Pegasus report progress reporting
Assessment of the GMA’s Compliance and Enforcement Function
The Game Management Authority is continuing to grow and build on its capacity and capability to regulate game hunting in Victoria. Our aim is to ensure the GMA is an effective regulator that delivers a modern approach to regulating game hunting now and into the future. Moving forward means taking on the lessons of the past, focussing our priorities and working with our partners and our stakeholders in new and productive ways.
Three year progress update
In July 2017, the Game Management Authority engaged Pegasus Economics to conduct an independent assessment of the effectiveness of GMA’s compliance and enforcement regime, the appropriateness of the operating model and the Authority’s capacity and capability to deliver its compliance and enforcement obligations.
The 2017 Pegasus Economics final report “Assessment of the GMA’s Compliance and Enforcement Function” (Pegasus Report) made 27 recommendations, 26 of which were supported in principle by the GMA Board. The GMA commenced addressing the 26 recommendations of the Pegasus Report in 2018. This report provides an update of activity against these recommendations for the second quarter of 2020. Progress reports will be provided quarterly on our website at www.gma.vic.gov.au
It is important to understand that although GMA supports in principle the 26 recommendations, several relate to matters of resource management or policy that are controlled by Departments other than the GMA. However, the GMA will work with the responsible bodies and seek to bring about change in these matters.
|1.1||The GMA should work with land management authorities to develop more flexible arrangements for land access based on permit and ballot systems that are widely deployed in other jurisdictions. Regulatory reform will need to be led by policy agencies.||Preliminary discussions held with Parks Victoria, the land manager, on opportunities to consider approaches to managing hunter densities. The possibility of introducing regulatory instruments to regulate hunter densities where appropriate has also been raised with DJPR for consideration as part of the review of the sunsetting Wildlife (Game) Regulations 2012. Section 86 of the Wildlife Act 1975 also allows hunter numbers to be regulated.|
Other government agencies are responsible for implementation.
|1.2||Game hunting licences should include more stringent minimum mandatory requirements, including testing for knowledge of the game hunting laws and the obligations and responsibilities of safe and sustainable hunting.|
A new Game Licensing System is in development to cater for new Game Licence testing arrangements. After undertaking a request for tender process, a contractor has been engaged and has commenced development of a new system, including e-learning and testing platforms. GMA has also appointed a Senior Project Officer to manage the implementation of mandatory online knowledge testing for future Game Licence applicants. Regulatory change will need to occur to implement this.
Research into the extent of hunters’ knowledge of the hunting laws and good practice has been completed and will guide the development of a licence test and areas to target education efforts.
Requires regulatory change for full implementation. This is lead by DJPR.
|1.3||There should also be a requirement that prospective duck hunters demonstrate their attendance at a Shotgunning Education Program (SEP) prior to the issue of a duck hunting licence and that similar courses be developed for the holders of other categories of hunting licences.|
The GMA engaged an external supplier to conduct market research into barriers and perceptions limiting participation in the current Shotgunning Education Program. As a result, the GMA with the financial support of Sport and Recreation Victoria, has released an updated practical program titled Gamebird Hunting Essentials Masterclass. This program was recently launched with associated marketing aimed at increasing voluntary participation. The attendance cost for juniors to attend was also subsidised to encourage greater participation.
GMA is investigating the roll-out of workshops to better educate industry and increase capability of program trainers.
Mandatory attendance of hunters at field-based training/proficiency testing would require the introduction of new regulations. This has been raised with DJPR for consideration in its remaking of the sunsetting Wildlife (Game) Regulations 2012.
Requires regulatory change for full implementation. This is lead by DJPR.
|1.4||Information and educational materials should be made available in languages that are relevant to the hunting community.||Fact sheets on the arrangements for duck season are produced in five different languages (Italian, Greek, Maltese, Arabic and Lebanese) and placed on the GMA website. Multi-lingual materials will be developed as required.||Implemented|
|1.5||The GMA needs to significantly expand its monitoring and information gathering activities, including by enlisting the support of hunting organisations, animal welfare organisations and land holders in undertaking active and passive monitoring of game numbers and the effectiveness of its compliance and enforcement activities.|
The GMA explored the best way for members of the public to report complaints of alleged illegal hunting. Complaints can now be received online through the GMA website and also by phone through the Customer Contact Centre. All information will be entered into a new case management system which became operational in the 1st quarter of this year.
