Environmental biosecurity. It’s back on the agenda

Feral Herald |
Key speakers at the second national environmental biosecurity forum held at Canberra on 29 June 2017: Matt Koval and Jo Laduzko from the Biosecurity Policy and Implementation Division of the Department of Agriculture and Water Resources (left), Andrew Cox, Invasive Species Council CEO and Paul Murphy, Wildlife Trade and Biosecurity Branch of the Department of Environment and Energy (right).

“Environmental biosecurity is back on the agenda.” Those were the words of CSIRO Research Director Andy Sheppard at a key biosecurity forum held late last month.

A day earlier the federal government had released its long-awaited response to the 2015 Senate committee inquiry into environmental biosecurity. Filtering through the system are two major reviews of national biosecurity that have recognised the gaps in a system meant to protect the environment. Momentum is now gathering.

These small but important steps are dividends of our work at the federal level highlighting the regular incursions of new pest species in Australia that go on to harm the environment and the historically poor responses from state and federal governments.

Senate inquiry response released

Of the 26 unanimous recommendations made by the Senate inquiry, seven were supported, 12 supported ‘in principle’ and two were not supported. Five were ‘noted’, which we assume means there was no interest in taking them further. Seven of the eight recommendations of the minority Greens report were not supported.

Experienced parliamentary watchers may expect us to be grateful to even receive a government response to a Senate committee inquiry (only half of the environment and agricultural inquiries from 2015 received a response). Instead, we expect a lot more.

No alternative to Environment Health Australia

The biggest disappointment was the lack of a credible alternative to our proposal for Environment Health Australia. This collaborative body would work to prevent the arrival into Australia of new environmental pests and diseases and develop effective responses to new incursions.

The federal government recognises that some aspects of environmental biosecurity ‘pose unique difficulties’, but suggests the best approach is to strengthen Australia’s existing institutions rather than create new bodies.

But these existing bodies have repeatedly failed to carry out this work. Environmental biosecurity lags far behind agricultural biosecurity, which does have specialist collaborative bodies (Plant Health Australia and Animal Health Australia).

Without Environment Health Australia or an equivalent collaborative arrangement between the federal and state governments and environmental stakeholders, we fear this important work will continue to inch along.

The inconsistency of the federal government was made apparent during the Senate inquiry when it created a third specialist body, Wildlife Health Australia (transformed from the Wildlife Health Network). Despite its name, this body is funded mainly to focus on diseases of concern to human health.

This year a new industry-focused plant biosecurity research body was established while environmentally focused preventative biosecurity research remains homeless.

Environmental biosecurity is very challenging and should not be treated merely as an add-on to existing agricultural focused biosecurity systems.

Inquiry responses supported

The Senate inquiry recommendations supported by the government mostly represent small steps forward and have plenty of wriggle room. Despite this, it is reassuring to see new activity within the agriculture department specifically to address environmental biosecurity.

There will be a review of the agriculture and environment departments to see how resources can better target environmental biosecurity risks. An important possibility flagged in the government response is an ‘environmental biosecurity policy statement’ and progress reports on the federal government’s management of biosecurity. At the June forum, government announced that a stocktake of environmental biosecurity is underway.

An agreement to implement the 2006 invasive ant threat abatement plan is welcome. This would best be done by updating the plan and integrating it with the invasive ants biosecurity plan presently under rapid development.

There was agreement that standardised labelling, weed identification and sales tracking protocols will be introduced for the horticulture industry. This will be done through a sub-committee of the Plant Health Committee responsible for interstate trade. It is unclear whether this will effectively limit the sale of weedy plants.

While we were disappointed that an important recommendation to prepare ‘a national priority list of pests and diseases not yet established in Australia that are of environmental biosecurity concern’ was merely supported in principle , government announced at the June forum that it would begin a two-year project run by ABARES to identify and prioritise environmental biosecurity risks and pathways.

This work would complement our joint work with Monash University to prioritise risks and pathways for exotic insects and plant pathogens that may impact on the environment. Together, these projects will form an important foundation for building a risk-based biosecurity system to protect the environment.

The other recommendations supported by government relate to the northern Australia quarantine strategy, improved targets for invasive species in the national biodiversity strategy and changes to the emergency response measures described below.

National biosecurity review calls for change

An independent review of how Australia protects itself from dangerous new invasive species has finally recognised the fact that we don’t pay enough attention to environmental pests and diseases.

