🦎 Rules explained · Conservation Regulator

Rules-as-code · Plain-English guide

Assessing an Authority to Control Wildlife

The rules the Conservation Regulator's own officers follow when they assess an application to control wildlife (an ATCW) — who must sign off, when a property inspection is required, and who may approve it. This is the internal decision workflow, not the applicant's form.

Conservation Regulator 3 active rule groups · 4 notes/stubs Version v2.0.0 Source: staging

How to read this guide

Where the other wildlife rulesets look at an applicant, this one looks at the assessment — the Conservation Regulator's internal review of an ATCW application. It sets a few obligations on officers, works out whether a property inspection is needed, and records who is allowed to make the decision. Several sections are deliberate notes or unfinished stubs, and the risk logic has gaps worth knowing about (see Observations). Colour code: Obligated / Required, Permitted, Forbidden, Rules work out.

01

The big picture

An Authority to Control Wildlife (ATCW) lets a landholder take, disturb or destroy wildlife that is causing damage. Before one is issued, a Conservation Regulator officer assesses the application. This ruleset encodes three parts of that assessment:

  1. Two officers, kept separate — an assessing officer and a decision-maker must both be recorded, and they must be different people.
  2. Property inspection — for grey-kangaroo applications, the rules work out whether a site inspection is required (and must be completed) based on a list of risk and scale triggers.
  3. Risk & delegation — the rules record a risk level and who is permitted to make the decision.

The ruleset began as a separate project and was later merged into the wildlife-regulation project (its first section says so). That history shows: alongside the working rules are several empty placeholder sections, and the risk logic is only partly built.

Three ideas behind the rules

Idea 1

Separation of duties

The person who assesses an ATCW must not be the person who decides it. The rules compute whether the two recorded officers differ and make “they differ” an obligation — a machine-checkable integrity control.

Idea 2

Inspect when the stakes are higher

Grey-kangaroo control can be sensitive. Rather than always inspecting, the rules require a property inspection only when one of a list of triggers fires — public land, plans in play, proximity to people, small properties, applicant-history concerns, or large numbers for the region.

Idea 3

Low risk → the delegate decides

The intent is that low-risk applications can be approved by the Permissions Lead, while identified risks escalate to a manager. The delegation half is encoded; the escalation half is not yet (see Observations).

02

What the system asks about

The assessment record sits beside the application. Most of what drives this ruleset is on the assessment itself and on the two officers; the kangaroo-inspection rule also reads a set of application and region facts.

🗂️ The assessment

The Regulator's internal review of one application.

Person assessor / Person decision-makerYou providetwo officers
Different officers assess and decideRules work outyes / no · obligated
Is property inspection requiredRules work outyes / no
Is property inspection completedYou provideyes / no · obligated when required
Is low riskRules work out“Permissions Lead can approve”
Risk factors (first-time applicant, high numbers, welfare risk, …)You provideyes / no each

👤 The officers (Person Reviewer)

The assessing officer and the decision-maker.

Unique IDYou providestaff identifier · required
Is Permissions LeadYou providedefault ATCW delegate
Is Manager Reg. Operations / DirectorYou provideescalation roles

🦘 The application & region

Facts the kangaroo-inspection rule reads.

Wildlife is Eastern / Western Grey KangarooYou provideyes / no
Covers public land · adjacent to shelter · <1 km from suburbia · <10 haYou provideyes / no each
Number of animals to controlYou providea count
Region + its kangaroo limitYou provideHume/Gippsland/… + threshold
Method of control · is shootingYou provideyes / no
03

Two officers, kept separate

The “Assessment Officers” group encodes a separation-of-duties control in three moves:

  • The assessor's unique ID is Required.
  • The decision-maker's unique ID is Required.
  • A computed flag, differentOfficersAssessAndDecide, is set to “the two IDs are not equal”, and made Obligated — so an assessment where the same officer does both fails the obligation.

This is the digital form of the ATCW policy that assessment and decision must be made by different people.

04

When a property inspection is required

This group applies only to applications whose wildlife is an Eastern or Western Grey Kangaroo. For those, a property inspection becomes Required — and completing it becomes Obligated — if any one of a list of triggers holds.

Any single row triggers the inspection:

TriggerMeaning
Covers public landThe application includes public land.
A management plan is preparedA wildlife management plan or a kangaroo management plan exists.
Adjacent to a licensed wildlife shelterThe property borders a licensed shelter / foster carer.
Method is not shootingThe proposed control method is anything other than shooting.
Within 1 km of suburbiaLess than a kilometre from an urban / peri-urban area.
Property under 10 hectaresThe site is smaller than ten hectares.
Concerns about applicant historyRecorded compliance concerns about the applicant.
Over the region's kangaroo limitAnimals to control exceed the region's threshold — Hume 250, Loddon Mallee 250, Gippsland 100, Barwon South-West 100, Grampians 100, Port Phillip 20.

The region test is per-region: for each of the six regions the rule compares numAnimalsToControl against that region's own limit constant. The “method is not shooting” trigger is worth a second look — it means any non-shooting method forces an inspection (Observation 4).

05

Risk & who may approve

The “Risk assessment” group records a risk level and controls who may decide:

  • isLowRisk is set to true — unconditionally. Its description is “Permissions Lead can approve”, so a low-risk assessment is meant to be approvable by the delegate.
  • The decision-maker is Permitted to be the Permissions Lead.
  • But if the assessor is already the Permissions Lead, the decision-maker is Forbidden from also being the Permissions Lead — reinforcing the separation between assessing and deciding.

