This chapter examines whether there is currently sufficient focus on
environmental biosecurity as distinct from industry-focused biosecurity,
including agricultural, horticultural and aquacultural biosecurity. This chapter
also examines proposals to improve the management of environmental biosecurity.
These issues are addressed through a discussion of the following matters:
the distinctive features of environmental biosecurity;
the economic valuation of environmental health;
the lack of emphasis on environmental biosecurity;
the proposal to establish Environment Health Australia; and
alternative proposals to strengthen environmental biosecurity.
Distinctive features of environmental biosecurity
Evidence received by the committee emphasised some essential differences
between environmental and industry biosecurity. Submitters and witnesses stated
that environmental biosecurity presents greater challenges than industry biosecurity
with regard to both detection and intervention.
With regard to detection, the number of species and the complexity of
the ecosystems involved in environmental biosecurity far exceed those of
concern in agricultural biosecurity. Furthermore, surveillance of the
environment in general is more difficult as it covers vastly greater territory
and areas which are often sparsely inhabited or difficult to access. Finally, industry
biosecurity, by its nature, involves stakeholders with a strong interest in the
health of particular species and ecosystems who provide a dedicated surveillance
system, whereas environmental biosecurity does not have this advantage.
With regard to intervention once an invasive species is detected,
whether that be attempted eradication, control and containment or long-term
management, environmental biosecurity also faces particular challenges. Once
again, the size and complexity of the natural environment make interventions
more difficult. Furthermore, as the goal of environmental biosecurity is to
protect existing species and ecosystems, the interventions available are
generally more restricted than those available in an agricultural setting.
The Invasive Species Council explained the distinctive challenges facing
environmental biosecurity as follows:
Although there are many overlaps with industry biosecurity,
environmental biosecurity is more challenging, with a greater scale and
complexity of threats, fewer management options and more limited resources.
Conservation requires protecting hundreds of thousands of species and complex
ecosystems with irreplaceable value, while organisms of value to industry are
relatively few. Much less is known about biodiversity than agricultural assets,
and there are high levels of uncertainty about the environmental impacts of
invasive species. Fewer management options are available and environmental
biosecurity relies on government and community investment for the public good,
while commercial incentives drive industry biosecurity.
The Australian Network for Plant Conservation (ANPC) made a similar statement:
Whereas agricultural biosecurity is mainly focused on
excluding or managing exotic biota (weeds, pests, diseases) that affect a
relatively narrow range of crop or livestock species and varieties or
production landscapes, with a definable economic value, environmental biosecurity
as part of Australia's overall conservation effort must focus on the whole
range of native biota and their associated ecological communities and
ecological processes. Estimates vary, but this native biota may encompass as
many as 650,000 non-microbial species of plants, fungi and animals (in contrast
to the few dozen species in most agricultural systems, or the several hundred
that make up the bulk of the horticulture industry). The native biota and
ecological relationships are essential, in their totality, to the overall
ecological health of the continent, including its production systems.
The ANPC also emphasised the difficulty inherent in managing invasive
species in the natural environment:
The 'assets' at stake in conservation are not replaceable –
each species and ecosystem is important, and are legislatively recognised as
such. A very large number of these 'assets' are involved, their spatial
distribution does not lend itself to easy or standardised management,
interventionist management is far more problematic and expensive, and we are in
any case still ignorant as to the biology, and ecology of very many native species
(and of the biological detail of the invasion process by exotic organisms).
Selective breeding for a more robust response to invasive threats is seldom an
option, is very expensive, and 'return to the wild' of improved genotypes is
Others agreed with this assessment. For example, Dr Andrew Burbidge stated
that the 'environmental system has very many more species of concern than we
have in agriculture'.
He also suggested that there are many species which may potentially cause an
environmental problem, but 'trying to predict which species might be a risk to
Australia's biodiversity is extremely difficult'. He explained that it is
difficult to 'predict whether a species is going to establish and, if it
establishes, whether it is going to become widespread and have an impact'.
