoing research on the genetic identity of dingoes has identified geographic bias in previous ancestry estimates in Ngarkat Conservation Area (SA) and that instead of being 75% hybrids these animals are a unique lineage of pure dingo with no detected dog ancestry based on over 250,000 genome-wide markers (K. Cairns, personal communication). The dingoes in Ngarkat Conservation Park and surrounding regions in SA need to be protected as a unique and distinct population, not subjected to “virtual eradication”, as they are an endemic locally adapted lineage.
The proposed SA wild dog policy is not evidence-based
As prominent researchers in predator ecology, conservation, threatened species recovery, biology, archaeology, cultural heritage, social science, humanities, animal behavior and genetics, we emphasize the importance of dingoes in Australian, and particularly SA ecosystems. The dingo is a keystone species that benefits small animals and plant communities by suppressing and changing the behaviours of mammalian herbivores and smaller predators (including introduced foxes and feral cats) (Johnson & VanDerWal 2009; Wallach et al. 2010; Letnic et al. 2012, 2013; Newsome et al. 2015; Morris & Letnic 2017). Their presence adds a stabilising influence and provides ecosystem resilience for species only found in Australia.
We are pleased that the SA Government recognises the ecological importance of dingoes; however, this is incongruous with the proposed eradication of dingoes south of the dingo fence. The proposed mandatory baiting densities/frequencies (south of the dingo fence) and extension of aerial baiting (across the state) is not in keeping with scientific advice to maintain healthy dingo populations across the landscape and will ultimately be counterproductive to livestock producers.
Dingoes provide a net benefit to landholders (particularly those with cattle) by supressing kangaroo, pig, wombat and goat abundance (Pople et al. 2000; Letnic & Koch 2010; Letnic et al. 2012; Allen 2014, 2015; Moseby et al. 2019), thereby increasing pasture productivity. Kangaroos cost landholders more money than dingoes (Allen et al. 2015) and introducing widespread aerial baiting north of the dingo fence will likely result in lower productivity through an increase in kangaroo and goat abundance. The issues seen in South Australia from overabundant macropods and feral herbivores are not found north of the dingo fence but this is unlikely to continue if this policy is adopted.
Dingoes also provide positive ecosystem services in the form of supressing populations of introduced mesopredators such as foxes and cats that pose a significant risk to threatened species persistence (Johnson & VanDerWal 2009; Letnic et al. 2009, 2011; Moseby et al. 2012; Gordon et al. 2015; Morrant et al. 2017). Dingoes are the sole non-human land-based top predator on the Australian mainland, and their importance to the ecological health and resilience of Australian ecosystems cannot be overstated (Johnson & VanDerWal 2009; Wallach et al. 2010; Letnic et al. 2012, 2013; Newsome et al. 2015; Morris & Letnic 2017).
Dingoes only pose a marginal risk to cattle and baiting has been observed to increase calf losses (Allen & Gonzalez 1998). The net productivity and ecosystem benefits of dingoes substantially outweigh the limited risk that dingoes pose to livestock, risks that we believe are manageable with appropriate animal husbandry practices, non-lethal measures (i.e., livestock guardian animals and electric fencing) or targeted lethal control (shooting and trapping). What evidence does SA PIRSA have that livestock predation/damage has increased, to what extent has it increased and have landholders been assisted to explore non-lethal management strategies such as livestock guardian animals, electric fencing, changes in animal husbandry practices or use of targeted lethal control (trapping/shooting) to remove problem animals?
Widespread use of mandatory 1080 baiting will limit producers use of livestock guardian dogs and endanger working or pet dogs
Mandatory baiting densities and frequency south of the dingo (and in the proposed 35 km buffer zone) fence pose a substantial risk to owned domestic dogs on farms that may have an important role as livestock guardian dogs or stock management (herding) animals. Producers currently using livestock guardian dogs will have to cease using them as their animals will be at risk of consuming baits, either laid on the property or spread onto the property by birds and foxes (van Bommel 2010). Mandatory baiting therefore precludes SA producers from incorporating livestock guardian dogs stock protection on their properties and risks the poisoning of working or pet dogs on the property. This removes an important livestock protection and management tool from producers ‘toolbox’ No landholder should be forced to bait with 1080 on their land, particularly if it precludes them from using established best-practice measures of livestock protection such as livestock guardian dogs (van Bommel 2010).
Eradication of dingoes is not culturally acceptable or appropriate
The proposed policy is not culturally appropriate nor acceptable. The draft policy directly acknowledges the important role that dingoes play in Indigenous culture, however, seeks to eradicate dingoes from all landholdings (private, public or under native title) south of the dingo fence. This biased targeting of dingoes south of the fence does not protect unique populations of SA dingoes, many of which are south of the fence. Surveys of the public suggest that lethal management of dingoes is not widely supported (van Eeden et al. 2019, 2020) and do not fit with society expectations to protect and conserve the natural environment. Furthermore, the policy seeks to allow (and possibly force) aerial baiting across the state, including on APY lands. Has SA PIRSA sought consultation with APY landholders and other Indigenous cultural groups?
