This submission responds to the draft regulations to the NSW Biosecurity Act 2016 that were open for comment between November 2016 and January 2017.
The submission considers that there was a big missed opportunity in addressing environmental biosecurity risks.
It suggests that there appears to be a large disparity in the implementation of the Biosecurity Act and its proposed regulations between how agricultural biosecurity risks are managed and how environmental biosecurity risks are managed. The Biosecurity Act tools appear to have been applied systematically and in great detail to agricultural biosecurity risks in close consultation with the agricultural industry. By contrast, environmental risks have not been subject to the same systematic application of the Act’s tools, leaving large gaps in the State’s environmental biosecurity.
On the whole, the approach to managing environmental biosecurity risks under the Biosecurity Act appears to be to merely transition existing management practices to the new legislation, without a review of risks and of measures to reduce those risks. Past views of environmental sector stakeholders have not been incorporated into the proposed regulations.