All reports of illegal hunting are sent directly to the Director Compliance and Intelligence to consider the most appropriate response. An Intake and Assessment Panel (IAP) has also been established to consider and assess all complaints provided to the GMA. The IAP will review the material to provide preliminary guidance as to whether an investigation should be undertaken by the GMA into the possible offending conduct.
The GMA has responded to sightings of concentrations of rare and threatened species and coordinated counts to determine if any additional management action was required. This is routine practice and will continue.
|1.6||The GMA should review the priority it attaches in its compliance and enforcement activities to protestor management.||Victoria Police is the lead agency to manage protestor compliance activities. Victoria Police has committed to being more active in protestor compliance allowing the GMA and its partner regulatory agencies to focus on hunter compliance.||Implemented|
|1.7||The GMA should seek to engage more constructively with stakeholders across a broader range of interests and values.|
The GMA consults with hunting, conservation and animal welfare organisations over the arrangements for the forthcoming duck season and possible wetland closures. The GMA has also consulted the RSPCA, Animals Australia and key duck hunting organisations over the development of advisory guidelines for the humane dispatch of downed waterfowl.
The GMA has developed and is implementing a stakeholder engagement strategy.
A Senior Communications Officer and Communications Manager have been appointed and a Facebook page and You Tube Channel are actively used to communicate with the public. The GMA’s website has been redesigned, content revised, graphics improved and mobile device compatibility has been improved. The updated website was released in the fourth quarter of 2019.
The GMA has developed and is implementing a program of increased in-field education presence aimed at interacting with the broader community and regulated stakeholders. This includes attendance at expos and agricultural field days. The GMA also attends local community group meetings, such as Landcare.
|1.8||The GMA’s stakeholder engagement strategies and programs should be more clearly directed to achieving the active cooperation of its stakeholders in supporting a respectful, responsible and compliant hunting culture.|
See 1.7. for details.
In addition, the GMA coordinates the RESPECT: Hunt Responsibly program in consultation with the hunting industry, hunting organisations and partner government agencies. This program identifies initiatives to encourage sustainable, safe and humane hunting. A workshop with government agencies, hunting organisations and industry representatives was held in August 2019. Annual workshops will be held.
A guide for the humane dispatch of downed birds has been developed following consultation with hunting and animal welfare stakeholders. The guide and a summary fact sheet were released and published on the GMA website in October 2019. The guide was mailed to all licensed duck hunters (approx. 26,000) in November 2019. A full length instructional video and two abridged videos focussing on the major techniques and a promotional video to complement the other educational materials were developed and released prior to the start of the 2020 duck season.
The GMA has developed and is in the process of implementing a program to increase its in-field education presence aimed at interacting with the broader community and regulated stakeholders.
|1.9||The GMA should improve the transparency of its reporting and complaint handling mechanisms and ensure that arrangements are in place for all complaints to be logged, reviewed by a senior officer and responded to.|
The GMA has met with Animals Australia and the Department of Jobs, Precincts and Region’s (DJPR) Prosecution Services on the merits and reporting needs for making formal complaints regarding alleged illegal hunting activities. An IAP has been established to consider all complaints from members of the public. The IAP will review the material to provide preliminary guidance as to whether an investigation should be undertaken by the GMA into the possible offending conduct.
A new Intelligence Case Management System (ICMS) has been procured and deployed in the 1st quarter of 2020 to assist in logging, reviewing and reporting progress and outcomes of all matters, including providing updates/outcomes of matters to complainants. The case management system is currently being tested by GMA Authorised Officers.
|2||Regulatory governance and approach to regulation|
|2.1||The GMA’s role as a regulator should be clarified and the independence of its licensing, compliance and enforcement functions protected.|
The GMA Board has developed a five (5)-year Charter, including Vision and Purpose Statements, that explicitly describe the GMA as a Regulator. A 2021 business plan based on the revised Charter has been prepared and approved by the Minister for Agriculture. The business plan will be posted on the GMA website.
