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Executive Summary

Key points:

In Victoria, recreational game hunting has occurred for over 150 years and remains a popular and culturally significant activity. There are around 41,500 licensed game hunters in Victoria, an increase of over 41 per cent in the last decade. The Department of Primary Industries (DPI) estimates that game hunting generates around $96 million of economic activity in Victoria annually.
In line with government policy, in December 2011, Game Victoria was established.Game Victoria will develop strategies and policies for the sustainable harvest of game species and support the promotion of the game hunting sector, including promoting game hunting as a popular recreational activity.
Game hunters in Victoria face a range of regulations. It is, therefore, important that the proposed Regulations impose the lowest possible burden on hunters, while achieving government other objectives.
Consultation with stakeholders and experience built up over the last 10 years has resulted in a number of changes to the proposed Regulations (see Box 1 on p. 12 for key changes).In almost all instances, the changes to the proposed Regulations will lower the regulatory burden and allow growth in the industry without compromising the Victorian Government’s objectives.
Fee levels have been examined and assessed on whether they remain efficient, effective and equitable. Aside from the introduction of new licence categories, fees remain at similar levels to the current fees. In line with licence arrangements for recreational fishing, people under the age of 18 years will not be required to pay a fee.
Overall, the proposed Regulations seek to continue to provide sustainable recreational hunting opportunities while ensuring the future of game species, the protection of their habitats and the humane and ethical treatment of those species that are hunted.

This Regulatory Impact Statement concludes that:

the benefits to society of the proposed Regulations exceed the costs;
the net benefits of the proposed Regulations are greater than those associated with any practicable alternatives; and
the proposed Regulations do not impose restrictions on competition.

Purpose of a Regulatory Impact Statement

In Victoria, all regulations expire (sunset) after 10 years of operation. This provides the Victorian Government with the opportunity to examine the efficiency and effectiveness of regulations and to evaluate whether they are still relevant or could be improved. Following a 12 month extension, the Wildlife (Game) Regulations are due to expire on 11 September 2012.

New regulatory proposals, including remaking expired regulations that impose a significant economic or social burden on a sector of the public require the preparation of a Regulatory Impact Statement (RIS). Given the nature of and restrictions imposed by the regulations, the Department of Primary Industries (DPI) considers that the burden imposed by the proposal requires assessment in a RIS.

A RIS formally assesses regulatory proposals against the requirements in the Subordinate Legislation Act 1994 and the Victorian Guide to Regulation.¹ The assessment framework of this RIS examines the problem to be addressed, specifies the desired objectives, identifies viable options that will achieve the objectives, and assesses the costs and benefits of the options. Following this, it identifies the preferred option and describes its effect. This RIS also assesses the proposed Regulations’ impact on small business and examines their impact on competition. Finally, it considers implementation and enforcement issues and documents the stakeholder consultation undertaken.

Context

The sustainable use of wildlife populations is consistent with contemporary conservation management principles and is sanctioned by international conservation treaties and conventions. Recreational game hunting is a form of sustainable use that, as a cultural tradition, has been undertaken for many centuries. In Victoria, recreational game hunting has occurred for well over 150 years and has been regulated since the early 1860s.^[2] There are approximately 41,500 licensed game hunters in Victoria³, who spent around 300,000 days hunting in 2010/11.⁴Licensed hunters comprise approximately 24,500 duck hunters, 23,000 deer hunters and 27,300 licensed quail hunters.⁵ The number of licensed game hunters has increased by 41 per cent in the last decade. Of those hunters licensed to hunt deer, approximately 14 per cent hunt Sambar Deer with hounds. A small number of hunters also hunt introduced game birds such as pheasant, partridge and quail.

Game species are the common property of the community and hunting activities need to be regulated to ensure that populations are maintained to provide a range of sustainable consumptive and non-consumptive uses for present and future generations. Hunting pressure also needs to be regulated so that it does not exacerbate any habitat-driven declines in game populations.⁶Further, the public has become increasingly aware of the issues surrounding hunting and demands a responsible management approach to ensure that hunting is conducted safely and that animal welfare concerns are addressed.

The sustainable use of wildlife in Victoria is provided for under the Wildlife Act 1975 (the Act), with the hunting of game administered by the Wildlife (Game) Regulations 2001 and the Code of Practice for the Welfare of Animals in Hunting made under the Prevention of Cruelty to Animals Act 1986.These regulatory instruments apply to game hunting wherever it occurs, including both private property and Crown land. As required by the Act, game hunting is managed on a sustainable basis for access to the resource. There are also objectives regarding the management of persons engaged in game hunting with regard to competency.

