Are governments planning to retreat from managing high impact invasive species threats to the environment?
In June, state and federal governments released for comment a proposed new approach for managing established pests and diseases deemed ‘nationally significant’.
Are we headed for an exciting new era with nationally coordinated, well-planned, collaborative, innovative efforts to protect biodiversity from the most harmful invasive species – or does the discussion paper presage government retreat from all but a few popular causes?
The approach’s underpinning concepts of national coordination and collaboration are endorsed. But some of the principles and statements in the paper ring alarm bells, for they flag a narrower role for governments and offer biased and poorly justified criteria for selecting nationally significant invasive species. And without the all-important discussion about funding and information about implementation, we cannot assess its real potential.
The paper left us wondering which direction government wants to take us. Our fear is that this new framework will see environmental threats mostly neglected.
The proposed framework
To be deemed ‘nationally significant’, a pest or disease must be established and beyond eradication. It ‘would be likely to have far reaching and/or national impacts’, and controlling it must be in the national interest.
Plans or strategies would be developed for each nationally significant pest or disease. The focus would be on asset protection as ‘a shared responsibility between landholders, community, industry and government’, with governments giving greatest priority to ‘supporting industry and community leadership and actions’. Regulation would be minimised in favour of collaboration.
The governments say that by supporting community and industry activity, they will be able to focus more on other aspects of biosecurity such as prevention.
International obligations should drive action
Under the proposed scheme, a pest or disease that has ‘significant impacts on the natural environment and ecosystems’ can qualify as nationally significant. The environment is one of seven categories in a list headed by ‘international market access and/or trade’.
It would be beneficial to have a systematic approach to identifying and listing significant invasive species. But because there is no method for translating environmental benefits into dollars, we may find the ‘national interest’ test is harder to meet for threats to the environment than for those to trade or agriculture. This is a common problem across many biosecurity programs, and often leads to environmental neglect. The paper says there won’t be national action when the costs of implementation exceed the benefits. But how do we compare implementation costs measured in dollars with benefits measured by the fate of species or ecological communities?
The recent federal Senate inquiry into environmental biosecurity recognised this problem, and recommended ‘the Commonwealth Government work with state and territory governments to develop a nationally consistent methodology for incorporating environmental impacts into cost-benefit analyses under the National Environmental Biosecurity Response’. This is essential for all biosecurity decision-making that relies on cost-benefit analyses.
Clearly, Australia’s list of invasive species with significant national environmental impacts is very long. But will the governments consider the fact that there is a strong national interest in controlling those threatening the environment? What the paper neglects to include in the national interest test is Australia’s international and national obligations to do so. It should be in Australia’s national interest to meet its obligations under the Convention on Biological Diversity and to achieve the objects of our national environmental laws. The 2011 Aichi targets under the convention include one to control or eradicate priority invasive species.
We need to persuade governments to include in the national interest test our international obligations to protect biodiversity, and to give high national priority to arresting and reversing biodiversity decline. Decision-making about nationally significant species should be transparent, informed by expert knowledge and opinion, and consultative.
National significance should not be a popularity contest
We know that governments are not prepared to spend the money to address all invasive species threats that could be deemed nationally significant, so how will priorities be determined? The paper implies it will be by popularity. Governments will ‘provide support where sustained collective action to manage an established pest or disease by an industry or community exists’.
This would strongly bias selection of nationally significant species to those in well-populated areas (where collective action is feasible) and to popular causes rather than biodiversity-based priorities. Cane toads would undoubtedly qualify but probably not most invasive invertebrates, or weeds and feral animals in remote areas. Many control programs – such as invasive ants requiring bait treatment and large-scale feral vertebrate control – rely on government action and are not readily amenable to community-led action. Conflict species such as feral deer or horses or species with economic benefits such as feral goats would also likely be rejected. This focus is likely to bias selection to agricultural priorities because industry has a much greater capacity – including resources – to undertake collective action.
We need to persuade governments that selecting priorities should not be a popularity contest. Priority should go to managing species with the greatest threats or potential threats to biodiversity. While community action is a bonus, it should not be a pre-condition for government action on invasive species impacting the environment.
It is in the national interest to learn as we go
There is also the risk that the national interest test will stymie action on difficult species, for one requirement is that action be ‘feasible and practical’. Often effective control measures can only be developed and improved through a dedicated long-term program. Australia has become a leader in ant control only because of sustained government programs on Christmas Island for yellow crazy ants and in southeast Queensland for red imported fire ants, which have fostered new techniques. Learning by trial and error should be facilitated and research should be given high priority.
There is too little in the paper about research. It is not mentioned in the policy principles. Supporting research is mentioned as one of the roles of government only ‘when a strong public interest exists to do so’. There is also no mention of training or extension in the paper.
We need to persuade governments the national interest can best be served in many cases by committing to learn through action. Governments should commit to research on control methods for significant threats rather than requiring (in a catch 22 situation) they be already available before there is national action.
We should learn from existing approaches
Australia already has long-established processes for identifying and coordinating action on some nationally significant invasive threats – through the development of threat abatement plans under environmental laws (the EPBC Act) and the Weeds of National Significance program. The paper doesn’t make clear how the proposed process will interact with the existing ones. Is the intention to expand, replace or modify these existing programs? It is strange how little mention they get in the discussion paper.