A review of the GMA’s structure has been conducted and a comprehensive restructure, including the establishing new regional offices, has been completed. Recruitment for a number of roles as part of this restructure is nearing completion.
|2.2||Action not supported|
|2.3||The GMA should put in place appropriate governance arrangements, including operational separation, establishment of an Enforcement Committee and appropriate protocols, to provide additional transparency and protect the independence of its licensing, compliance and enforcement functions.|
The GMA has restructured to separate the compliance and intelligence functions from strategy and research and stakeholder and hunting programs functions and appointed a Director to lead the Compliance and Intelligence Division.
Advice on the GMA’s Standard Operating Procedures (SOPs) has been sought and received from the Victorian Government Solicitor’s Office. All SOP’s have been reviewed and have been updated and approved and are now available to all staff at a central electronic location.
Advice on the outcomes of compliance complaints has been implemented. An Intelligence Case Management System has selected and is now in operation. Public complaints are lodged through the Customer Contact Centre or the GMA website and all are reviewed by the Director Compliance and Intelligence for appropriate action (see 1.9).
A new Game Licensing System is currently under construction (see 1.2).
|2.4||The GMA should develop a more dynamic approach to compliance and enforcement that is informed by improved information on hunters’ understanding of their obligations and better targeted to secure improved compliance outcomes.|
A new Game Licensing System is currently under construction (see1.2).
An Intelligence Case Management System for regulatory/compliance activities has been identified and selected (see 1.9).
Maps clearly identifying where hunting is permitted on Victoria have been developed and are available online at the GMA’s website. A phone application, More to Explore, showing where hunting can occur across Victoria has been released.
Research into establishing a baseline for the level of hunters’ understanding of hunting laws and good hunting practice has been completed. Results will help to inform educational and training materials and the development of a Game Licence test.
|2.5||The GMA should develop an annual compliance strategy that sets out specific compliance and enforcement goals, priorities, strategies and performance measures that are to be applied in the upcoming period, and the basis on which those priorities and strategies have been selected and are to be evaluated against|
The GMA has been restructured and a Director Compliance and Intelligence appointed (see 2.3). The Director Compliance and Intelligence was recruited in part to increase the strategic skills for developing an annual compliance strategy. A Compliance Strategy 2020-2025 and a Compliance and Enforcement Policy was approved by the Board at its December 2019 meeting. The GMA’s website articulates GMA’s specific compliance and enforcement goals, priorities and plans. Specific performance measures for are being developed.
Significant work has been done in developing an annual compliance plan, which will guide compliance operations state-wide and also regionally.
|2.6||The GMA’s compliance strategies should be informed by improved measures of the knowledge base and compliance posture of the hunters, game farms and other agents that it is seeking to regulate.|
The purchase of intelligence services has been increased from 0.5FTE to 1 FTE. An Intelligence Case Management System has been identified and selected and was deployed in the 1st quarter of 2020.
|2.7||The GMA’s approach to regulation should seek to incorporate a stronger emphasis on compliance-based strategies that positively influence hunter behaviours and opportunities for self-regulation and co-regulation where stakeholders can demonstrate their willingness and ability to comply.|
The GMA coordinates the RESPECT: Hunt Responsibly program in consultation with the hunting industry, hunting organisations and partner government agencies. This program identifies initiatives to encourage sustainable, safe and humane hunting. A workshop with government agencies, hunting organisations and industry representatives was held in August 2019 to develop a work program for the next 12-months.
The GMA has also developed a draft five-year Education Strategy which directs actions to increase compliance through behavioural change and increased knowledge and awareness.
Parks Victoria is working with hunting organisations and has identified two sites to pilot the co-management of State Game Reserves.
|2.8||The GMA should regularly review and evaluate the effectiveness of its compliance and enforcement efforts against its intended compliance outcomes, and adjust its strategies as required to achieve better compliance outcomes.|
An Intelligence Case Management System has been identified and selected and the GMA’s purchase of intelligence services has increased from 0.5 FTE to 1 FTE.
