The TCT recently made a submission on the Draft Proposal and Environmental Management Plan (DPEMP) for translocation of the Tasmanian devil to Maria Island National Park. Below is the content of the submission.
1 Mitigation strategies
As part of the DPEMP, the Save the Tasmanian Devil Program (STDP) has provided a document, ‘Environmental Risk Assessment – Impact of the introduction of Tasmanian devils to Maria Island on the natural values of the island’ (2007) which clearly outlines the potential significant impact that the introduction of Tasmanian devils may have on a range of threatened species and built heritage values found on Maria Island; however, it has failed to demonstrate that these impacts can be effectively mitigated.
Until a comprehensive mitigation strategy is developed, the TCT does not support the proposal to translocate Tasmanian devils to Maria Island.
The STDP risk assessment identifies the following potential impacts on threatened species and built heritage:
· competition between wedge-tailed eagles (Aquila audax fleayl) and devils for food
· the proliferation of rats, due to devils decreasing feral cat population, resulting in an increase of rats preying on swift parrot (Lathamus discolor) and the forty-spotted pardalote (Pardalotus quadragintus) chicks;
· damage to World Heritage listed-buildings by denning devils.
We acknowledge that there is considerable uncertainty regarding the type and scale of impacts and whether some will be negative, but this uncertainty is normal with translocations and does not in any way negate the need for a mitigation strategy. Mitigation measures need to be planned in the event that rats proliferate, the food supply of wedge-tailed eagles is affected or devils occupy historic buildings.
The mitigation measures also need to be assessed to ensure they do not have a negative impact on threatened species (in particular, if poisoning of rats is recommended); significant impacts on EPBC Act listed species may require later referrals to the Australian Government.
One of the few suggested mitigation measures to prevent devils impacting on listed species is that critical habitat for species such as ground-nesting birds can be fenced, or ‘otherwise protected’ if fencing is impractical. No details are given about the type of fencing, how and when it will be erected and maintained. Fencing will not prevent rats preying on swift parrot and forty-spotted pardalote chicks. Where fencing is not effective, no other measures are proposed. Mitigations strategies need to be precautionary and pre-emptive, as the exact impact of most developments is not known.
- The TCT recommends that the STDP produce a comprehensive mitigation strategy, make it available for public comment and refer it to the Australian Government for assessment prior to proceeding with translocation of devils to Maria Island.
- Recommendation: To test assumptions and assist with refining the mitigation strategy, the STDP should consider a trial of introducing devils (either desexed or all the same gender) and study the movements, habits and impacts, or consider conducting ‘an island on an island’ trial in which devils are fenced in a certain area and monitored.
2 Management of Tasmanian devils on Maria Island
The DPEMP (p. 10) states that Maria Island was identified as ‘likely’ to be a successful translocation site from a devil perspective and based on maximising population size and minimal management. The TCT is concerned that there is no mention of the predicted carrying capacity for devils on Maria Island and that no other islands have been investigated as a potential translocation site for disease-free devils.
The DPEMP (p. 10) states that food supplication may occur on initial release. It provides no details of how the food will be distributed to devils or in what quantities. It is expected that the devils will disperse once they are placed on the island. What processes will be put in place to ensure devils in more remote areas are receiving adequate supplementary food? The DPEMP makes no mention of any mitigation strategy to deal with drought conditions on Maria Island. Will devils be given supplementary water during times of drought?
The DPMEP (p. 12) states that ‘devils selected as founders for the proposed translocation will be assessed according to temperament and likelihood of interacting with people’. How is it possible to predict whether a devil is likely to interact with humans, especially if it is hungry?
The DPEMP states on page 13 that, ‘should monitoring indicate that devils are responsible for unacceptable adverse impacts to listed species or to the Maria Island ecology or values, then devil numbers may be reduced (through trapping and removal) and animals relocated to other aspects of the conservation effort’. How successful will trapping be, given that devils are difficult to catch? What are the ‘other aspects of the conservation effort’ and will some devils be euthanased if they are not required for other aspects of the program or are not healthy enough? If euthanasia is considered as an option, it should be acknowledged in the DPEMP and a strategy should be provided for dealing with the expected and justifiable public concern.
The TCT has concerns about the funding of the proposed translocation project. Given that federal funding for the STDP ends next year and that PWS has a restricted budget, how will ongoing monitoring of devils be financed? Relying on volunteer assistance from individuals is not sufficient. Failure to provide adequate funding would limit the DPIPWE’s capacity to manage devils and implement mitigation strategies.
Recommendation: The TCT suggests that the DPEMP be amended to include further details regarding:
- predicted carrying capacity for devils on Maria Island
- food supplementation for devils who inhabit remote areas and provision of water during periods of drought
- temperament checks of devils prior to release so there is a greater assurance of low interactions with visitors to Maria Island
- trapping and removal methods including a protocol for euthanasia and the consequent public relations issues this will raise
- the level of resources required for management of the translocated devil population, the level of resource likely to be available and plans for dealing with a funding/resource shortfall.
3 Devil Facial Tumour Disease status of Tasmanian devils
The DPEMP (p. 10) states that ‘up to fifty Tasmanian devils will be selected and screened prior to introduction for suitable behaviour traits and genetic suitability for introduction to the island. They will undergo comprehensive health checks to minimise the risk of introducing novel pathogens or parasites to Maria Island as well as any weeds, pests or other disease’.
The DPEMP fails to explain how the devil facial tumour disease-free status of the animals will be determined. This is totally inadequate as guaranteeing disease-free animals is the critical factor in the success of the translocation of devils and one slip-up will endanger the entire translocation effort.
A recent event in which a Tasmanian devil raised by the Devils in Danger Foundation contracted DFTD (‘Blow to Rescue Plan’, Examiner 24 April 2012) raises concerns about the effectiveness of testing for the disease and the likelihood of it being introduced to Maria Island, especially as the number of devils introduced increases.
Recommendation: The TCT believes that the proposed translocation of devils to Maria Island should be held off until the STDP can demonstrate, with the maximum possible certainty, that DFTD can be tested for and identified in devils and that any animals that are not proven to be disease free are excluded from the translocation program.
4 Independent oversight of translocation program
The DPEMP makes no mention of independent assessment and review of the research and monitoring associated with the translocation of devils to Maria Island. Nor is there any mention of any broader oversight by the general public. Given that the proposed translocation involves significant uncertainties and risks in terms of environmental impacts, survival of devils and controversial methods (e.g. euthanasia of devils) the STDP should actively involve outside scientists and the community. We suggest that this and greater transparency can only assist with the success of the project.
Recommendation: Assuming that the STDP can produce a DPEMP that satisfies the concerns mentioned above, we suggest that two oversight committees be formed to assist the STDP to implement the program; one consisting of independent scientists and one representing general community interests.
The TCT understands and appreciates the importance of ensuring that the Tasmanian devil is not wiped out by Devil Facial Tumour Disease and the critical role that insurance populations play in achieving this goal, but we have grave concerns about the translocation of devils to Maria Island both in terms of the impact that devils may have and their survival on the island.
It is disappointing that, given all the time and resources the STDP has had to come up with appropriate ways of managing devils, they are now rushing to translocate them to Maria Island without appropriate plans in place.
In its current form, the TCT does not support the proposal to translocate Tasmanian devils to Maria Island.
To date, no final decision has been made about the translocation of Devils to Maria Island. The latest newsletter from the Save the Tasmanian Devil Program reports that, if the DPEMP is approved, then the project would be implemented this year, but it will depend on resources, including the availability of staff.