In late 2022, the Australian Federal Government sponsored a Working Group to write a proposal to deal with the growing number of deer in Australia. This is called the National Feral Deer Action Plan. The Plan specifically excludes recreational hunting and recreational hunters as a valid tool that can be utilised for control of deer populations, due to a variety of reasons. We highly recommend you follow that link, download The Plan, and read it yourself. The Working Group is open to submissions from the public, for ideas to include in The Plan.

The following is our submission.


Proposal to include Recreational Hunting


The Action Plan posits that recreational hunting, and recreational hunters by extension, are not suitable to be included due to two listed reasons; current populations are too high to be controlled by recreational hunting (pg 7) and that recreational hunting is in contrast with conservation best practices (pg 4), whilst recommending that recreational hunters become volunteer shooters (pg 13). With this, recreational hunting was not included in any of the listed actions. This submission aims to provide evidence that recreational hunting and hunters currently provide enough substantial deer population suppression to be considered a valid tool in the proposal and provide a framework of actions that include recreational hunting. I acknowledge the experience and expertise that the working group brings to the issue and appreciate that recreational hunting was at least acknowledged in the draft, however I believe that key points were overlooked.

Validity of ground-shooting

When looking at the effectiveness of recreational shooting, first the effectiveness of ground-shooting needs to be confirmed. The use of firearms can be highly effective in providing a clean kill if the user has chosen proper shot placement and using an appropriate calibre1, 2. This may be legislated, however when these requirements are not legislated, recreational deer hunters will self-impose rules dictating minimum requirements that would ensure an ethical kill3. Building on that, when proper objectives are defined, properly resourced, and used in suitable terrain, ground-based shooting operations can be used as a tool for reducing overabundant populations of undesirable wildlife4. When comparing the effectiveness of contract shooters to volunteer shooters (who whilst unpaid, are compensated via accommodation, fuel, and food, remaining a cost to the state compared to recreational hunters), the contract shooters cost the state 75% more than volunteers, with only a 55% increase in effectiveness when population reduction operations include paid contractors5. Effectiveness between contractors compared to their unpaid counterparts can be attributed to a number of factors outside of the volunteers or recreational hunters control, namely that contract shooters have access to tools, such as self-loading firearms and suppressors, to increase their success rate which cannot lawfully be possessed by recreational hunters5. I appreciate that this has been acknowledged in the Action Plan (action 1.6) and that the Plan will promote the use of firearm suppressors.

Contributions to the economy

The contributions to the national and local economies from recreational hunting shouldn’t be dismissed, as recreational hunters as opposed to volunteer shooters, receive no compensation but contribute to the economy. A 2014 nationwide survey on expenditures and motivations of Australian recreational hunters concluded that the average annual direct expenditure per hunter on hunting was $1,835, and indirectly $2,168, totalling an over $1-billion contribution to the Australian economy from hunting6. The annual contribution to the national economy was revisited in 2019-2020, estimating to be over $2.4-billion7. Just in Victoria alone, recreational hunting contributes approximately $365-million and 3,3138 jobs to the economy8. The economic impact of recreational hunters is an important factor, because where both contract and volunteer shooters have a cost per unit eradicated, recreational hunters have a contribution per unit eradicated6.


Validity of recreational hunting as a conservation tool

The report implies that recreational hunting is in contrast to management for conservation, indicating that recreational hunters should sign up to be volunteer shooters, however as pest management programs that utilised recreational hunters, in the role of a recreational hunter, have shown to be successful9. Hunting success can be tied to hunting effort, and recreational hunters who believe they are contributing to good conservation objectives are likely to exert more effort10. Hunting effort cannot only be increased via proper and reasonable objectives, however increasing the amount of active hunters increases both hunting effort and hunting pressure11. The number of recreational hunters nationwide is difficult to determine, however the Victorian Game Management Authority (Vic GMA) monitors the amount of individuals who hold a hunting licence annually. Over an 11-year period from 2009 to 2019, there was an annual increase of licence holders with a deer hunting endorsement of 7.9%, with an increase of licensed deer hunter numbers from 16,193 to 41,98512. This was increased to 49,857 in 2021, which signifies a jump of nearly 20% of recreational deer hunters in a 2-year period, and correlated with a 49% increase in deer harvest over the average since 200913.

Page 7 of the NFDAP says that current populations are too high to be controlled by recreational hunting or recent control efforts, whilst that may be true, the complete dismissal of the contribution of recreational hunting to deer population suppression should not be ignored. Victoria has an estimated 1,000,00014 deer, with approximately 3,000 of these being Hog deer (Axis porcinus)15. To the best of my knowledge, there is no published literature regarding the populations of other deer species. However, when robust population estimates are unavailable, recreational hunting harvest can be used as a demographic proxy16.