A Compliance Strategy 2020-2025 has been approved by the GMA Board. In addition, regional compliance plans for 2019-20 have been completed and plans for 2020-21 are in preparation.
Metrics for the effectiveness of compliance efforts are currently being developed. A stakeholder sentiment survey is currently being scoped to measure the key stakeholders’ views of the effectiveness of the GMA in achieving its statutory responsibilities. This survey will be conducted in the 2020-21 financial year.
|2.9||The compliance strategy should be supported by more transparent processes for tasking and coordination of compliance and enforcement actions and improved reporting on compliance and enforcement outcomes.||The GMA has increased the resources dedicated to information collection and analysis to ensure that compliance operations are based on intelligence and targeted to where the greatest harms are occurring (see 2.5). In an attempt to improve transparency to its stakeholders and the community, the GMA will publish enforcement data and information both in its Annual Report, which gets tabled in Parliament, and also on its website to inform the public of the nature and outcome of prosecutions.||Implemented|
|3.1||The existing operating model should be supported by a clear accountability and governance framework that provides a definitive statement of the accountability framework within which the GMA and its partner agencies are expected to work and detailed agreements between the individual agencies in relation to the identification of priorities, the allocation of responsibilities, resource sharing and dispute resolution.|
GMA has provided advice to DJPR on this action. DJPR is coordinating the development of an accountability framework that recognises the role of all relevant government agencies in game hunting and game management.
DJPR is responsible for implementing this action.
|3.2||The GMA should seek clarification of the Government’s intent regarding the requirement that enforcement operations be undertaken with Victoria Police and, if necessary, refine and clarify the GMA’s Standard Operating Procedure in which this policy is reflected.||The Victorian Government Solicitor was engaged by the Director Compliance and Intelligence to assist in its review of GMA’s Standard Operating Procedures. All SOP’s have been reviewed and have been updated and approved and are now available to all staff at a central electronic location.||Implemented|
|3.3||The GMA should encourage the participation of volunteer resources from hunting organisations, animal welfare groups and community organisations to assist in the collection of information on the effectiveness of its compliance and enforcement efforts and support safe, responsible and sustainable behaviours in the field.|
The community is actively being encouraged to report any suspected illegal hunting activity through existing reporting channels (Customer Contact Centre, online through the GMA’s website, GMA Authorised Officers).
The GMA actively and regularly encourages the public to report illegal hunting through social media, media releases and the GMA’s website.
An IAP has been established to review such complaints and includes expertise on animal welfare, legal, compliance and prosecutions and meets weekly or as required to ensure complaints are assessed and, where appropriate, acted upon as expediently as possible.
|4||Capacity and capability|
|4.1||The funding model under which the GMA operates should be reviewed. This should include consideration of better ways of managing the demand for the GMA’s services, its approach to regulation, and the balance of resources it allocates to protestor management and enforcement activities relative to persuasive strategies to encourage higher levels of compliance.|
As part of its 2019 election commitments, the government has allocated an additional $1.5M per year recurrent to the GMA. This assisted to fund the restructure and the addition of new Game Officers, communications and research staff.
The restructure has been completed and recruitment for these roles is nearing completion. The new structure and additional resources have already seen an improvement in the GMA’s capacity and capability to effectively regulate.
The GMA has developed a new five (5)-year Charter and the 2020-21 business plan has been approved by the Minister. New regulations, proposed testing arrangements and an improved approach to compliance (including systems and processes) and communications are aimed to improve hunter compliance.
|4.2||The GMA needs to develop the capacity to develop high-level compliance strategies and to apply appropriate regulatory tools and capabilities to solve problems, prevent harm and influence behaviour.|
As outlined above, the GMA is implementing an improved Compliance and Intelligence Division structure made up of a Director, Regional Compliance Team Leaders, Senior Game Officers and Game Officers. This structure allows the Director to focus more clearly on strategic management driven by gathered intelligence. The number of on-ground compliance staff is being more than doubled. The Director, Team Leaders and a number of compliance officer roles have been recruited. Recruitment is expected to be completed by the end of 2020.
