Nomination Form for listing a key threatening process under the Environment Protection and Biodiversity Conservation Act 1999 (epbc act)




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Table 5: Numbers of baits removed by different species Source: Glenn and Dickman (2003a)


Species


Number of takes

Spotted tail quoll (Dasyurus maculatus)

49 (46.2%)

Small mammals

14 (13.2%)

Unknown

13 (12.3%)

Australian brush turkey (Alectura lathami)

12 (11.3%)

Wild dog (Canis lupus)

9 (8.5%)

Red fox (Vulpes vulpes)

7 (6.6%)

Superb lyrebird (Menura novaehollandiae)

2 (1.9%)

Another survey carried out by Glenn and Dickman (2003b) indicated similar results. This study observed two factors – the take of bait by different species and the difference in the take of bait buried in the ground surface and buried in raised mounds. Again the results show that a large majority of baits were taken by tiger quolls. Furthermore results indicated that even though less tiger quolls took baits buried under ground surface than baits buried in raised mounds, the majority of baits from under ground surface were still taken by tiger quolls. Table 6 shows these results.




Table 6: Numbers of baits removed from bait stations by different species

Source: Glenn and Dickman (2003b)




Species


Mound


Flat


Total

Spotted tail quoll (Dasyurus maculatus)

33

13

46

Small mammals

11

3

14

Unknown

7

5

12

Wild dog (Canis lupus)

6

6

12

Red fox (Vulpes vulpes)

4

0

4

Superb lyrebird (Menura novaehollandiae)

2

0

2

Australian brush turkey (Alectura lathami)

1

0

1

Total

64

27

91

Number of bait nights

341

318

659

Glenn and Dickman do not discuss the density of different species in the area of the study, so it can not be determined whether feral species were more or less abundant than quolls at the time. However the study was carried out in the Upper Hunter Valley of NSW (Fosterton and Chichester State Forests), which is an area known to experience a relatively abundant population of foxes and feral dogs.


Regardless, the results of Glenn and Dickman’s studies (2003a and 2003b) leave no doubt that there is a high potential for significant numbers of baits to be removed by non-target species, particularly quolls.
Adding to this evidence is a study by Murray and Poore (2004), using baits injected with a non-toxic baitmarker, Rhodamine B. Murray and Poore (2004) found that out of the 16 tiger quolls subsequently captured, 10 had Rhodamine B in their vibrissae. Furthermore aerial baiting trial with non-poisoned fresh and 70% dried meat baits found that 67% and 33% respectively of the quoll population consumed one or more baits (Belcher 2000; Murray et al. 2000; XXXX XXXX in prep.).
Also notable were observations in Glenn and Dickman’s (2003b) survey of quolls taking multiple baits and moving 800-1200 m between bait stations. Glenn and Dickman (2003b) concluded by saying that while some quolls may survive the dose of 1080 contained in a single foxoff bait (based on a bait containing 3 mg 1080 and sensitivity data in McIlroy 1981b) the chances of survival after consuming more than one bait is highly unlikely.
The level of risk to quolls from 1080 baiting depends on the amount of 1080 ingested, the size of the animal, and the palatability and accessibility of baits to Quolls. The higher tolerance of tiger quolls to 1080 is offset by the smaller body size than dogs and foxes (McIlroy 1981), and a dose of 3-4.5 mg ingested from a single bait is potentially lethal to juvenile, many female and some male Quolls (Murray 1998; Belcher 2000b). A large male animal consuming two baits (ingesting 6-9 mg of 1080) within a short period is also potentially at risk. Baits for wild dogs typically contain 6 mg of 1080.
According to Belcher (2000b) a large male quoll captured in south-eastern NSW several days after a nearby area was aerially baited for dogs displayed symptoms of 1080 poisoning. It died soon after and subsequent tissue analysis found 1080 present.
Murray (1998) also states that due to the limited reproductive ability of tiger quolls, even the loss of a few animals from poisoning is likely to be significant for small populations.
Finally, in the study by XXXX XXXX (in prep) “the results indicate that aerial baiting can have an immediate, substantial impact on populations of D. maculatus and that the impact may last for more than four years after baiting”.
This threatening process could cause the tiger quoll to become eligible for listing in another category representing a higher degree of endangerment, under the EPBC Act, particularly when considering the eastern states are shifting back towards highly indiscriminate aerial baiting to deploy 1080 and doing so in this species’ habitat.
Spot-tailed quoll, spotted-tail quoll, tiger quoll (Dasyurus maculatus maculatus – Tasmanian population)
This population is listed as vulnerable under the EPBC Act. In the advice to the Minister for Environment and Heritage on listing this species as vulnerable under the EPBC Act the TSSC (2004) stated, “1080 poison baiting programs may play a significant role in localised population declines to the extent that local populations may decline rapidly to extinction”.
The TSSC (2004) considers the threat of 1080 baiting to the southeast mainland population to also apply to the Tasmanian population. Research carried out on the southeast mainland population of the tiger quoll indicates that the Tasmanian population is potentially at risk from 1080 baiting in Tasmania. The recent intensity of fox baiting in Tasmania has serious implications for the Tasmanian population of D. maculatus maculatus (in the six months to December 2004, 18,000 1080 baits for foxes were laid over 300,000 to 35,000 ha (TAS DPIWE (in Paine 2005)) and during July, August and September 2005, 8,060 1080 baits for foxes were laid. This eradication program is expected to continue (Department of Primary Industries, Water and Environment 2005)).
According to the Nature Conservation Branch (undated) of the Department of Primary Industries, Water & Environment (Tasmania) “Application of any poisons in insecticides or meat baits” is a “key threat” to the tiger quoll.
Data on the potential impact of 1080 baiting on this population of the tiger quoll is limited, so the nominator can not provide any further information.