The five-year review of Australia’s national biosecurity arrangements (the Intergovernmental Agreement on Biosecurity) could lead to a major shake-up. It called for environmental agencies at the state and federal level to play a ‘far stronger and direct role’ in most aspects of the system.

It pointed out that ‘national environmental pest and disease risks are yet to be systematically identified, prioritised and planned for’.

The draft report proposed six recommendations that would elevate national environmental biosecurity concerns and lead to greater parity with agricultural and public health biosecurity.

The reforms would be a game-changer for the environment, properly establishing the environment’s place in Australia’s biosecurity system.

We strongly endorse five of the six environmental recommendations, including:

  • The creation of a Chief Environmental Biosecurity Officer.
  • A new Environmental Biosecurity Committee of the national biosecurity committee that includes non-government experts.
  • An updated biosecurity agreement that includes a program to address the shortfall in work on priority environmental pests and diseases and a reference to ecologically sustainable development as well as Australia’s international obligations under the biological diversity convention.

The sixth recommendation was that the existing agricultural bodies, Animal Health Australia and Plant Health Australia, should undertake the work needed to better prepare Australia for environmental incursions.

This is unrealistic. It would require agreement from the agricultural industry partners in those bodies. The environment would understandably be a low priority for them and community representatives would probably not be meaningfully involved in the work. It fails to acknowledge the differences between environmental and agricultural biosecurity.

There is no doubt the draft report contributed to the increased activity we are already seeing on environmental biosecurity in Australia.

The big question is whether the proposed structural reforms relating to the environment will be implemented. For this to occur they must overcome a major hurdle. The decision of state and federal governments on whether to adopt the review’s recommendations will predominately be made by agricultural ministers and agricultural departments.

The final review report will be publicly released at the meeting of state and federal agricultural ministers in late July.

Review on responses to new invaders

Another major review relevant to environmental biosecurity is also in its finishing stages.

The federal and state governments are currently considering their response to a review by KPMG of the National Environmental Biosecurity Response Agreement (NEBRA).

This 2012 agreement sets out how governments jointly respond to new environmental incursions. It is triggered under limited circumstances for serious invaders that aren’t of major agricultural concern, and can lead to national cost sharing for eradication efforts.

We have been highly critical of NEBRA. The restrictive criteria mean the agreement is rarely triggered, and only for the worst invasive species like red fire ants.

Missing is a precautionary approach. The level of certainty required for decisions is inappropriately high given the potential for severe and irreversible harm to the environment coupled with a general lack of information about the impacts of environmental invaders and techniques for eradication.

Failure to apply a precautionary approach resulted in the rejection of the smooth newt as a target for eradication and the premature abandonment of myrtle rust eradication (the latter was done under an industry deed).

Eradications only proceed if it can be shown that benefits outweigh the costs even though there is no agreed methodology for valuing environmental benefits. This becomes a barrier to action unless eradication also has social and agricultural benefits.

The government response to the 2015 Senate inquiry endorsed the need for a method for environmental benefit-cost analysis. Given the inevitable limitations of any such method, we advocate that it not be a precondition for eradication.

We seek much greater transparency and accountability. Such is the opacity of decision-making  under NEBRA, we were unable to even access a a full list of species that had been considered for eradication.

In the case of the smooth newt, we found out about the incursion by accident a year after it was detected and had to resort to a freedom of information request for details.

Our detailed submission called for majority rather than consensus decision-making and for the industry agreements not to supersede NEBRA for major environmental threats. Since any delay in responding can make the difference between success and failure, the arrival of high priority environmental pests should automatically trigger the agreement.

Given that most states have ad-hoc eradication response strategies and limited capacity, an effective national agreement is vital to stopping new invasive species permanently establishing in Australia.

The final review report was handed to state and federal governments in June and remains secret.

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Help protect NSW!

Our expert team has written a list of policy asks detailing exactly what the next NSW government needs to do to stamp out some of the worst invasive species impacts across the state. But they will only become a reality if every key political candidate at the 2023 NSW state election hears about it from you!

Dear National Deer Management Coordinator,

Please accept this as a submission to the National Feral Deer Action Plan.

[Your personalised message will appear here] 

I am very concerned about the spread of deer and am pleased that a national plan has finally been developed. Without urgent action, funding and commitment from all levels of government it is clear that feral deer will continue to spread and damage our environment.