Nature of the problem

Given the framework established by the Act, the proposed Regulations seek to manage game hunting in a manner that provides for and promotes sustainable, humane, ethical and safe recreational hunting opportunities, while minimising the destruction of non-game species and ensuring the protection of wildlife habitats. It is also important to ensure that game resources and public land are managed on an equitable basis, between game hunters and other users of public land.

Specifically, the proposed Wildlife (Game) Regulations seek to manage problems in the following categories:

sustainable and equitable management of game resources;
humane and safe hunting; and
competency and accountability.

More broadly, the proposed Regulations seek to manage an environmental externality known as ‘tragedy of the commons’. This involves managing a public resource in a manner that ensures its sustainability and to prevent over-use.

Objectives

The objectives of the proposed Wildlife (Game) Regulations 2012 are to provide for the efficient and effective management of game hunting in Victoria, in ways that:

provide continued sustainable, equitable, humane, ethical and safe recreational hunting opportunities;
ensure equitable sharing of game resources between stakeholders;
minimise the destruction of non-game species;
ensure the protection of wildlife habitats; and
facilitate game-related businesses.

Options for achieving the objectives

The Subordinate Legislation Act 1994 requires that non-regulatory options must be considered as part of the RIS assessment. Further, the Premier’s Guidelines provide guidance on alternatives to achieve the Government’s objectives. Alternatives to subordinate legislation include: providing better information to affected groups to raise awareness of their rights and/or obligations; introducing voluntary codes of conduct; utilising market mechanisms as a regulatory tool; and establishing a code of practice for the conduct of an activity.

A common regulatory solution to correct the externalities identified with ‘tragedy of the commons’ is to establish rules and requirements governing the species that may be hunted, when they may be hunted, the method by which they are hunted, the quantity that may be taken, and defining areas where hunting may occur. Establishing systems to regulate the take of game are common regulatory tools used throughout Australian and international jurisdictions to manage such externalities. Such regulations trace their origins back many hundreds of years.

The scope of consideration of regulatory and non-regulatory options in many cases is limited because of the existing powers of the Act and other legislation. Thus, options considered in this RIS focus on the ‘residual problems’ that would not be managed in the absence of the regulations. Therefore, five specific option areas were considered:

Option 1 – licensing and registration requirements;
Option 2 – sustainable game management;
Option 3 – gundog and hound control;
Option 4 – non-toxic shot; and
Option 5 – balloting.

Costs and benefits of the options

The ‘base case’ describes the regulatory position that would exist in the absence of the proposed Regulations; that is, of no game hunting being permitted. It is necessary to establish this position in order to make a considered assessment of the incremental costs and benefits of the viable options. Given the operation of the Wildlife Act 1975, the base case for purposes of analysis in this RIS is represented by the situation in which no game hunting could legally occur in Victoria. This is because the Act precludes the taking of game except where authorised to do so. It is the Wildlife (Game) Regulations that provide this authorisation for the general public to hunt and take game species. In the absence of these regulations, no game hunting is permitted.

Given the difficulty in measuring the costs and benefits associated with game hunting, this RIS uses a number of methodologies to inform its assessment of viable options. The present value (PV) discounted cash-flow technique is used to measure the likely costs associated with administrative costs and compliance costs; however, others costs and benefits proved difficult to quantify in monetary terms. The Multi-criteria Analysis (MCA) assessment tool⁷ is therefore used in an attempt to assess the costs and benefits of the viable options. The option with the highest score represents the preferred approach.

Costs

Each of the proposed Regulations was examined for the likely costs they would impose on parties impacted by the proposal. Table 1 below shows that these costs over a 10‑year period are approximately $13.3 million (PV), representing an annual cost of around $1.3 million per annum.

Table 1: Discounted costs imposed by the Proposed Regulations, 10-Year Assessment Period
Summary of Costs Imposed by the Wildlife (Game) Regulations 2012
Regulation	Type of Cost	Costs ($)
Licensing and registration	Administrative	5,844,632
Hog Deer tags and checking stations	Administrative	243,724
Non-toxic shot	Substantive Compliance	7,276,131
	*Total*	13,364,487
	*Annual Cost*	1,336,449

Of these costs, approximately 54 per cent ($7.2 million) are directly related to the requirement to use non-toxic shot.^[8] A simple average of the identified costs suggests that the proposed Regulations impose approximately $32 of regulatory costs (excluding fees) per annum on each licensed hunter. When fees are included, this equates to around $73 per annum per hunter.