  1. Evidence that the threatening process adversely affects two or more listed threatened species (other than conservation dependant species):


Tiger quoll, spot-tailed quoll, spotted-tail quoll (Dasyurus maculatus maculatus – southeast mainland population):
Evidence presented under the previous criteria indicates that 1080 baiting is likely to have an adverse affect on the listed southeast mainland population of the tiger quoll. We note that the tiger quoll has a limited reproductive ability (Murray 1998). Thus, even the loss of a few animals from poisoning is likely to be significant for small populations (Murray 1998).
Spot-tailed quoll, spotted-tail quoll, tiger Quoll (Dasyurus maculatus maculatus – Tasmanian population)
Evidence presented under the previous criteria indicates that 1080 baiting is likely to have an adverse affect on the listed Tasmanian population of the tiger quoll. We note that the tiger quoll has a limited reproductive ability (Murray 1998). Thus, even the loss of a few animals from poisoning is likely to be significant for small populations (Murray 1998).

Other Species at risk:
Data on the impact of 1080 on other listed species is very limited or absent, however there is enough indication to note that there may be a further range of threatened species adversely impacted by 1080.
Long-nosed potoroo (Potorous tridactylus tridactylus – southeast mainland population)
This species is listed as vulnerable under the EPBC Act. According to XXXX XXXX (unpublished) this species is known to take 1080 baits and is also known to be killed by them. Studies carried out by McIlroy (1982) found that long-nosed potoroos are more sensitive to 1080 poison than rabbits. McIlroy states, “because of the greater susceptibility to 1080 of this group than of rabbits, rabbit poisoning campaigns should be avoided in areas which contain these non-target species [long-nosed potoroos]”.
McIlroy also notes anecdotal evidence that long-nosed potoroos are killed during rabbit baiting campaigns (XXXX XXXX pers comm.1979 and XXXX XXXX pers comm. 1981) and states “long-nosed potoroo …will readily eat carrot bait because their natural food is underground tubers and roots”.
The AVPMA (2005a) also states the “carrot baits are likely to be dangerous for potoroos”
Data on the potential impact of 1080 baiting on this species is limited, so the nominator can not provide any further information.
Northern quoll (Dasyurus hallucatus)
The northern quoll has recently been listed as endangered under the EPBC Act. While little research has been carried out to investigate the impact of 1080 on the northern quoll, studies done elsewhere in Australia have indicated very clearly that quolls can be heavily impacted by this control method.
There has only ever been one study carried out to determine the impact of 1080 on the northern quoll (Dr Scott Burnett pers. comm. April 2005). King (1989) radio-tracked a sample of northern quolls during a 1080 baiting campaign for wild dogs and found that all survived. However, King’s study was only carried out in Western Australia, where populations of the species are likely to have a higher tolerance to fluoroacetate than populations of the same species in eastern Australia. Northern quolls have all but disappeared from Cape York and no studies have been carried out to determine the possibility that 1080 has impacted upon the population in this area.
According to the Cairns and Far North Environment Centre (2005), the most common method of control of feral pigs and dogs in Cape York is aerial baiting with 1080 poison. Baiting for feral pigs requires an extremely high dose of 1080, of 75 mg, and the NSW Department of Primary Industries state, “a disadvantage of using 1080 is that it carries a high risk of non-target poisoning due to the large doses required to kill feral pigs”.
Thus the nominator feels that there is a possibility that 1080 baiting may have had an adverse impact on northern quoll populations in northeastern Australia and continue to.
Data on the potential impact of 1080 baiting on this species is limited, so the nominator can not provide any further information.
Spotted-tailed quoll or yarri (Dasyurus maculatus gracilis – North Queensland subspecies)
This species is listed as endangered under the EPBC Act. This subspecies species’ range is small and occurs around Cairns and Cooktown. No research has been carried out on whether 1080 baiting has an effect on the population, however studies done elsewhere in Australia have indicated that quolls are heavily impacted by this control method. Data on the potential impact of 1080 baiting on this species is limited, so the nominator can not provide any further information.
Wedge-tailed eagle (Aquila audax fleayiTasmanian population)