In 2021, Victorian recreational hunters harvested an estimated 118,874 deer of all species, which included an estimated 68,916 Sambar deer (Rusa unicolor), which was 57.97% of the total harvest13. This can infer that Sambar deer make up 57.97% of the 1,000,000 estimated deer in Victoria, totalling 579,739.89 (rounded to 579,740)13. This means that in 2021, recreational hunting harvested 11.88% of the Sambar deer population.

A study published in 2020 on the reproduction of Sambar deer in Victoria outlined an intrinsic rate of [population] increase (rm) using Lotka-Euler equations to be  between 15-24%, needing an annual anthropogenic mortality rate of 13-19% to maintain a stable population17. This means that recreational hunting of Sambar deer in Victoria takes 62-91% of the necessary numbers required to maintain a stable population. Understandably, this is below the threshold to induce a population decline, however it shows that recreational hunting contributes more than a statistically significant amount of population control necessary to be a contributing factor in this proposed Action Plan, and should therefore be included.


Concerns with carcasses and wild dog increases

A major concern with the exclusion of recreational hunters is to do with the surplus edible biomass that would be left behind by volunteer and contract shooters. No plan has been proposed in this Action Plan to deal with carcasses in any way, a concern as current procedures involving contract shooting are to leave it behind. Numerous studies on the diets of eutherian predators indicate that both wild dogs (Canis familiaris) and Red foxes (Vulpes vulpes) eat deer, sourced either from predation or scavenging18, 19. Current literature suggests that ease of access to deer carcasses may be contributing to the good health of wild dogs and encouraging successful litters20, with a commensal relationship having formed between wild dogs and anthropogenically produced deer carcasses21. Therefore, an increase in the short-term availability of this edible biomass caused by improper management of the killed deer will likely lead to an increase in wild dog numbers19. By including recreational hunters who have the knowledge, tools, skillset, and motivation, to take as much edible meat from the deer carcass as possible would be a step in the right direction towards mitigating undesirable invasive predator population increases, while making best use of an edible resource.


Actions for 2022-2027

As mentioned, it is the opinion of the Working Group that recreational hunting falls out of the scope of The Plan. Along with the evidence to show that recreational hunting can be a major contributor to deer population suppression, this submission has included a number of realistic objectives, with actions, outcomes, and performance measures by 2027. These will use alphabetical indicators rather than numerical, as they would change the ordering outlined in The Plan.



Performance Measure by 2027 (or earlier)

Goal 1: Stop the spread of large feral deer populations and reduce their impact

APPROACH: Increase awareness and capability

A.AA Promote use of recreational hunters going into areas of incursion for the purpose of pest control and meat harvest

Use of paying recreational hunters who acknowledge the need to take more than one deer increases.

Land managers willingly engage in recreational hunters as their first port of call, tally numbers and measure effectiveness annually

A.AB Promote the use of already implemented public access hunting opportunities, such as Victorian forest and NSW’s R-Licence state forest program.

More deer taken by recreational hunters who contribute to pest control and the economy on publicly owned land.

Annual comparisons of harvest on public land hunts, with new metrics including uptick in promotion of these opportunities

A.AC Promote the regulated use of recreational hunting in state controlled public access environments for the purpose of feral deer control.

State agencies/governments implement programs that allow recreational hunters into state owned environments to supplement control activities.

All state agencies wishing to improve their environmental deer impact strategies are taking steps to improve access (or begin to allow) by recreational deer hunters.

APROACH: National coordination and collaboration

A.AD Building on 1.9-1.11, establish an ‘opt-in’ program for land managers and recreational hunters that allow land owners to easily signal the need for pest control, which vetted (as outlined in Action 1.8) recreational hunters can signal they are available and can come do it

Impacts of feral deer are first addressed by land owners in a manner which benefits them the most, in a timely manner.

Use statistics measured every half-year.

GOAL 2: Control or eradicate small populations before they spread

APPROACH: Research and innovate new controls

A.AE Introduce a record keeping of the time between reporting of a new incursion and when a controller attends the reported area, specifying who attended (e.g. volunteer or contract shooter, government agent, recreational hunter).

An establishment of the effectiveness for the different types of response teams, which allows land managers to dictate their preferred type of response accordingly.

Half-yearly statistical analyses comparing the average response times of the various controllers.

APPROACH: Increase awareness and capabilities

A.AF Building on A.AE, publish the data in an open access manner, which can inform land managers to what the quickest response may be, and allow third parties to study this data and form detached objective studies.