The total quantifiable costs of the proposed Regulations are in the order of $30.1 million (PV) over a 10 year period (or around $3 million per annum). This includes compliance and administrative costs imposed by the regulations, as well as fees for Game Licences ($16.7 million).

Benefits

The Victorian Government estimated that game hunting contributes around $96 million per annum to the Victorian economy. This figure is likely to grow given the continued strong growth in hunting and hunter numbers. Given that the annual discounted cost of the regulations is in the order of $3 million per annum and the benefits associated with game hunting in Victoria are likely to be in excess of $96 million, it is apparent that the benefits associated with the proposed Regulations outweigh the costs. However, to ensure the cost/benefit ratio is maximised, in line with government objectives, a number of alternatives were considered (see discussion below).

Aside from economic benefits, other benefits associated with the proposed Regulations include: environmental benefits (including ensuring that game species populations are sustainable; prevention of toxic shot being deposited on Victorian wetlands and waterways; minimising the destruction of non-game species), social benefits, and scientific benefits (including capturing data on the game populations).

Preferred option

The analysis in this RIS supports the proposed Regulations as the preferred option compared to the other options considered in this RIS. This finding was concluded against the decision criteria described in section 4.2.4; that is, while the quantifiable costs are largest compared to the other options (a discounted cost over a ten-year period of around $30.1 million), the likely benefits of the regulations are assessed as exceeding the costs.

Assessment of the options using the MCA framework also suggests that the proposed Regulations are superior to the alternatives. Most importantly, the proposed Regulations are assessed as the most effective in achieving the government’s policy objectives.

The proposed Regulations ensure that game is hunted in a sustainable, controlled, humane and ethical manner and define and encourage responsible and conservative hunting practices. The proposed Regulations will also ensure that game resources are shared equitably between recreational hunters and other user groups. Game hunters will benefit from continued recreational hunting opportunities in Victoria and industries will benefit from providing the goods and services to support the pursuit.

The proposed Regulations will prescribe the conditions and restrictions relating to the hunting of game in Victoria and, in some cases, areas where hunting is not permitted or is restricted in some way. Tools used to achieve this include the prescription of open and close seasons, bag limits, and permitted hunting methods. The proposed Regulations will also prescribe the licensing requirements for game hunters and the tag and checking station requirements for Hog Deer hunters. Conditions relating to the possession and use of game will also be prescribed.

The majority of the existing arrangements for game hunting in Victoria will remain unchanged under the proposed Regulations. However, some new and amended regulations are proposed. In almost all instances, the changes to the proposed Regulations will generally lower the regulatory burden and allow growth in the industry without compromising the Government’s objectives. (For details of the proposed Regulations see Attachment A , along with a comparison of the current regulations and proposed Regulations, see Attachment B.) The key changes contained in the proposed Regulations are summarised at the end of this section in Box 1 on page 12.

The proposed Regulations are broadly consistent with the objectives and actions in other jurisdictions, however, there are some state-specific variations that take into account the difference in conditions, geography and game species. The proposed Regulations are authorised to be made under sections 22A, 58C and 87 of the Wildlife Act 1975.

Proposed fees

The Government incurs costs in administering Victoria’s game and hunting regimes. The rationale for charging fees is that those individuals who privately benefit from a government service or regulated activity should make some contribution to costs incurred by government in providing that service or activity.

The Victorian Cost Recovery Guidelines apply to cost-recovery arrangements of government departments and include the recovery of the costs incurred by government in providing goods and services.⁹The government policy is that regulatory fees and user charges should generally be set on a full cost-recovery basis; however, if it is determined that full cost-recovery is not consistent with other policy objectives of the government, then it may not be appropriate to introduce a full cost-recovery regime. Consideration may be given to a regime that includes partial cost-recovery (if it can be demonstrated that a lower than full cost-recovery does not jeopardise other objectives) and/or to rely on other funding sources (e.g. general taxation) to finance the government activity.