The Tasmanian population of this species is listed as endangered under the EPBC Act. It is difficult to determine whether 1080 baiting would cause this species to be eligible for listing in another category representing a higher degree of endangerment under the EPBC Act. However there is evidence to suggest that it is adversely affected by 1080.
Wedge-tailed eagles are known to take several baits at a time (Denny 2001). However, according to Denny (2001) the main difficulty in determining if the taking of the bait leads to death is the interval between ingestion of the bait and the onset of any signs of toxicity. McIlroy (1984) states that for birds the onset of symptoms can take as long as 60 hours, and death may not occur for 11 days. This may lead to incorrectly concluding that the taking of the bait does not lead to death.
There is anecdotal evidence that wedge-tailed eagles have died from eating carcases of animals poisoned with 1080 (Bell and Mooney 1998). Furthermore, according to Bell and Mooney (1998), indirect harm might occur from the reduction of the prey. According to Garnett and Crowley (2000) wedge-tailed eagles are known to die in Tasmania as non-target species during illegal poisoning of Tasmanian devils and forest ravens. Thus it is evident that 1080 certainly does have the ability to kill individuals.
Data on the potential impact of 1080 baiting on this species is limited, so the nominator can not provide any further information.
Australian Pesticides & Veterinary Medicines Authority (APVMA) 1080 Review
The APVMA (2005a) released preliminary findings from a Review on the use of 1080, in May 2005. According to the APVMA (2005b) the review was undertaken to address concerns over unintended effects on the environment through the poisoning of non-target animals. For example, it recommends the strengthening of label instructions and controls on the use of 1080.
Note: the findings from the APVMA Preliminary Review was released for public consultation on 23rd May 2005. Following the public consultation period these preliminary findings are being revisited to include assessments of the public submissions received. A final report has not yet been released. The APVMA’s recommendations do not have regulatory status at this time.
While we appreciate the APVMA Preliminary Review’s attempt to provide a greater margin of safety to minimise non-target species damage, we do not agree with the message expressed in the media that the Preliminary Review has determined that 1080 is ‘safe for the environment’. The APVMA (2005b) does claim “The initial review findings have highlighted that, with certain improvements, the APVMA can be satisfied that the continued use of 1080 is safe for the environment.” But the nominator has examined the Review and sees no substantiated evidence presented in it, to back up the conclusion that 1080 is ‘safe for the environment’. The Review merely provides recommendations such as, “meat baits need to be placed with great care in spotted-tailed quoll habitat as these animals are sensitive to 1080 and may be negatively impacted by poisoning”.
As mentioned in this nomination the Review recommends meat baits to be placed at a rate of 2 baits per km in tiger quoll habitat. However, studies have indicated that quolls will easily cover almost twice this range in one night. Glenn and Dickman (2003b) observed quolls taking 3-4 baits in one night from bait stations 400m apart (see previous section on tiger quoll in this nomination).
Besides this point, it is evident that 1080 baiting campaigns are in fact not carried out in line with this and many other guidelines proposed in the APVMA Preliminary Review. The nominator has detailed above a number of 1080 baiting campaigns in NSW that have deployed 30-40 baits per km in areas important for the endangered tiger quoll. While the APVMA Preliminary Review does not have any regulatory status at this time, it still provides initial review findings.
The APVMA (2005a) also proposes that carrot baits “should not be laid in areas where the presence of [potoroos] raises concerns”. However the nominator is aware that carrot baits are used in areas containing potoroo species particularly in Tasmanian and the southeast mainland. Indeed the listed long-nosed potoroo is known to be killed by 1080 baiting (XXXX XXXX unpub. and APVMA 2005a).
The APVMA (2005a) states that baits for pigs are “likely to be hazardous to birds of prey and goanas”, due to their high concentration. It states that baits must be “laid in the evening and recovered the next morning in order to avoid exposure of these diurnal feeders”. Aerial baiting for pigs is carried out in seasonally inaccessible areas on Cape York Peninsula and rugged parts of the Blue Mountains (APVMA 2005a). It is reasonable to say that in such inaccessible and rugged areas these baits would not be sufficiently monitored.