Because isLowRisk is hard-set to true and never re-evaluated against the risk factors, every assessment currently reads as low risk (Observation 1).

06

Notes & unfinished sections

Four of the ruleset's seven sections carry no working rules. They are recorded here because their presence shapes how the ruleset should be read — and what is still to be built.

  • “Overview: version control” — a note that the ruleset started as its own project and was merged into wildlife regulation. No rules.
  • “Incomplete application may be returned” — a note that the officer may return an incomplete application; the authors decided this “is not required” to encode. No rules.
  • “Common Wombats” — an empty heading; no wombat-specific assessment logic is present.
  • “Risk escalation” — the most consequential stub. It lists ten risk factors (first-time applicant, adverse community interest, unusually high numbers, high numbers for the property, locally restricted species, management plan required, four or more successive applications without alleviation, health/safety risk, uncommon control method, animal-welfare risk) in its condition — but its “then” branch is empty. The comment says “[LAST 4 DOT POINTS NEEDED]”. So the factors are wired up but trigger no escalation, no risk-level change and no manager sign-off (Observation 2).
07

Worked examples

🦘 A · A large grey-kangaroo cull in Hume

Given Wildlife is an Eastern Grey Kangaroo Yes
Given Region is Hume, limit 250
Given Animals to control 400
1 Grey-kangaroo guard is true.
2 Hume + 400 > 250 makes one trigger true, so the inner test passes.
3 isPropertyInspectionRequired = true; completing the inspection becomes Obligated.
A property inspection is required and must be completed before the assessment can proceed.

🧑‍⚖️ B · The same officer assesses and decides

Given Assessor ID E-1042
Given Decision-maker ID E-1042
1 Both IDs are required and present.
2 differentOfficersAssessAndDecide = (E-1042 ≠ E-1042) = false.
3 That flag is Obligated to be true, so the obligation is violated.
The assessment breaches the separation-of-duties obligation — the same person cannot both assess and decide.

⚠️ C · A high-risk application (today)

Given Applicant is a first-time applicant Yes
Given Risk to animal welfare is likely Yes
1 The escalation group's condition is satisfied (two of its risk factors are true).
2 Its “then” branch is empty, so nothing happens — no escalation, no risk-level change.
3 isLowRisk remains hard-set to true from the risk-assessment group.
Despite clear risk factors, the assessment still reads as low risk and permits delegate approval. The escalation path is not yet encoded (Observations 1–2).
08

Test cases

Coverage at a glance

0 test suites and 0 scenarios are defined for this ruleset.

None of the behaviour above — the separation-of-duties obligation, the grey-kangaroo inspection triggers, the per-region thresholds, or the delegation rules — is pinned down by an automated test.

This is a meaningful gap for a ruleset that encodes integrity controls. Worthwhile first tests would be: the same-officer case (expect the “different officers” obligation to fail); one positive and one negative per inspection trigger, including a boundary case at each region's kangaroo limit; the assessor-is-Permissions-Lead case (expect the decision-maker forbidden); and — once the escalation logic exists — a high-risk case expecting isLowRisk to become false.

Observations

1 · Risk is hard-coded to “low”

isLowRisk is set to true outright, with no dependence on the risk factors the ruleset collects. As encoded, every assessment is low risk and eligible for delegate approval, regardless of the identified risks.

2 · The escalation branch is empty

The final group evaluates ten risk factors in its condition but has no rules in its body (comment: “[LAST 4 DOT POINTS NEEDED]”). The factors are therefore computed but unused — no escalation to the Manager, Regulatory Operations, and no change to the risk level or approver. This is the ruleset's largest unfinished piece.

3 · Inspection logic is grey-kangaroo only

The property-inspection rule is nested entirely inside the Eastern/Western Grey Kangaroo guard. No other species — including the “Common Wombats” heading, which is an empty stub — can trigger an inspection through this ruleset.

4 · “Method is not shooting” is a broad trigger

Among the inspection triggers is “the control method is not shooting”. Taken literally, any non-shooting method (or an unspecified method) forces an inspection. That may be intended, but it is a wide net and worth confirming against policy.

5 · Region thresholds rely on supplied constants

Each region carries its own limit as an input constant (e.g. Port Phillip 20, Hume 250). The comparison is only as reliable as those constants; there is no lookup enforcing them, so an incorrect or missing limit would quietly change when an inspection is required.

Glossary

Authority to Control Wildlife (ATCW)
An authority allowing a landholder to take, disturb or destroy wildlife causing damage. This ruleset governs the Regulator's assessment of an ATCW application.
Assessor / Decision-maker
The officer who assesses the application and the officer who decides it. The rules require both to be recorded and to be different people.
Permissions Lead
The default delegate for ATCW decisions. Low-risk applications are intended to be approvable by the Permissions Lead; identified risks are meant to escalate to the Manager, Regulatory Operations.
Obligated / Required
“Required” marks a field that must be filled in; “Obligated” marks a condition that must hold for the assessment to be compliant (e.g. the two officers must differ).
Property inspection
A site inspection of the property. For grey-kangaroo applications the rules decide whether it is required and, if so, make completing it an obligation.