This submission responds to the following consultation documents:
– Discussion Paper – Towards a risk-based approach to wildlife licences
– Revised NSW Native Animals Keepers Species List
– Draft Code of Practice for Keeping Native Reptiles
– Draft Code of Practice for Keeping Native Frogs
– Draft Code of Practice for Keeping Native Birds
EDO NSW generally supports a risk-based approach to wildlife licences. However, it must be recognised that the use of Codes may provide a defence against actions that would otherwise constitute a legal offence. As such, it is vital that risk-based management is precautionary in its approach to assigning risk and is supported by clear and enforceable management requirements. In this regard, EDO NSW submits that there should be a number of improvements made to the proposed risk-based approached and the draft Codes, should they be adopted.