Considering that in many cases these guidelines and recommendations are not followed, the APVMA cannot come to the conclusion that 1080 baiting is “safe for the environment”.
Recent 1080 baiting trials carried out by the NSW Department of Environment & Conservation and the Queensland Department of Natural Resources & Mines
The NSW Department of Environment and Conservation (DEC) and the Queensland Department of Natural Resources and Mines (DNRM) concurrently carried out studies on the impact of 1080 baiting on the tiger quoll. The DEC conducted field experiments in northern NSW in 2004 and 2005 and in southern NSW in 2005 (see Kortner and Watson 2005), and the DNRM carried out their studies in southern Queensland between 2002 and 2005.
The preliminary results of this research have been discussed by the DEC (2005). In NSW at least one quoll was found to have died of 1080 poisoning and in the Queensland at least two quolls died of 1080 poisoning. The DEC (2005) notes that further analysis is needed and admits that “even a few deaths caused by aerial baiting may have a significant impact on a small population of quolls that has already been weakened by factors such as drought, habitat fragmentation or disease. It is also possible that 1080 may have other impacts on quolls that survive after eating baits – such as infertility and birth defects.”
Despite this, the NSW Government has been using these preliminary results to justify the reintroduction of large-scale 1080 aerial baiting in Kosciusko in the Adaminaby and Yaouk areas in 2004 and 2005, without any environment assessment.
The nominator believes it is highly premature to use these results to conclude that 1080 has a low impact on the tiger quoll.
Inquiry into the impact on agriculture of pest animals, House of Representatives Standing Committee on Agriculture, Fisheries & Forestry
In 2005, the House of Representatives Standing Committee on Agriculture, Fisheries & Forestry conducted a Parliamentary Inquiry into the impact on agriculture of pest animals. The Inquiry touched on the issue of 1080 baiting in the control of pest animals. A final report on the Inquiry was released in November 2005 (House of Representatives Standing Committee on Agriculture, Fisheries & Forestry 2005) (the report).
The report notes that views are opposing on whether 1080 impacts on non-target species. It then refers in relative detail to limited evidence that might indicate that 1080 does not have an impact on quolls, but fails to mention in similar detail, the greater number of studies that have indicated that 1080 has an impact on quolls and several other native species. The nominator considers the report partial to the use of 1080 poison in the control of pest animals.
The report makes particular note of preliminary findings from research carried out by the NSW DEC and the Queensland DNRM, whereby “quoll mortality rates from 1080 are much lower than previously thought”. As discussed above, the nominator believes it is premature to use these preliminary findings to conclude that 1080 has a low impact on quolls, particularly when the south east mainland population of the tiger quoll is becoming increasingly threatened.
The report discusses the APVMA 1080 Review (2005a) and states “The review found that, although 1080 can have an impact on individual non-target animals, it does not have an impact at the population level.” This comment is highly misleading. Nowhere in the APVMA Review is the statement that 1080 does not have an impact at the population level. Rather, the APVMA Review (2005a) admits that 1080 can in fact have an impact on populations and states “…trapping results indicate substantial reductions in tiger quoll populations after aerial wild dog baiting.” As a result of the APVMA Review’s findings, they stress, Do NOT exceed 2 baits per km in locations where carnivorous native mammals are active”.
In the report the Committee recommends that 1080 must remain available to landholders to control pest animals despite stating that there are unresolved issues in terms of opposing conclusions in relation to its impact on non-target species. It also recommends that the Australian Government reconsider its commitment to phasing out the use of 1080 poison in Tasmania.
The nominator utterly rejects the report’s recommendations. The recommendations rely heavily on the insistence by landholders and organisations that 1080 is a convenient method of pest animal control. The report does not adequately address the environmental concerns surrounding 1080 use and does not provide any scientific assessment or analysis on whether 1080 has an impact on non-target species. Nor does it consider the precautionary principle. While the report discuses other methods of feral animal control, such as trapping and fencing, it does not consider alternatives to substitute the use of 1080 baiting.
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