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Comments on the draft report on biosecurity import requirements for guava fruit from Taiwan (pursuant to Biosecurity Advice 2025-P03) 

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A joint submission by the Australian Network for Plant Conservation Inc. and the Invasive Species Council.

The Biosecurity Import Requirements Draft Report issued with Biosecurity Advice 2025-P03 recommends allowing the importation of commercially produced fresh guava fruit (Psidium guajava) from Taiwan. The Draft Report excludes Myrtle Rust (Austropuccinia psidii) from risk assessment on the grounds that it is not present in Taiwan. 

We argue that this finding was not well justified – a concern validated by the confirmed occurrence of Myrtle Rust in Taiwan, reported after the Draft Report’s publication. Although DAFF now proposes to conduct a risk assessment of Myrtle Rust, we provide here a critique of the original decision to exclude Myrtle Rust from assessment: 

  1. Historical evidence for presence: The Draft Report too cursorily dismissed a 1991 Taiwan detection as ‘unreliable’, based on attenuation or misinterpretation by secondary sources. 
  2. Other evidence for presence: Relying on a lack of recorded presence as an indicator of absence is not a reliable approach for a highly mobile pathogen like Myrtle Rust. The assessment failed to consider the implications of its rapid spread across the Pacific region since 2005, including recent detections in neighbouring countries: Japan (2007) and southern China (2009, 2024). 
  3. Process concerns: The assessors did not consult with the National Myrtle Rust Working Group before concluding that this high-priority biosecurity threat required no risk assessment. 

We suggest there are grounds for a review of the approach to pre-assessment categorisation, and the depth of assessment performed and reported, particularly for environmental pathogens. 

We also provide information germane to the forthcoming risk assessment: 

  • Fruit morphology: Some Guava varieties have terminal pits that could harbor spores and evade cleaning. 
  • Internal infection: Myrtle Rust can infect fruit internally without visible external symptoms. 

We urge the assessors to consider in detail the risks of introducing different strains of Myrtle Rust –whether new strains pathogenic to additional hosts or the existing pandemic strain, not yet present in Western Australia and South Australia. We urge consideration of the risks of introducing multiple variants that could lead to genetic recombination, expanded host ranges and more severe impacts. 

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    Dear Project Team,

    [YOUR PERSONALISED MESSAGE WILL APPEAR HERE.] 

    I support the amendment to the Kosciuszko National Park Wild Horse Heritage Management Plan to allow our incredible National Parks staff to use aerial shooting as one method to rapidly reduce feral horse numbers. I want to see feral horse numbers urgently reduced in order to save the national park and our native wildlife that live there.

    The current approach is not solving the problem. Feral horse numbers have rapidly increased in Kosciuszko National Park to around 18,000, a 30% jump in just the past 2 years. With the population so high, thousands of feral horses need to be removed annually to reduce numbers and stop our National Park becoming a horse paddock. Aerial shooting, undertaken humanely and safely by professionals using standard protocols, is the only way this can happen.

    The government’s own management plan for feral horses states that ‘if undertaken in accordance with best practice, aerial shooting can have the lowest negative animal welfare impacts of all lethal control methods’.

    This humane and effective practice is already used across Australia to manage hundreds of thousands of feral animals like horses, deer, pigs, and goats.

    Trapping and rehoming of feral horses has been used in Kosciuszko National Park for well over a decade but has consistently failed to reduce the population, has delayed meaningful action and is expensive. There are too many feral horses in the Alps and not enough demand for rehoming for it to be relied upon for the reduction of the population.

    Fertility control as a management tool is only effective for a small, geographically isolated, and accessible population of feral horses where the management outcome sought is to maintain the population at its current size. It is not a viable option to reduce the large and growing feral horse population in the vast and rugged terrain of Kosciuszko National Park.

    Feral horses are trashing and trampling our sensitive alpine ecosystems and streams, causing the decline and extinction of native animals. The federal government’s Threatened Species Scientific Committee has stated that feral horses ‘may be the crucial factor that causes final extinction’ for 12 alpine species.

    I recognise the sad reality that urgent and humane measures are necessary to urgently remove the horses or they will destroy the Snowies and the native wildlife that call the mountains home. I support a healthy national park where native species like the Corroboree Frog and Mountain Pygmy Possum can thrive.

    Kind regards,
    [Your name]
    [Your email address]
    [Your postcode]


    Dear Project Team,

    [YOUR PERSONALISED MESSAGE WILL APPEAR HERE.] 

    I support the amendment to the Kosciuszko National Park Wild Horse Heritage Management Plan to allow our incredible National Parks staff to use aerial shooting as one method to rapidly reduce feral horse numbers. I want to see feral horse numbers urgently reduced in order to save the national park and our native wildlife that live there.

    The current approach is not solving the problem. Feral horse numbers have rapidly increased in Kosciuszko National Park to around 18,000, a 30% jump in just the past 2 years. With the population so high, thousands of feral horses need to be removed annually to reduce numbers and stop our National Park becoming a horse paddock. Aerial shooting, undertaken humanely and safely by professionals using standard protocols, is the only way this can happen.

    The government’s own management plan for feral horses states that ‘if undertaken in accordance with best practice, aerial shooting can have the lowest negative animal welfare impacts of all lethal control methods’.

    This humane and effective practice is already used across Australia to manage hundreds of thousands of feral animals like horses, deer, pigs, and goats.

    Trapping and rehoming of feral horses has been used in Kosciuszko National Park for well over a decade but has consistently failed to reduce the population, has delayed meaningful action and is expensive. There are too many feral horses in the Alps and not enough demand for rehoming for it to be relied upon for the reduction of the population.

    Fertility control as a management tool is only effective for a small, geographically isolated, and accessible population of feral horses where the management outcome sought is to maintain the population at its current size. It is not a viable option to reduce the large and growing feral horse population in the vast and rugged terrain of Kosciuszko National Park.

    Feral horses are trashing and trampling our sensitive alpine ecosystems and streams, causing the decline and extinction of native animals. The federal government’s Threatened Species Scientific Committee has stated that feral horses ‘may be the crucial factor that causes final extinction’ for 12 alpine species.

    I recognise the sad reality that urgent and humane measures are necessary to urgently remove the horses or they will destroy the Snowies and the native wildlife that call the mountains home. I support a healthy national park where native species like the Corroboree Frog and Mountain Pygmy Possum can thrive.

    Kind regards,
    [Your name]
    [Your email address]
    [Your postcode]