The feral deer population in Australia is growing rapidly and spreading across the country, damaging our natural environment, causing havoc for farmers and foresters and threatening public safety. Unlike much of the world where deer are native, our plants and wildlife haven’t evolved to deal with these heavy hard hooved animals with a voracious appetite.
With no natural predators and an ability to adapt to almost all environments, they could occupy almost all of Australia unless stopped. Despite this, state and territory governments have been slow to respond and in Victoria and Tasmania they are still protected by law for the enjoyment of hunters.

This plan should be adopted by all governments but must also be underpinned by dedicated funding and clear responsibilities. A plan without funding or accountability is a plan that will fail and Australia cannot afford for this to fail.

In order to prevent the spread of feral deer and reduce their impact on our native wildlife, ecosystems and agriculture, I ask that the following recommendations be adopted for the final National Feral Deer Action Plan:

1. All federal, state and territory governments should adopt the National Feral Deer Action Plan and declare feral deer to be a priority pest animal species.

2. All federal, state and territory governments should commit to:

  • Contain deer to the existing large population areas.
  • Reduce and eradicate smaller and isolated populations.
  • Protect important environmental assets such as world and national heritage areas.
  • Develop and fund regional plans and strategies to manage deer populations which involve land managers across all tenures.

3. In order to drive action and the success of this plan, there should be dedicated Commonwealth funding and support for:

  • A permanent national feral deer coordinator position.
  • A permanent federal feral deer action committee with representatives from the commonwealth and state and territory governments and the environmental and agricultural sectors.
  • An ongoing public education campaign on feral deer.
  • A network of regional feral deer coordinators to drive local action across tenures.

4. The expected outcomes for the plan need to be more ambitious, with clear interim targets including:

  • Within one year, all States and Territories should have in place arrangements to implement the National Feral Deer Action Plan, including allocating dedicated funding for implementation.
  • Within one year, feral deer management plans should be developed for key environmental assets of national significance, including the Tasmanian Wilderness World Heritage Area, the Greater Blue Mountains, the Australian Alps, the Gondwana Rainforests and the Wet Tropics of Queensland.
  • Within five years coordinated landscape scale management should be in place where land owners, land managers, government and community are demonstrably working together.

5. A national feral deer containment map with three zones should be adopted. It should be more ambitious than the zone map in the current draft plan and there should be greater clarity in the naming of the zones. Improvements that should be adopted include:

  • Renaming the zones to better reflect the management intention to ‘Containment Zone 1’ (the current large population zone), ‘Containment Buffer Zone 2’ (the current buffer zone) and ‘Eradication and prevention Zone 3’ (the current small isolated population zone).
  • The NSW northern rivers area should be in the eradication and prevention zone as there are few feral deer currently in this region and eradicating isolated populations and preventing spread into this area is still possible.
  • The whole of South Australia should be in the eradication and prevention zone as eradication is the goal of the SA Government.
  • The Tasmanian region in the containment zone should be smaller to reflect greater ambition and potential for eradication of deer populations.
  • In eastern Victoria areas such as Wilson’s Promontory, Westernport islands and the Mornington Peninsula should be in the eradication and prevention zone.

6. There should be consistent laws and regulations across all states and territories that:

  • Recognise feral deer as a pest animal and treat them as such.
  • Establish a clear responsibility for all landholders and managers to be involved in feral deer control programs.
  • Set clear penalties to stop the wilful or negligent release of feral deer.
  • Prevent new deer farms in areas where no feral deer are present and phase out all deer farms in the eradication and prevention zone.
  • Enable enforcement of compliance, including on government land.

I support the follow principles being adopted in the final National Feral Deer Action Plan:

  • Feral deer are a pest and should be treated as such on all tenures, except on approved deer farms.
  • Federal, state and territory governments have a responsibility to fund the outcomes under this plan.
  • All land managers in areas where feral deer are present have a responsibility to be involved in feral deer control programs.
  • The focus of management efforts should be on eradication of isolated, satellite populations, protection of key environmental assets currently impacted and stopping the spread to new regions.
  • Feral deer control should be undertaken humanely, safely and professionally according to agreed protocols and all tools which meet this criteria should be adopted, including aerial control.
  • Funding for coordination, regional planning and community engagement is necessary for effective feral deer management.
  • Ongoing management and follow up control efforts are required to achieve long lasting results.
  • Rules and regulations should be consistent across jurisdictions and land tenures.
  • Recreational hunting is not an effective strategy for feral deer control and should not be relied upon.
[Your name]
[Your email address]
[Your suburb], [Your state]