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(VIC) Mandate Public Disclosure of Decision Criteria and Reasoning Applied to Wildlife Control Permits
- Ophelia Davenport
- Sep 23
- 5 min read
Updated: Oct 7
Author: Ophelia Davenport | Publish date: 23/09/2025
Problem Identification:
In VIC, the reasoning and decision criteria applied to Authority to Control Wildlife (ATCW) permits are not publicly disclosed.
Section 28A of the Wildlife Act 1975 (VIC) (the Act) does not include a provision that requires public disclosure of how the assessment criteria for issuing ATCW permits are applied.
This means that detailed criteria or reasonings for each approval are not available to the public. Wildlife Victoria has argued that the ATCW permit system operates without transparent decision-making standards, which undermines public confidence in the system. Further, they have highlighted that limited transparency could hinder opportunities for public scrutiny and government accountability.
Context:
An ATCW permit refers to a license which ‘allows a person to shoot, wilfully disturb or trap wildlife where it is damaging property, crops or other wildlife habitat or for the purposes of management, conservation or protection of wildlife.’ Currently, the VIC government publishes annual data showing the number of issued ATCW permits.
The Conservation Regulator (VIC government body) has stated that, since commencing a public review process in 2017, it has been committed to ‘progressing a range of measures to improve the [ATCW] system.’ It has said that this includes working to improve publicly accessible website information to ‘provide current, relevant, and clear information regarding the ATCW decision-making process.’ However, no provisions have been added to the Act to enforce this commitment.
According to a 2018 VIC government review of the ATCW system, a more transparent assessment process could improve community confidence in the validity of issued permits. Wildlife Victoria has contended that decision-making transparency could help reduce perceptions of bias in permit decisions, leading to increased public trust in the effectiveness of the Conservation Regulator.
With this, the 2018 system review said that there are fewer opportunities for public oversight, reducing the ability to question or improve decision-making. According to a 2021 Expert Advisory Panel’s review of the Act, the lack of transparency surrounding ACTW permits has been a primary reason that those outside the process have been prevented from challenging authorisation decisions. Wildlife Victoria has expressed that greater transparency could help the public evaluate the effectiveness of the regulatory body's decision-making and its oversight of the wildlife control permit system.
Advice/Solution Identification:
The VIC Minister for the Environment should add a provision to section 28A of the Wildlife Act 1975 (VIC) to require public disclosure of both the assessment criteria for ATCW permits and a statement of reasoning showing how the criteria were applied in each decision.
The Law Institute of Victoria has recommended that ‘expanded reporting requirements be included in the Wildlife Act for the granting of permits and authorisations to provide for transparency and accountability about decisions made in respect of wildlife.’ Further, the LIV submits that clear and publicly accessible criteria for permit applications be made available.
Precedent:
If VIC were to enact this reform, it would be world-leading, to the author’s knowledge.
Public Support:
News Coverage:
The Courier - “Wildlife advocates call on the state government to improve the transparency of animal relocation permits.” Animal welfare advocates say the government needs to improve the transparency of animal relocation permits to ensure companies are held accountable for animal populations. By: Malvika Hemanth | 5 October 2023 - The article can be found here, but may not be accessible due to a subscription paywall.
Where to go to learn more:
Expert Advisory Panel’s Review of the Wildlife Act 1975 - Section 7 of this consultation summary report has presented views on ATCW permits, drawn from submissions to the 2021 review of the Wildlife Act 1975 (VIC). Download and read the full report here.
The Authority to Control Wildlife (ATCW) System Review - This 2018 consultation response summary has captured a range of stakeholder concerns about the ATCW system, along with initial suggestions for reform. Notably, Theme 5 has offered general commentary on how information about the ATCW system could be better provided and shared. Download and read here.
Environmental Justice Australia and Humane Society International, ‘Failing Our Wildlife’ - This 2020 report has identified key issues with the Wildlife Act 1975 (VIC), including Section 28A. Read here.
Humane Society International, ‘Licence to Kill’ - This 2024 report quantified the national scale of licensed killing of Australia’s native wildlife, using data obtained from state and territory governments. It examined licensing frameworks across jurisdictions (including VIC) and their practical implementation. Read the full report here.
Law Institute of Victoria, ‘The Independent Review of Victoria’s Wildlife Act 1975’ - Parts 3 and 4 of this submission to the 2021 independent review of the Wildlife Act 1975 (VIC) addressed concerns around transparency, accountability and reporting in relation to ATCW permits. View the submission here.
Human Perspective:
When Brenda, a wildlife carer in regional Victoria, received a distressed call about a mob of kangaroos being shot on a neighbouring property, she was left heartbroken and confused. The landowner had obtained an ATCW permit but no details were available about what evidence was provided, whether non-lethal measures were considered, or how the decision was reached. For Brenda, who has spent years rehabilitating orphaned joeys, the lack of transparency felt like a betrayal. She had no way of knowing whether the cull was truly necessary or whether alternatives had been ignored. This uncertainty also undermined her trust in the system. Without clear, public criteria for decision-making, Brenda believes that she and others cannot meaningfully engage in discussions about wildlife management, nor can they hold the government accountable when they believe there has been an error.
To protect the anonymity of those involved, this is a fictionalised account drawn from an amalgamation of real-life stories, experiences, and testimonials gathered during the research process for this brief. Any resemblance to actual individuals is purely coincidental.
Conflict of interest/acknowledgment statement:
N/a
Support
If your organisation would like to add your support to this paper or suggest amendments, please email Info@foreaustralia.com.
Reference list:
Law Institute of Victoria. (2021, July 2). Independent Review of the Wildlife Act 1975. https://engage.vic.gov.au/download/document/16095
Peterson, D., Brockington, J., Hellstrom, J. & Pascoe, J. (2021, October 19). Expert Advisory Panel's Review of the Wildlife Act 1975 Consultation Summary Report. The State of Victoria Department of Environment, Land, Water and Planning. https://engage.vic.gov.au/download/document/16019
The State of Victoria Department of Environment, Land, Water and Planning. (2018). The Authority to Control Wildlife (ATCW) system review: Consultation Response Summary. https://engage.vic.gov.au/download/document/3641
Victoria State Government. (2025, June 3). Wildlife management and control authorisations. https://www.vic.gov.au/wildlife-management-and-control-authorisations
Victoria State Government. (2021, July 1). Reforming Victoria's authority to control wildlife system. https://www.vic.gov.au/reforming-victorias-authority-control-wildlife-system
Victoria State Government. (2025, April 4). Authorities to Control Wildlife: 2024. https://www.vic.gov.au/authorities-control-wildlife-2024
Wildlife Victoria. (2021, June). Independent Review of the Wildlife Act 1975. https://engage.vic.gov.au/download/document/16081
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