Draft Eco-Certification Program – Response from Wildlife Tourism Australia
12 December 2003
Please address any correspondence on this issue to:
Dr Karen Higginbottom
Secretary, Wildlife Tourism Australia
k.higginbottom@griffith.edu.au
ph. 07 5545 3498
Overall Comments
WTA supports the significant expansion of the program from the previous version in terms of criteria relating to impacts on wildlife and their habitats. We believe that the Eco-Certification Program can play an important role in raising standards in these areas.
The sections and topics that are included are appropriate given the current state of knowledge and practice in this area. However we expect that in the next update of this scheme we will be able to provide more detailed feedback relating to specific species and forms of wildlife tourism activities.
We also support the inclusion of sections on conservation initiatives.
The definition of ‘natural areas’ needs further consideration as far as it relates to wildlife. The criteria seem tailored for totally uncontained populations, with an emphasis on protected areas, and yet there is a continuum from such areas through to zoos, and when much wildlife tourism occurs on private land or other tenures. Some wildlife sanctuaries (e.g. the smaller Earth Sanctuaries, certain naturalistic wildlife parks) contain natural habitat, and yet are enclosed and sometimes involve more intensive management of wildlife than occur in totally free-ranging situations.
We suggest that the current approach is appropriate given the lack of time for further consultation on this issue, but needs further consideration for the next update of the scheme.
The following comments are limited to issues relating specifically to the environmental impacts of wildlife tourism activities, and of other tourism activities on wildlife ie. principally sections 6.17, 6.18, 6.19, 6.27, 6.28, 6.29, 6.31.
6.17 Minimal Disturbance to Wildlife
Core criteria
Add:
Adopt an appropriate minimal approach distance to animal breeding sites (e.g. bird nests, seal breeding colonies)
Where activities involving wildlife do occur, customers are advised to avoid rapid or sudden movements, and to keep noise to a minimum
a) And e) How is the user to interpret ‘significant’? Perhaps replace with ‘observable’ or ‘detectable’?
d) This may be inappropriate for repeated viewing of wildlife on private land – e.g. viewing of kangaroos on farmstays.
f) Restate as ‘wildlife handling for the purpose of visitor viewing’.. since in some cases animals such as reptiles lying in the road might be removed for their own safety.
g) Remove example of ‘no feeding by hand’ as it falsely gives the impression that this applies generally
Advanced criteria
a) Regular rotation is not always the best practice. For example, if tours stay on tracks or roads following the same path each time, nearby animals such as kangaroos learn that they do not need to disrupt their behaviour when such groups pass – this can be good for both the animals and the tourists. Suggest that this criterion is deleted.
Clarify c) by stating ‘Regular, scientifically recorded data on animals sighted such as species, number and locality is provided….’
g) Again this does not seem appropriate for some activities such as regular watching of kangaroos on private land. Perhaps limit to protected areas, breeding colonies and threatened species? Another problem is: what happens if the operator would like the agency to assess the impact, but the agency does not do so (e.g. due to the ever problematic lack of resources)?
6.18 Minimal Impact Nocturnal Wildlife Viewing
Core criteria
First note should read ‘Minimal disturbance to’ not ‘Minimal impact’ to match section 6.17?
Fix wording of second note – ‘but’ should be ‘must’
a) The criterion ‘ Only guides should use spotlights’ should be relaxed to allow for situations, for example, where guide drives vehicle, and asks guest to use spotlight, under guide’s supervision.
a) Add ‘animals are not touched or approached at any time’ and ‘flash photography is prohibited’.
a) Research by Robyn Wilson indicates that light intensity, rather than filter colour, may be most important in terms of impacts on certain possum species. However this obviously varies between species, and good evidence on this aspect for most species is lacking. We suggest that use of red filters be replaced by stating that only low intensity lights (low wattage or through use of a filter) be used to shine at animals once they have been located.
a) Add that spotlights should be shone directly on animals for a minimal time, and should avoid their faces as far as possible.
We hope to provide updated information on spotlighting for the next version of the scheme.
Add:
e) When observing fairy penguins, the following measures are undertaken (in addition to those listed above):
. lights are not shone directly on penguins face at any time
. customers are advised to wear dark clothing to reduce visibility by wildlife
c), d) Consider deleting the criteria that are covered in a) and b), but ensuring that it is clear that these apply to all viewing of nocturnal wildlife (in a) replace ‘when spotlighting’ with ‘when viewing nocturnal animals’
Advanced criteria
a) Replace ‘infra-red binoculars’ with ‘infra-red viewing equipment’, as this may include other forms such as infra-red cameras and monitors.
6.19 Minimal impact marine mammal and mega fauna viewing
Add to the notes section ideally list the relevant codes of practice that are legally enforceable. These include boats and cetaceans, swimming with whale sharks.
a) Add to ‘staff member monitors behaviour’ ‘ in order to determine whether any adverse reaction is occurring’ or similar.
a) ‘codes of ethics adopted by commercial marine mammals’??? – fix wording. Need to be explicit – adopt codes as required by law and as recommended by relevant industry associations?
c) Wording of ‘customers are prepared for their reaction’ needs to be clarified.
6.23, 6.24 Minimal impact boat use
Add to notes that if tour involves deliberate or accidental encounters with marine mammals or mega fauna, relevant criteria from this section should be followed.
6.27 Minimal impact caving
Add to c)
Customers are advised not to shine lights directly on any cave dwelling animals
Section 6.30 Minimal impact trail riding and animal tours
Core criteria
Add:
A carry in – carry out policy should apply (whether there is a walking component of this type of tour or not).
Advanced criteria
Add:
. collect and carry out of all faecal matter produced by the animals during the trip (this is needed to stop spread of exotic plants).
Section 6.31 Minimal impact fishing
WTA notes that in order to achieve ecocertification (whether nature or ecotourism), fishing is not to be seen as the prime focus of an enterprise. Some of our members have concerns about enterprises that include fishing being able to obtain ecocertification. However we also recognise that it is valuable to raise environmental and animal welfare standards among enterprises that include fishing
Ensure structure of wording is made consistent (and throughout document) e.g. ‘use’ not ‘using’
Add point on avoiding catching threatened fish species?
Advanced criteria
Add: Monitor number of each species caught and other details and provide these to the relevant government authority.