Australia’s system for abating major threats to biodiversity. Submission to the EPBC Act review

Australia’s system for abating major threats to biodiversity: a priority for reform of the EPBC Act. A joint submission by the Invasive Species Council and Bush Heritage Australia to the independent review of the EPBC Act. Published March 2020, submitted April 2020.

If Australians are to protect what is most distinctive about this country – its plants, animals and ecological communities, most unique to Australia – we urgently need to overcome many threats to nature. Reforming recovery efforts should be a concerted national focus on abating the major threats causing decline.

Among the most important parts of the EPBC Act are the sections specifying processes to identify and facilitate national action on major threats – the listing of key threatening processes (KTPs) and the preparation and implementation of threat abatement plans (TAPs). While the current KTP system is conceptually sound, the majority of threats to nature in Australia have not been abated, and many are worsening. Therefore, the KTP system is not achieving the relevant object of the EPBC Act – to provide for the protection of threatened species and ecological communities.

In this submission we identify major impediments to the effectiveness of the KTP system and reforms needed to strengthen the system. The system should be retained – something like it is essential for conservation – but it needs strengthening and expanding.

Summary of proposed changes

In total 22 recommendations are proposed. The most important elements of the proposed new KTP system are the following. Reforms marked with an asterisk (*) require changes to the EPBC Act.

1. Improved processes for listing and abating KTPs

  • Systematic listing of KTPs identified by the Threatened Species Scientific Committee or equivalent expert committee, supplemented by KTP nominations (recommendations 1–2)*
  • A separate category for emerging KTPs (recommendation 3)*
  • Requirement for a scientific threat response statement followed by a threat abatement plan except when information is insufficient or abatement is best abated through other processes (recommendation 5)*
  • Specified elements for threat abatement plans to include implementation commitments, costings, targets, monitoring and reporting requirements and review triggers (recommendation 7)*
  • Alignment with recovery planning (recommendation 8)
  • A national monitoring and reporting framework and standards to track KTPs and abatement progress (recommendation 12)
  • Costings – current funding levels, costs of abatement actions and overall funding needed for effective abatement (recommendation 14)
  • Adequate funding to prevent extinction and reverse biodiversity decline (recommendation 15)
  • Support for a threat abatement service industry (recommendation 17)

2. Additional processes for abating complex KTPs

  • The capacity to develop effective additional responses to complex KTPs through listing them as matters of national environmental significance (recommendation 18)*
  • A new system for invasive species – listing invasive species as a matter of national environmental significance and categorising them as the basis for action to prevent and minimise harm to biodiversity (recommendation 19)*

3. Improved governance

  • A new detailed Intergovernmental Agreement on Biodiversity to engender stronger commitments and cooperation by federal, state and territory governments to abate KTPs (recommendation 20)
  • Stronger accountability through a parliamentary biodiversity commissioner or equivalent (recommendation 21)*


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