Fees were generally calculated on an activity-based ‘bottom up’ approach. Each activity in processing and administering was identified and time taken to carry out these functions was estimated by DPI and the Department of Sustainability and Environment (DSE). The physical cost of consumables (e.g. paper, licences, etc.) was apportioned according to the proportion of licences issued. Enforcement and compliance costs were identified by DPI, Parks Victoria and Victoria Police. It proved difficult to directly attribute many of these costs to the proposed Regulations (i.e. many costs associated with compliance are imposed by the Act itself or other legislation, e.g. the Firearms Act 1996). Nevertheless, based on consultation with relevant agencies, 25 per cent of the total compliance costs were attributed to activities covered by the proposed Regulations.

DPI considers that the cost base on which the fees are calculated are efficient, as the proposed fees have not increased significantly since 1995 (other than indexation increases from 2005). This suggests internal efficiencies within DSE and DPI that have kept fee levels stable.

An assessment was undertaken to determine the most appropriate fee model. The analysis suggests that cost-recovery, with concessions available for relatively less well-off groups, is preferred. The principal reason for this is that this model satisfies efficiency grounds by collecting the majority of fees at the cost-recovery rate, while reducing barriers to access game hunting for some of the less well-off groups in the community.

Table 2: Proposed fees for the Wildlife (Game) Regulations
Fee item	Current fee ($)	Proposed fee ($)	Change (%)
Game birds	48.80	48.30	-1%
Deer	48.80	48.30	-1%
Game birds and deer	78.20	76.70	-2%
Fee for variation of game licence	12.20	12.50	2%
Issue of replacement game licence	12.20	12.50	2%
Waterfowl Identification Test (WIT)	26.80	25.00	-7%
Hound Hunting Test (HHT)	24.60	25.00	2%
Deer – non-resident fee	n.a.	48.30	–
Game birds – non-resident fee	n.a.	48.30	–
Game birds and deer – non-resident fee	n.a.	76.70	–

DPI estimates that these fees will raise approximately $1.9 million per annum based on 41,500 licensed hunters. Over a 10-year period, the proposed fees will raise around $15.9 million (PV). However, DPI proposes that no fees will be charged for persons under 18 years of age and eligible recipients within the meaning State Concession Act 2004 will be charged fees at half of the full rate. No concessions are proposed for the WIT and Hunting with Hounds Test (HHT). This is because these tests only need to be passed once and the fee levels are not considered to act as a barrier to undertaking hunting. The total value of concessions per annum is in the order of $285,000, which is equivalent to a cost-recovery of 88 per cent of the costs.

The rationale for exempting under-18s from the fee base rests on two main arguments: equity and the existence of some positive externalities. Consistent with the fee exemption for recreational fishing licences for under-18s, the proposed exemption seeks to ensure that financial barriers do not place the less well-off at a disadvantage, preventing them from participating in game hunting. While full cost recovery for under-18s may not appear large ($48.30), the cumulative effect of other regulatory burdens may act as a deterrent. For example, under-18s need to hold a junior Firearms Licence and pass a firearms safety test (no similar arrangement existing for fishing licences). With respect to positive externalities, this implicitly recognises that younger Victorians would benefit from a better understanding of the natural environment and wildlife; would benefit from an active outdoor lifestyle; and would encourage younger persons to use Victoria’s magnificent public lands. In addition, game hunting activities have the potential to strengthen family and social bonds, as well as providing ongoing and direct training which may lead to safer and more experienced game hunters. The need for direct supervision of juniors not required to sit the Waterfowl Identification Test or Hound Hunting test by fully licensed adults will mitigate the possibility of negative externalities for younger, inexperienced hunters to inadvertently target non-game species.

The value of the exclusion of under-18s from the fee base is in the order of $33,500 per annum. While an increase in the number of under-18s taking up game hunting would increase the value of this concession, the longer term economic impacts are likely to be positive. This would be the case if a proportion of under-18s developed an interest in game hunting that carries on into adulthood. The attendant expenditure on game hunting in Victoria is noted above.

Groups affected

The major group that will be affected by the proposed Regulations is game hunters who will be required to comply with the regulations when hunting game. Game hunters will continue to be required to pay a Game Licence fee to hunt game in Victoria in accordance with cost-recovery principles and pass tests in order to hunt duck or Sambar Deer with hounds.

