Disclaimer: This document provides legal information only and does not replace the need for professional legal advice in individual cases. While every effort has been made to ensure the information is accurate, the EDO does not accept any responsibility for any loss or damage resulting from any error in this document or use of this work.

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.