Up front: I urge you to please acknowledge that the expert report you have relied upon to support a Belconnen kangaroo cull is inconsistent and contradictory, circular, biased and speculative, and that it would be unsatisfactory for one or more kangaroos with intrinsic value and life rights to lose their lives because of such a badly flawed report.

Please note also that I was preoccupied with family and work commitments and in the finalisation of my PhD graduation (e.g. getting final thesis copies copied and bound) when you called for submissions late in 2007 on this matter. I thought from media reports last year that the kangaroos were to be relocated alive and thought that was the end of it. I'm shocked that the cull option has been put back on the table and even more shocked that it has been supported by your government Mr Stanhope.

I urge you to please ensure that no kangaroo is killed under government direction until you have properly addressed the concerns I and others are raising here.

I see that your report at http://www.envcomm.act.gov.au/__data/assets/pdf_file/0007/95812/BTNS_report.pdf Dr Cooper states as follows on pages 5, 14 and 15:

On page 5:
Recommendation 5 – Kangaroos are to be removed from BNTS by the most humane method suitable for that site having regard to advice from the AFP that firearms are not to be used at BNTS. (The Expert Panel has recommended sedating by darting followed by euthanasia by lethal injection.)

On pages 14-15:
The expert panel considered non-lethal and lethal methods (Attachment G, pages 9 to 11). They
found that shooting is the most humane method. However, the AFP will not allow this method to
be used at BNTS due to public safety concerns. The expert panel therefore recommended that the kangaroos be removed from BNTS by sedating by darting followed by euthanasia by lethal injection.
[I note that the word "found" is used here and I dispute the validity of the word "found" in this case. It seems clear that "believe" better reflects the "expert" position here.]
...
From discussions with officers in Defence it is understood that the option of moving the kangaroos
to New South Wales is being explored. It would seem that this could not occur unless the
Conservator of Flora and Fauna granted an export licence to the Department of Defence (see
sections 48 and 104 of the Nature Conservation Act). The panel’s recommendation and the Conservator’s policy regarding this issue (Attachment G, page 11) are supported.

Then in the Attachments at http://www.envcomm.act.gov.au/__data/assets/pdf_file/0004/95818/BTNS_Attachments.pdf, Attachment G, the final expert report, contains as follows:

The only identifiable nonlethal method of removing the kangaroos from BNTS is to physically move the kangaroos to another site. For the 60 kangaroos subject to research at BNTS this may be appropriate, provided that another site suitable for holding captive kangaroos for research purposes can be located. However, for the other kangaroos currently captive at the BNTS site, we do not consider dart-capture followed by release into the wild to be a humane option for the reasons set out below. Firstly, it is against current ACT Government policy. This policy has been in
place for some time and is backed by sensible and robust investigation and research.

The above quote is plainly inconsistent and contradictory in claiming that non-lethal kangaroo translocation "may be appropriate" for "the 60 kangaroos subject to research at BNTS", but not humane for kangaroos not subject to such research. "Research status" is obviously not a legitimate basis for determining what is humane or not.

So it appears here as though (1) Mr Stanhope has commissioned you Dr Cooper to carry out an investigation, (2) you Dr Cooper have sought the views of an expert group, and (3) that expert group "finds" that the Kangaroo cull is preferable to translocation, "firstly" because translocation "is against current ACT Government policy". This "first" basis for opposing non-lethal removal is clearly a hollow and circular argument. The "second", "third" and "additional" reasons the expert group use to oppose the translocation option, furthermore, are all largely or wholly speculative in relation to what may or may not happen if translocation was attempted.

The expert group claim that the ACT Government policy opposed to translocation "has been in place for some time and is backed by sensible and robust investigation and research", but they do not cite any specific sources of such investigation and research. The expert report opposition to non-lethal kangaroo removal is based on circular argument and speculation which are clearly no substitute for legitimate scientific analysis, and I believe you have a duty to now make such analysis and research fully transparent and available to the public.

The expert group report shows that the expert group have been strong devil's advocates in relation to the non-lethal kangaroo removal options, but have aggressively "argued for the angels" in support of lethal options. This raises obvious issues of bias and due process that should concern people irrespective of their position on this matter. The pros and cons of lethal and non-lethal options alike should have been even-handedly assessed and presented in the expert group report. Both options should have been presented in their best light in order to minimise the possibility of bias and oversight. The expert report makes the blanket claim that "shooting is universally accepted as the most humane lethal method of removing kangaroos." Most people would probably agree much more with the view held by me and many others that "unnecessary killing of animals is fundamentally wrong", and could only be considered justifiable in extreme circumstances, and would not be nearly as quick as your expert group to conclude that the Belconnen case is one where such killing is unusually justifiable or essential. It's fine that the expert group have their views, but their report plainly lacks validity to the extent that it is clearly much less than even-handed in its consideration of lethal and non-lethal removal options.

I urge you to please acknowledge that the expert group report you have relied upon is obviously inconsistent and contradictory (in acknowledging that non-lethal translocation "may be appropriate" for kangaroos "subject to research", but not humane for those not subject to such research), circular (in using government policy as the first reason raised to oppose kangaroo translocation), biased (in failing to even-handedly present the pros and cons of lethal and non-lethal kangaroo removal options) and speculative (in relation to what may or may not happen if non-lethal translocation was attempted), and I further urge you to please ensure that no kangaroo is killed until the expert group report's flaws are properly addressed, nor until a trial translocation is attempted so as to remove uncertainly on the viability or otherwise of non-lethal translocation as a method of removing kangaroos from Belconnen.

Regards,
Mark Drummond
BSc(hons) DipEd BA BE(hons) MBA MPubPolMgmt PhD
5 Loddon Street
KALEEN ACT 2617
phone 02 6255 0772
email: markld@ozemail.com.au