An Intelligence Case Management System has been identified and selected to improve the management and tracking of all reported activities and the intelligence service has been increased from 0.5 FTE to 1 FTE. SOPs have been reviewed and annual regional compliance plans have been prepared.
In addition, investment in compliance technologies is progressing. For example, Team Leaders, Senior Game Officers and Game Officers have been issued with infield technology (Surface Pros / Body Worn Cameras etc.), which has greatly increased the regulatory tools for GMA staff and to influence behaviours, especially when footage is played before the Courts.
A Senior Communications Officer and Communications Manager have been appointed. A Research Principal has been appointed and commenced employment in early-January 2020. New regulations have been introduced to require the immediate recovery of downed ducks and minimum salvage of at least all breast meat. Later duck season opening weekend start times have being trialled and are currently under review by government. Drone technology has been trialled. Programs delivered by the GMA will focus on influencing hunters across the compliance spectrum, from prevention, monitoring and surveillance to enforcement.
|4.3||The GMA should consider completion of the Australian Government Investigations Standards (AGIS) or demonstration of equivalent qualifications training as a mandatory requirement for staff involved in investigations.|
Following recruitment of all compliance positions, staff will be required to undertake the appropriate training in both investigation and surveillance training. These skills will be maintained and updated over time.
An improved system to track and record fulfillment of training and refresher requirements is also being introduced.
All GMA Authorised Officers are required to have, as a minimum, a Certificate IV in Government (Investigations). One (1) course is currently half-way through being delivered and will be completed once current COVID-19 restrictions are lifted.
|4.4||If the GMA is to continue to perform surveillance operations, it should ensure that staff have received appropriate training in safe and effective surveillance techniques.||See 4.3.||Implemented|
|4.5||The GMA should engage skilled and qualified communication and marketing experts who can engage effectively with a dispersed and diverse stakeholder base across a wide range of channels and communications media.||A Communications Manager was appointed in June 2019 and joined the Senior Communications Officer. An annual stakeholder engagement plan has been developed and will be reviewed annually. A Facebook page has been introduced and the GMA’s You Tube site is being better utilised and new video clips to improved hunter compliance are currently being developed. The GMA website has been redesigned to make it more modern, contemporary and improve usability. All content has been reviewed and rationalised, graphics improved, and the website is mobile device compatible. The updated website became operational in the fourth quarter of 2019. The Game Hunting Victoria phone app has been shut down and replaced with hunting layers in the More to Explore app. A new online web-based mapping system has been developed and is now hosted through the GMA’s website to inform the public on where hunting is and isn’t allowed across Victoria.||Implemented|
|4.6||The GMA should seek to more effectively manage the demands on its resourcing, including by seeking tighter land access arrangements, examining the possibility of more selectively regulating some game species, exploring opportunities for co-regulation and by re-allocating resources away from relatively expensive enforcement activities toward more cost-effective activities such as information and education.|
Land access arrangements, setting regulations and legislation and co-regulation are matters for other responsible agencies and not the GMA. The GMA has engaged with the responsible agencies to provide advice on possible approaches.
GMA has restructured to provide greater focus on hunter education and skills development. A new Game Licence Test and proficiency testing is being developed to ensure hunters have a minimum standard of competence and knowledge of hunting laws and good hunting practise. A new Game Licensing System is under construction to accommodate the test. Social and web-based media will provide improved information and education aids to hunters to improve compliance and ensure safe and sustainable hunting. GMA is delivering field-based education events to better engage with hunters in the field and help them to comply with laws. This also includes increasing an education presence at industry and outdoor retail stores.
Regulatory change and revised approaches to land management are reliant on other agencies.
*Implemented – actions for which the GMA has control and has implemented
In progress – actions for which the GMA has control and is in the process of implementing
Completed – actions that are the responsibility of other government agencies to implement and GMA has raised and discussed the issue and possible response/s
Page last updated: 25 Aug 2020