Many industries will benefit from game hunting, including those associated with the manufacture, maintenance, importation and retail sale of firearms, ammunition, and camping, boating and motor vehicle equipment. Many hunters also use dogs to assist in hunting which creates a market for the dogs themselves, dog food, training and housing accessories and veterinary care. Many rural townships and regional businesses will also benefit from an influx of hunters during open seasons, where food, accommodation, hunting accessories and fuel are purchased. The general community will benefit from the assurance of the proper conservation and maintenance of game resources and their habitats and from controlled and safe hunting methods.

It is also acknowledged, at the margin, that other recreational users of public land may be impacted by game hunting, particularly around peak periods such as the duck opening season.

Conclusion

This Regulatory Impact Statement concludes that:

the benefits to society of the proposed Regulations exceed the costs;
the net benefits of the proposed Regulations are greater than those associated with any practicable alternatives; and
the proposed Regulations do not impose restrictions on competition.

Public consultation

The prime objective of the RIS process is to enable members of the public to comment on proposed Regulations before they are finalised. Public input, which draws on practical experience and expertise, can provide valuable information and perspectives, and thus improve the overall quality of regulations. Therefore, the proposed Regulations are being circulated to key stakeholders and members of the community for consideration. Game Victoria within DPI, which will administer the proposed Regulations, welcomes and encourages feedback.

DPI has prepared this RIS to provide stakeholders the opportunity to comment on the proposals. While comments on any aspect of the proposed Regulations are welcome, stakeholders may wish to comment on:

ways in which the licence application process can be streamlined;
the proposed short-term licences for hunting or taking non-indigenous game birds on a game bird farm;
hunting ducks or Sambar Deer with hounds without the need to pass the respective tests, but under direct adult supervision;
the proposed non-resident Game Licence;
while the Act provides that a game licence may be issued for a period of up to five years, current administrative practice is to issue a game licence for a maximum period of three years. Would there be benefits or demand for a Game Licence with a five year duration?;
whether the current measures for managing duck hunting protestors are adequate to protect public and law enforcement agency personal safety without unnecessarily restricting human rights. This proposal is not contained in the draft regulations but is included for discussion purposes;
whether an exemption for juniors and/or women to use lead shot in small gauge shotguns for duck hunting is appropriate, given the relatively small number of hunters involved (estimated to be a maximum of 500) and the relatively small amount of lead shot that would be involved. This proposal is not contained in the draft regulations but is included for discussion purposes;¹⁰
given the close scoring in the assessment of the fees, whether the concessions should be removed from the proposed fees. In particular, is the fee exemption for under-18s appropriate?;
changes to approved methods for hunting deer, including the use of Harriers, deer hunting dogs and additional gundog breeds;
changes to accommodate technological advances in firearms, bows and ammunition;
ways in which the Hog Deer tag or checking station regulations could be improved;
whether the areas proposed for closure to forms of deer hunting are appropriate;
any practical difficulties associated with the proposed Regulations; and
any unintended consequences associated with the proposed Regulations.

It should be noted that the issue of whether there should be game hunting is outside the scope if the RIS. The Government has already made the policy decision that it will permit game hunting (as provided for under the Wildlife Act 1975) given the economic benefit to the State that has been measured at approximately $96 million.

All submissions will be treated as public documents and published on the Department of Primary Industries website