At the very least the merits and inadequacies of existing national programs should be reviewed so that we can learn from them.
It is concerning that the paper claims the proposed new approach would ‘represent a significant change’. This implies that existing approaches will be abandoned. But there is too little detail to ascertain how things will change.
In a section entitled ‘What would change’, the government says the new approach is a ‘more market-driven approach’ and ‘governments’ role will shift towards ‘supporting collective action by others and investing public funds where they can add the most value’. This reinforces our concerns that governments will abandon action on environmental threats that seem difficult, with benefits that are hard to quantify, or are not amenable to community-led action. Does it also mean they will abandon existing programs?
In order to effectively respond to nationally significant threats, governments must review existing programs and consult early and widely to develop the best approaches.
Containment is an important goal
The discussion paper identifies four categories of response to invasive species – prevention, eradication, containment and asset-based protection – but it specifies in the policy principles that only the last of these will be applied to nationally significant species. This is far too narrow a focus. Most invasive species in Australia have yet to achieve their full potential range, and there will be substantial environmental benefits in containing them and preventing further spread.
One example is prickly acacia, a weed of national significance in north Queensland, for which the approach has been to remove outlying populations and contain it in core areas of infestation.
Even if spread of an invasive species will inevitably occur, there can be great benefits in delaying it to allow the development of better control measures. The paper implies that governments will allow nationally significant invasive species to spread and focus their efforts only on protecting certain sites or species from their impacts.
We need to persuade governments that a piecemeal, asset-based approach will not work for the environment. Containment should be added as a policy principle for species yet to reach their full range, especially those in the early stages of invasion.
We need government leadership and genuine collaboration
There is a worrying absence of the notion of government leadership. The paper says governments should take the lead on eradication programs, but leadership is not one of the roles of government in managing nationally significant threats.
The vision informing this paper seems to be of community groups out there diligently controlling invasive species with the government in the background offering support. This might work for agricultural threats that need to be controlled on-farm but is completely unrealistic for most high priority environmental threats, especially those in sparsely populated areas or for invasive species yet to spread to their potential range.
It is essential for governments to take a leadership role on nationally significant threats to the environment.
Instead of leadership, the paper promotes the idea of collaboration. However, we fear that envisaged is a limited form of collaboration, focused only on on-ground actions. The paper implies governments will continue to exclude the community sector from a substantial role in most biosecurity policy and decision-making.
There is no commitment in the paper to a transparent process involving the community sector for determining nationally significant pests and diseases and developing plans or strategies for listed species. The paper says four government committees (the Invasive Plants and Animals Committee, the Plant Health Committee, the Animal Health Committee, and the Marine Pest Sectoral Committee), mostly made up of representatives from agricultural departments, will consider potential candidate species.
We need a commitment from governments that they will foster genuine collaboration with the community in policies and decisions on nationally significant invasive species, not just in on-ground work.
There is a role for enforcement
We are concerned by the strong emphasis in the paper on minimising regulation, with a policy principle to minimise ‘enforcement intervention’. Poor enforcement is often the norm for environmental threats, so any suggestion that it should be reduced or reliant on existing community action is worrying.
We need to persuade governments that regulation and enforcement are important tools in managing threats, particularly on private land where the landowner has no other incentives to manage environmental threats.
What about funding and implementation?
A cynic would interpret the government wish to avoid a leadership role as its desire to limit public funding. The paper implies that government funding will be available only as a top-up to existing resources, invested ‘where they can add the most value’.
There is no acknowledgement of the current critical underfunding for managing threats to biodiversity and no commitment to increase funding.
There is also a strange statement in the paper that ‘asset-based management may be the most cost-effective for an individual and/or as the basis for collective action by a community or industry’. This suggests that containment is neglected in the paper because governments want individuals and groups to bear most of the management costs. Containment will often be the more cost-effective approach for managing environmental threats but the paper implies that public funding will be too limited for containment programs.
Although the paper proposes a national plan or strategy for each invasive species deemed nationally significant, there is no information on how they will be implemented. The implementation of the first 20 strategies for weeds of national significance worked well when there were government funds for a coordinator and national committee, but this stopped when funding ceased. The strategic plans for the 12 new weeds of national significance, approved in 2012, lacked the national coordination necessary to drive implementation. The implementation of threat abatement plans, which would mostly address established invasive species, is very limited, with few or no resources for coordination.
The need for public funding is greatest for environmental threats where there is no commercial incentive on private land to control particular invasive species.
The paper talks of the need to maximise public benefit from public funding. There should be a review of current funding that is primarily for private benefit in managing invasive species. While public funding for public good research is declining, the Australian government currently matches industry levies for research including on biosecurity threats to agriculture, thus providing substantial funds to established pest management for private benefits. According to the principles espoused in the paper this funding should be redirected to neglected areas that are in the public interest, including research on environmental threats. Without an explicit commitment to do this, we remain sceptical that the governments are serious about directing public funds to optimise public benefits.
Governments need to commit funds for developing and implementing plans and strategies and to substantially increase funding for research and management of nationally significant environmental threats. Without funding commitments, this program will be an environmental flop.