Unnecessary and anticompetitive restrictions

Submission to Manager Extensive Agriculture Branch, DPIW

11 March 2008 (PDF version, 51KB)

Mr. Robin Thompson
Manager Extensive Agriculture Branch
DPIW   
PO Box 46
Kings Meadows 7249

Dear Robin;

My wife and I were delighted to hear that the Regulations in which dorper sheep are included as prescribed animals are to be reviewed. The registration process and code of practice are designed to deter the ownership and breeding of the four disparate sheep breeds included in the legislation. This ‘exotic’ sheep legislation ignores science and is severely impeding the development of alternative sheep industries in Tasmania.

Under the legislation in Tasmania we are required to let potential purchasers know they must register with the DPIW, fill in several pages of paperwork, and submit to an inspection of their property. Discouraging enough but we have also lost clients deterred by the requirements of the compulsory Code of Practice, the implicit threat of prosecution for non-compliance and the stigma that now surrounds these breeds due to the sustained spin campaign of the wool industry in this State.

The current situation is inequitable, is patently discriminatory, solves no wool contamination problems and puts us at a severe disadvantage in the marketplace.

Tasmania has many sheep breeds recognized as having the potential to ‘contaminate’ or reduce the quality of fine wool, some with similar characteristics to the dorper. However none of them have restrictions placed on their usage, giving those breeders a competitive advantage. Indeed no other sheep breeders in Australia are limited in their marketing opportunities in this manner and we feel this constitutes a restriction of trade.

To varying degrees all British breeds and the European breeds have the potential to transfer dark and medullated fibres to merinos. Merinos of course, despite the best efforts of geneticists also carry some dark and medullated fibres. In response to improved prices for prime lamb there has been a 60% increase in non-merino breeds (of which the alternative breeds represent a tiny fraction) in Australia over the past decade. Couple this with an increase from 15% to 44% in merinos mated to non-merino sires from 1990-2002 (anecdotally in excess of 60% in some states), all raising cross-bred lambs and we have the recipe for the increase in dark and medullated fibres noted in the Australian wool clip. Irrational claims made by some within the wool industry, such as the capacity for “wind blown fibres” shed by ‘exotic’ sheep to contaminate the wool of merinos in the paddock next door, were thoroughly discredited by research (Hatcher et al). Similarly education has shown that fibre transfer can be avoided through standard management and hygiene practices such as those employed to minimize contamination from the traditional British and European sheep breeds.

The literature review ‘Managing the Risk of dark and/or Medullated Fibre Contamination’ (Hansford, 2003) presents a more balanced case regarding historical and current wool contamination issues. This review confirms it is more difficult to detect isolated contaminant fibres from poorly bred Merinos than it is for merinos run with the new breeds. Similarly research also indicates that fibres transferred from coloured conventional sheep run with white wool sheep pose a far greater risk of contamination in terms of persistence throughout processing than do fibres from the new breeds. Unfortunately the wool industry can’t legislate against poor breeding and poor husbandry practices amongst its wool producers, but here in Tasmania it appears you can legislate against a contrived perception.

In fact we consider the legislation to be an insult to the integrity of Tasmanian wool producers

Tasmanian wool producers work within quality assurance parameters intended to provide confidence to prospective purchasers, as do our wool producing competitors nationally and internationally. Schemes such as the Tasmanian Quality Wool scheme, the AWEX Code of Practice for Preparation of Australian Wool Clips and most recently the national vendor declaration scheme for Dark and /or Medullated Fibres were developed to ensure truth in labelling and to cope with any contamination potential. The CSIRO with funding from AWI has developed a low cost test for dark & medullated fibre (dmf) by core sampling bales to further provide buyers and processors with a reliable measure of dmf’s in sale lots. Equipped with these tools, clearly the responsibility for managing any contamination risk lies solely with the woolgrower.

Diversification is considered the life blood of agriculture, however the Regulations and the attendant Code of Practice has rendered four distinct sheep breeds, un-fettered by red tape in every other State of Australia, commercially unviable choices for diversification in Tasmania.

The dorper is a hardy adaptable breed that does not require shearing, crutching or mulesing and offers the advantage of low chemical and low labour inputs. We feel dorper sheep can complement prime lamb production here in Tasmania and are an ideal choice for organic lamb production or for those land managers who do not wish to be part of the wool industry. Within all other states of Australia dorper sheep numbers are increasing exponentially as farmers realise the benefits of this breed, allowing more flexible and sustainable grazing regimes under a variety of climatic conditions. With the ever increasing cost of production, exacerbated by drought in all States including Tasmania, it is imperative that Tasmanian sheep producers, like their mainland counterparts, should be free to exercise their right to take advantage of market opportunities as they arise.

In 2001 when the traditionalist merino breeders forming the TFGA wool council tried to ban dorpers from Tasmania, the Minister for Primary Industries at the time, the Honourable David Llewellyn, told TFGA that the issue should be resolved “... through grower education and/or the introduction of vendor declarations for wool sales”. In 2008 there is no excuse for wool grower ignorance. Technological changes in wool testing have been and will continue to be made and a variety of quality assurance schemes are in place. We sincerely hope that Minister Llewellyn, revisiting his old portfolio, will not allow the Tasmanian sheep industry to be held back any longer by old thinking and vested interests and we trust his views from 2001 will be reflected in his decision today.

Yours Sincerely,

Jim & Joanna Lyall

Brocburn Dorper and White Dorper Stud

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