Box 1: Proposed key changes in the Wildlife (Game) Regulations 2012
*Game Licences* Remove the requirement for people under the age of 18 years (‘juniors’) to pay a Game Licence fee. Create a new ‘Provisional’ Game Licence for persons aged between 12 and 17 years of age. This licence will be a free, once-off licence valid for one calendar year, or part thereof. The licence will enable juniors to hunt duck or Sambar Deer with hounds without sitting the respective tests, but only while under the direct supervision of an appropriately licensed adult. Create a new Non-resident Game Licence. This licence will be for the duration of 14 days and will allow non-residents of Australia to hunt duck or Sambar Deer with hounds without passing the respective tests, but only while under the direct supervision of an appropriately licensed adult. A Non-resident Game Licence will allow non-residents of Australia to hunt game other than duck and Sambar Deer with hounds and without the need for direct supervision, as there are no requirements to pass a test for these species (i.e. Sambar Deer while stalking, other deer species, Stubble Quail and other non-indigenous game birds).Non-residents must still abide by the game hunting laws. Create a new Game Bird Farm Hunting Game Licence. This licence will be valid for 7 days and will apply to non-indigenous game birds only hunted on game bird farms. This licence will be issued at no cost. Extend requirements for persons to notify the department of any convictions relating to hunting from other states and territories, not just Victoria, as previously required. Extend the period required to notify the department of a change of address from 7 days to 14 days. *Hunting methods* Allow the use of 10 gauge shotguns to hunt game birds. Broaden the current firearm and archery requirements for deer hunting to facilitate technological and market advances, without compromising animal welfare. Allow the use of fully or partially rifled firearms (i.e. shotguns specifically designed for deer hunting)for deer hunting. Provide authority for the department to issue permits to allow the use of antique (pre-1900) shotguns with a gauge greater than 10. Allow the use of shotguns with blanks to aid in gundog training. Broaden the use of electronic devices permitted to accommodate technological and market advances (e.g. two-way radios, GPS collars for hounds). Update the non-toxic shot list to provide for technological and market advances. Amend the definition of spotlight to reflect current advances in technology. *Sambar Deer hunting with the use of hounds* Allow Harriers to be used for hound hunting, in addition to Beagles and Bloodhounds. Prescribe the maximum height and breed standards of hounds in regulation. Allow the training of up to three hound pups in addition to the current pack limit of five hounds. Allow two additional junior hunters (under the age of 18 years) to hunt without being considered part of the 10 person hunting team limit. Change the start of the hound hunting season to 1 April every year, but close the season shortly prior to and shortly after Easter (i.e. the Thursday before Easter Sunday until the Thursday after Easter Sunday, when Easter falls in April). Allow hounds to be registered for life once they are mature (12 months), rather than renewing registration every three years. Provide options that remove the requirement for hound owners to put their residential address on the collar of the hound. Remove the option to identify a young hound by ear tattoo and replace it with the requirement for microchipping – consistent with the Domestic Animals Regulations 2005. *Deer hunting with dogs* Create a new category of approved ‘deer hunting dogs’ to allow dogs other than hounds or gundogs to be used for hunting deer (except for Hog Deer). These dogs are mostly Terrier breeds. Set the maximum number of gundogs and approved deer hunting dogs to two and create an offence for dogs that maim or attack wildlife. Allow all deer species, except for Hog Deer, to be hunted with the aid of gundogs and deer hunting dogs. This does not apply to hounds. Allow gundogs and deer hunting dogs to be used throughout the state. This does not apply to hounds. Approve the use of three new gundog breeds, allowing a total of 28 breeds that can be used for hunting deer (other than Hog Deer) and game birds. *Hunting other* Extend the Red Deer open season from two months to the whole of the year. Allow the selling of taxidermied game products, such as deer heads or mounted ducks, which have been obtained legally. Remove the requirement for the return of unused Hog Deer tags. Add the Mitchell Shire to ‘recognised deer habitat’.

¹ Department of Treasury and Finance, 2011, 2.1 ed, Victorian Guide to Regulation incorporating: Guidelines made under the Subordinate Legislation Act 1994, August 2011, Melbourne

² Norman, F. I. and Young, A. D., 1980, ‘Short-sighted and doubly short-sighted are they. A brief examination of the game laws of Victoria, 1858 – 1958’, Journal of Australian Studies, 7: 2-24

³ Note that many hunters hold licences covering multiple game categories; therefore the numbers cannot be simply added.

⁴ Gormley, A.M. and Turnbull, J. D., 2011, Estimates of Harvest for Deer, Duck, and Quail in Victoria: Results from Survey of Victoria Game Licence Holders in 2011, Arthur Rylah Institute for Environmental Research, Technical Report Series No. 224, Department of Sustainability and Environment, Heidelberg, Victoria

⁵ Game Licensing System database (July 2012), Department of Primary Industries.

⁶ Loyn, R.H., 1989, The Management of Duck Hunting in Victoria – A Review, Arthur Rylah Institute for Environmental Research, Technical Report Series No. 70

⁷ This methodology is described in detail in Section 4.2.3.

⁸ Arguably, the prescription of calibres, projectile weights and dog and hound breeds influence hunter behaviour. These elements have not been costed in this RIS given that in most cases ethical hunters would use such calibres, projectiles, etc. and that the cost of substitution is relatively low. In addition, these elements would be extremely difficult to cost given the wide range of possible alternatives.

⁹ Department of Treasury and Finance, 2010 Cost Recovery Guidelines, Melbourne