AJP ACT response to the Draft Technical Report – Managing wombats: A review of current practice, issues and challenges to inform wombat management in the ACT
Background: The Animal Justice Party aims to give a political voice to animals, to pursue the vital issues of animal protection through Australia’s political system and to encourage political parties to adopt animal-friendly policies
Introduction & Core Position
The Animal Justice Party ACT (AJP ACT) is responding to the ACT Government's Draft Technical Report, Managing wombats: A review of current practice, issues and challenges. Guided by our core political principles of Kindness, Equality, Rationality, and Non-Violence, the AJP represents the interests of animals as sentient individuals who possess an intrinsic right to live free from human-mediated harm, displacement, and exploitation.
Wombats are an iconic, highly sentient native species deeply interwoven with the ecology of the Australian Capital Territory and the cultural heritage of Traditional Custodians.
The primary position of the AJP ACT is one of absolute opposition to Recommendation 5 of the report, which suggests exploring a Controlled Native Species Management Plan (CNSMP) for Bare-nosed Wombats under the Nature Conservation Act 2014.
AJP ACT firmly rejects any policy trajectory that opens the door, either immediately or in the longer term, to the lethal control, culling, or commercialised management of wombats. Instead, the ACT Government must commit to an entirely non-lethal, evidence-based, compassionate framework that supports landholders through non-violent mitigation tools and expands community-led health initiatives to combat sarcoptic mange.
1. Absolute Rejection of a Controlled Native Species Management Plan (CNSMP)
The suggestion to evaluate a CNSMP for Bare-nosed Wombats is a dangerous regulatory step. In the ACT, the CNSMP mechanism (as seen with Eastern Grey Kangaroos) has historically functioned as a bureaucratic pathway to justify large-scale, ongoing lethal culling under the guise of "environmental balance" or asset protection.
Declaring wombats a "controlled native species" shifts their legal and cultural status from a fully protected native animal to a problem to be managed or suppressed. AJP ACT rejects this framework for the following reasons:
- Absence of a Scientific Evidence Base: As highlighted by the Conservation Council ACT Region, the Draft Technical Report explicitly concedes a profound lack of reliable, long-term population data for wombats in the Territory. Worryingly, the report relies heavily on anecdotal feedback and data from sources up to 51 years old to imply population increases. It is ecologically reckless to establish a regulatory framework for a "controlled" species based on guesswork and outdated literature.
- A Slippery Slope to Lethal Control: While the government states that the report does not currently propose a cull, creating a CNSMP builds the legislative scaffolding required to authorise lethal control in the future. The AJP ACT maintains that lethal management is a moral and ecological failure that should be completely ruled out.
2. Wombats as Crucial Ecosystem Engineers
The draft report heavily emphasises the "complexities" and "damage" caused by wombats to human infrastructure and agricultural assets. This narrow focus overlooks the immense ecological benefits wombats provide to the ACT environment.
Wombats are vital "ecosystem engineers." Their extensive burrowing networks play a crucial role in:
- Soil and Hydrology Health: Turning over tonnes of soil, which aids nutrient cycling, prevents topsoil compaction, and increases water infiltration into dry landscapes.
- Wildlife Refuges: Wombat burrows are documented lifesavers for a myriad of other native species, including small mammals, reptiles, and birds, providing critical microclimates and survival refuges during extreme weather events, bushfires, and floods.
By framing wombats primarily as a source of property damage, the report skews the narrative toward conflict rather than coexistence. Wombats are a public asset to biodiversity, and policy should protect them accordingly.
3. Flawed Consultation and Data Deficiencies
The AJP ACT shares the serious concerns raised by wildlife groups regarding the narrow scope of the consultation process used to draft this paper.
- Unrepresentative Feedback: The draft report indicates that less than 1% of rural landholders in the region were consulted, while broader community members, urban-edge developers, and Traditional Custodians were largely left out of the initial scoping phases.
- The Danger of Anecdotal Policy: Policy decisions impacting the life and safety of native animals must never be driven by localised frustrations or self-reported agricultural grievances. Before any long-term strategy is finalised, the ACT Government must fund comprehensive, independent, and peer-reviewed spatial mapping and population monitoring across the Territory to determine the actual conservation status and distribution of our wombats.
4. Prioritising and Funding Non-Lethal Coexistence
Property conflict between landholders and wombats is highly preventable through existing, non-violent infrastructure modifications. Rather than looking toward legislative control mechanisms, the ACT Government should actively subsidise and mandate non-lethal interventions.
We call for government-funded initiatives to support rural leaseholders and urban-edge properties with:
- Wombat-Friendly Fencing and Gates: Providing technical assistance and financial grants to install heavy-duty exclusion fencing equipped with one-way swinging wombat gates, allowing animals to move through designated corridors without destroying fence lines.
- Burrow Stabilisation and Humane Deterrents: Standardising best-practice non-lethal deterrents (such as structural reinforcement, acoustic deterrents, or scent-based mapping) to naturally steer wombats away from high-value infrastructure like dams or foundations before burrows are established.
- Roadstrike Mitigation: The report notes wildlife-vehicle collisions as a major issue. The ACT should invest in wildlife underpasses, virtual fencing technology, and reduced night-time speed limits in high-density wombat corridors to address road trauma.
5. Compassionate Health Management and Mange Treatment
Sarcoptic mange (introduced via European foxes and domestic animals) is a horrific, painful, and fatal disease plaguing ACT wombat populations. Wombats have a fundamental right to be free from this introduced suffering.
The AJP ACT strongly advocates for the following approaches to health management:
- Support, Don't Restrict, Carers: The draft report expresses concern over the unregulated use of mange treatments (like Cydectin) near aquatic systems. While environmental safety is important, the government must not use this as an excuse to tie wildlife carers up in red tape or restrict access to life-saving treatments. Instead, the government should collaborate directly with expert organisations, such as Wombat Rescue and ACT Wildlife, to supply approved treatments and streamline delivery pathways.
- Expand the Community Mange Treatment Program: The ACT Government should provide long-term financial, logistical, and technical resources to expand volunteer-led programs. Utilising burrow flaps that automatically apply anti-parasite medication as wombats enter their homes is a highly effective, non-invasive method that requires state-level support to scale up.
- Strict Criteria for Euthanasia: While the report recommends a mechanism for the humane euthanasia of wombats with severe mange on rural lands, the AJP ACT insists this must only occur under strict, independent veterinary oversight where recovery is biologically impossible. Euthanasia must strictly be an act of immediate mercy for the individual animal, never an off-the-record tool used by landholders to clear wombats from private property.
Summary of Key Recommendations
- Formally strike out any reference to or future consideration of a Controlled Native Species Management Plan (CNSMP) for wombats.
- Commit explicitly to a 100% non-lethal framework, legally ruling out culling, commercial exploitation, or lethal relocation.
- Establish a Wombat Coexistence Fund to financially assist rural leaseholders with the purchase and installation of wombat gates, fencing, and non-lethal deterrents.
- Provide ongoing operational funding to volunteer wildlife rescue groups to expand non-invasive, community-led mange treatment programs.
- Mandate comprehensive, independent scientific studies to establish accurate baseline data on wombat populations, completely replacing anecdotal reporting in government policy.
The ACT has a unique opportunity to lead the nation in compassionate, progressive wildlife management. By rejecting the outdated, violent paradigm of "pest control" and embracing funded, evidence-based coexistence, the ACT Government can protect these vital ecosystem engineers for generations to come.
The Animal Justice Party ACT