An open access database that allows land managers to make decisions based on statistical precedence, and have third-parties perform audits and studies on performance.

Half-yearly analyses done to ensure response time is decreasing on all kept control methods.


These actions should be easy to implement in the already outlined framework, as most merely build upon the pre-existing actions. Understandably, it is not within the capacity of this Working Group to alter the laws of each state, however as noted in Action 1.6, The Plan is capable of promoting best practices to each governing body. If the goal is to optimise the suppression of the deer population, then every tool should be utilised. This, as shown earlier in the submission, includes recreational hunting. As not every state allows recreational hunting in state forests, promoting the benefits of recreational hunting to the appropriate governing bodies is within The Plan’s best interests, as implementation of such allowance would increase the amount of recreational hunters harvesting deer nationwide. This, in combination with programs to collect more data, will amount to more accurate modelling to be conducted, which can direct future propositions.

It is my hope that the Working Group reads this submission in good faith, with the understanding that our goals do align with conservation best practices, and are able to implement the actions either in their entirety or partially.

I am more than happy to discuss anything I have written about in person, over the phone, or through any other median (e.g. video call).

Yours Sincerely,
Daniel Lewis-Kuhl
BSc Biological Sciences, Environmental Science and Wildlife Ecology


  1. Caudell, J., Review of Wound Ballistic Research and Its Applicability to Wildlife Management. Wildlife Society Bulletin, 2013. 37.
  2. Hampton, J.O., et al., Improving animal welfare in wildlife shooting: the importance of projectile energy. Wildlife Society Bulletin, 2016. 40(4): p. 678-686.
  3. Australian Deer, A., Australian Deer Association. Australian Deer Association.
  4. Bengsen, A.J., et al., A systematic review of ground-based shooting to control overabundant mammal populations. Wildlife Research, 2020. 47(3): p. 197-207.
  5. Comte, S., et al., Cost-effectiveness of volunteer and contract ground-based shooting of sambar deer in Australia. Wildlife Research, 2022: p. -.
  6. Finch, N., et al., Expenditure and motivation of Australian recreational hunters. Wildlife Research, 2014. 41: p. 76.
  7. Group, R.G.C., Economic and social impacts of recreational hunting and shooting. 2019.
  8. Department of Jobs, P. and V. Regions, Economic contribution of recreational hunting in Victoria. 2020.
  9. Fantinel, K., Farmer assist in the national spotlight, in Australian Shooter. 2014.
  10. Ward, K.J., et al., Categorizing Deer Hunters by Typologies Useful to Game Managers: A Latent-Class Model. Society & Natural Resources, 2008. 21(3): p. 215-229.
  11. SCHROEDER, S.A., D.C. FULTON, and J.S. LAWRENCE, Managing for Preferred Hunting Experiences: A Typology of Minnesota Waterfowl Hunters. Wildlife Society Bulletin, 2006. 34(2): p. 380-387.
  12. Moloney, P.D., et al., Bayesian modelling reveals differences in long-term trends in the harvest of native and introduced species by recreational hunters in Australia. Wildlife Research, 2022. 49(8): p. 673-685.
  13. Moloney, P. and J. Flesch, Estimates of the 2021 deer harvest in Victoria Results from surveys of Victorian Game Licence holders in 2021. 2022.
  14. Victoria State, G., Victorian Deer Control Strategy. 2020.
  15. Ramsey, D., C. Pacioni, and E. Hill, Abundance and population genetics of Hog Deer (Axis porcinus) in Victoria. 2019.
  16. Hušek, J., M.R. Boudreau, and M. Panek, Hunter estimates of game density as a simple and efficient source of information for population monitoring: A comparison to targeted survey methods. PLOS ONE, 2021. 16(8): p. e0256580.
  17. Watter, K., et al., Reproductive seasonality and rate of increase of wild sambar deer (Rusa unicolor) in a new environment, Victoria, Australia. Animal Reproduction Science, 2020. 223: p. 106630.
  18. Fleming, P.A., et al., Distinctive diets of eutherian predators in Australia. R Soc Open Sci, 2022. 9(10): p. 220792.
  19. Davis, N.E., et al., Interspecific and Geographic Variation in the Diets of Sympatric Carnivores: Dingoes/Wild Dogs and Red Foxes in South-Eastern Australia. PLOS ONE, 2015. 10(3): p. e0120975.
  20. Wicks, S., et al., An integrated assessment of the impact of wild dogs in Australia. ABARES Report, 2014. Research report no. 14.4.
  21. Forsyth, D., et al., Interactions between dingoes and introduced wild ungulates: Concepts, evidence and knowledge gaps. Australian Mammalogy, 2018. 41.


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