Conservation of dingoes in SA is not compatible with aerial baiting
We underline the importance of adequate protection of dingoes within SA ecosystems. Dingoes are an important keystone species. Aerial baiting poses a significant threat to the persistence and identity of dingoes by directly suppressing and destabilising dingo populations and increasing the risk of hybridisation with domestic dogs. Aerial baiting, in particular, breaks down pack structures and dramatically decreases dingo abundance across large regions (but almost never eradicates them); this increases the likelihood of hybridisation with roaming (or feral) domestic dogs and increases the spread of dog genes through the population via genetic bottlenecking. The SA dingo population is demonstrated to be of high genetic integrity, with infrequent evidence of domestic dog introgression (Stephens et al. 2015). There is also preliminary evidence that some dingo populations in SA are locally adapted and unique, deserving of protection as evolutionarily significant units (K. Cairns, personal communication).
Non-target species at risk by unnecessary aerial baiting and ground baiting
Bait consumption by non-target species is a significant concern. There is ample scientific evidence that non-target species such as corvids (crows), varinids (goannas), omnivorous or carnivorous marsupials such as quolls will consume 1080 baits (Glen et al. 2007; Körtner 2007; Buckmaster et al. 2014). In some studies, non-target consumption of 1080 baits was in excess of 80% (Allen et al. 1989; Moseby et al. 2011; Dundas et al. 2014; Kreplins et al. 2018). This poses an unacceptable risk to SA’s native fauna, who might consume baits and be poisoned. It also provides increased risk of pest species developing bait shyness and increased tolerance to 1080 when used indiscriminatory. The impacts of feral cats and red foxes are likely to be amplified in disturbed ecosystems, where dingo populations have been dramatically decreased, such as those being targeted by high-density aerial baiting. Cats in particular infrequently eat baits and a reduction in the number of larger predators is likely to result in a substantial increase in cat abundance.
This has the potential to negatively impact on ongoing threatened species recovery efforts. Indiscriminate and non-target specific lethal management should not be implemented if there is a risk to the persistence of threatened native fauna.
Signed:
- Dr Kylie M Cairns, Research Fellow, Centre for Ecosystem Science, School of Biological, Earth and Environmental Sciences, University of New South Wales
- Dr Katherine Moseby, Centre for Ecosystem Science, , School of Biological, Earth and Environmental Sciences, University of New South Wales
- Associate Professor Euan Ritchie, School of Life and Environmental Sciences, Deakin University
- Rob Appleby, Director, Wild Spy Pty Ltd
- Professor Peter Savolainen, KTH – Royal Institute of Technology, Department of Gene technology, CBH, Science for Life Laboratory, Solna, Sweden
- Dr Arian Wallach, Centre for Compassionate Conservation, University of Technology Sydney
- Dr Melanie Fillios, Archaeology, University of New England, Director, Australian Centre for Commensal and Domesticate research
- Dr Holly Sitters, School of Ecosystem and Forest Sciences,
University of Melbourne - Professor Benjamin N. Sacks, Veterinary Genetics Laboratory, Department of Population Health and Reproduction, School of Veterinary Medicine,
University of California, Davis, USA - Dr Justin W Adams, Biomedical Discovery Institute, Monash University
- Dr Clare Archer-Lean, Author of Iconic Dingo Report 2017, School Creative Industries, University of the Sunshine Coast
- Dr Bradley Smith, Central Queensland University
- Associate Professor Mathew Crowther, School of Life and Environmental Sciences, University of Sydney
- Professor Corey J A Bradshaw, Matthew Flinders Fellow in Global Ecology, Flinders University
- Lily van Eeden, School of Life and Environmental Sciences, University of Sydney
- Dr Angela Wardell-Johnson, Environmental Sociologist, Curtin University
- Dr Gabriel Conroy, Environmental Management Program Coordinator, University of the Sunshine Coast
- Dr Justine Philip, Environmental History and Ecosystem Management, Museums Victoria
- Professor Claire Wade, Chair of Computational Biology and Animal Genomics, School of Life and Environmental Sciences, University of Sydney
- Dr Neil R Jordan, Lecturer, Centre for Ecosystem Science, School of Biological, Earth and Environmental Sciences, University of New South Wales
- Dr Daniel Hunter, wildlife cinematographer, The Natural History Unit,
Victoria, Australia - Dr Sankar Subramanian, School of Science and Engineering, University of the Sunshine Coast
- Professor Chris Johnson, University of Tasmania
- Dr Benjamin Pitcher, Department of Biological Sciences, Macquarie University
- Dr Georgette Leah Burns, Environmental Futures Research Institute, Griffith University
- Associate Professor Steven Ogbourne, University of the Sunshine Coast
- Loukas Koungoulos, Department of Archaeology, University of Sydney
- Professor Chris Dickman, FAA, School of Life and Environmental Sciences, The University of Sydney
- Dr Thomas Newsome, Lecturer, The University of Sydney
- Dr Linda Van Bommel, School of Natural Sciences, University of Tasmania
- Dr Brian W. Davis, Professor of Genomics, Ecology and Evolutionary Biology, College of Veterinary Medicine and Biomedical Science, Texas A&M University, USA
- Dr Jennifer Carter, School of Social Sciences, University of the Sunshine Coast
- Dr Jack Tatler, Narla Environmental
- Dr Eloïse Déaux, Department of Comparative Cognition, University of Neuchâtel, Switzerland
- Dr Graeme Finlayson, Bush Heritage Australia
- Professor Mike Letnic, Centre for Ecosystem Science, School of Biological, Earth and Environmental Sciences, University of New South Wales
- Dr Rebecca Spindler, Bush Heritage Australia
