Submission to the Review of the National Environmental Biosecurity Response Agreement (NEBRA)

A submission to the independent review of Australia’s National Environmental Biosecurity Response Agreement (NEBRA) in response to a call for comments on a discussion paper in January 2017. The submission was submitted in March 2017 and endorsed by 21 state and national conservation, industry and natural resource management organisations.

The submission identifies as the highest priorities for reform the process for decision-making under NEBRA to optimise the public interest. These include automatic triggering of NEBRA for priority organisms, majority instead of consensus decision-making, an emergency response fund, and meaningful involvement of environmental stakeholders and environment departments. Outbreaks of national environmental significance should always be considered under NEBRA (rather than the Emergency Animal Disease Response Agreement (EADRA) and the Plant Pest Response Deed (EPPRD) ) and no industry body should have a right under any agreement to veto an eradication. The proposed Environment Health Australia or equivalent is needed to undertake the preparatory work for effective responses to outbreaks, and an environmental body or committee with ecological expertise is needed to inform decision-making under NEBRA.

Mechanisms to foster transparency and accountability, such as a requirement to publish all decisions and information relied on, are vital for decision-making in the public interest. The NEBRA criteria (as well as those under EADRA and EPPRD) should be revised to reflect Australia’s environmental obligations and the characteristics of environmental invasions, including application of the precautionary principle, removal of the requirement for eradications to be cost beneficial and extension of NEBRA to outbreaks where existing outbreaks are contained and have a low risk of spread.

Attached to the submission was our proposal for Environmental Health Australia.

The submission was endorsed by Arid Lands Environment Centre, Australian Marine Conservation Society, Australian Network for Plant Conservation, Bush Heritage Australia, Conservation Council ACT Region, Conservation Council SA, Environment Centre Northern Territory, Gene Ethics, Humane Society International, Island Conservation, Kuranda Envirocare, National Parks Association of NSW, National Parks Association Queensland, National Parks Australia Council, Nature Conservation Society of SA, Northern Gulf Regional Management Group, Queensland Conservation Council, Vertebrate Pest Managers Association Australia, Victorian National Parks Association, Wildlife Queensland and WWF-Australia.

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