Mr Richard Stoklosa also emphasised the complexity of environmental
biosecurity compared to industry biosecurity, and that this situation is not
helped by the lack of knowledge about specific organisms that may pose a
Environmental biosecurity, I would say, is a step change in
terms of complexity above agricultural biosecurity. I think agricultural pests
are pretty well described for the types of commodities or the types of plants
and animals that are being cultivated. I would have to say that agricultural
businesses see biosecurity as almost their lifeblood, and they do it really
well. There are a lot of lessons to be learned from that group. But I think
that, when you get into environmental biosecurity, you are talking about
probably a plethora of organisms that are not already on a pest or disease
species list, which you start needing to consider. Again, the way to do that is
to do a proper risk based threat analysis and start to look at how to group,
prevent, detect and eradicate organisms that fall into different categories.
A further point raised in evidence about the relationship between industry
and environmental biosecurity was that, historically, many invasive species
have been deliberately introduced to Australia for agricultural or
horticultural purposes without due weight being given to their potential
environmental impact. This history points to the differing priorities of
agricultural and horticultural biosecurity, which have primarily economic aims,
and environmental biosecurity, which has primarily a conservation focus.
The committee received evidence that many of Australia's most
environmentally damaging weeds have been deliberately introduced for
agricultural and horticultural reasons. For example, the Wet Tropics Management
Authority observed that:
...many of our worst weeds have been deliberately introduced
for horticultural and agricultural purposes and the interests of these industries
appear to be given greater weight than the impacts on the environment. Some are
still actively being promoted for pasture feed or biofuel crops, for instance,
without effective consideration of their current or potential weed impacts.
Ms Anna-Marie Penna, Vice President of the Australasian Council of Weed
Societies, clarified that the term 'deliberately introduced' covers a variety
of circumstances, including cases where the best available scientific advice
recommended such introductions:
'Deliberate' can be 'under the best possible advice that we
have at the time you should be using this species to control erosion, even
though it is an exotic not a native to that area'—those sorts of things. That
was the case with buffel grass being introduced on Barrow Island back in the
sixties. The CSIRO advised what was then called the WA Oil Company to sow
buffel around the airport for erosion control, and now it is a significant
problem on Barrow, because it takes a long time to control buffel.
There is 'deliberate' in terms of people not understanding
that garden plants can be problematic once they escape outside their gardens;
people dumping over the fence into the neighbouring nature reserve and those
sorts of things. And there is 'deliberate' in terms of people who do not care.
There is also accidental release, through lack of knowledge, or just stuff
coming off abandoned properties and things like that.
Associate Professor Driscoll of the Centre of Excellence for
Environmental Decisions at the ANU also submitted that 'Australia has one of
the worst records globally of major environmental impacts caused by plants
introduced for pasture', and cited the introduction of Gamba grass for pasture
as an example. He further noted that his research team had identified the 'development
of new varieties of existing introduced pasture species as having a high risk
of worsening Australia's environmental weed problem' and that 'similar risks
are inherent in the biofuel, carbon sequestration, forestry and horticulture
The Australian Network for Plant Conservation further emphasised the
role agriculture and land management have played as motivating factors in the
introduction of environmental weeds:
It is also the case that a significant proportion of
Australia's serious environmental weeds were deliberately introduced as
agricultural or land management plants – Tall Wheat Grass, African Lovegrass,
and Buffel Grass being examples – without assessment of their environmental
impacts, which have become severe.
Economic value and environmental biosecurity
Several submitters pointed to a further distinction between
environmental and agricultural biosecurity: the difficulty in developing an
agreed method by which to calculate the value of biosecurity impacts on the
environment. The Australian Network for Plant Conservation argued that the
difficulty in valuing 'ecological services' arises not only from the complexity
of environmental biosecurity but also from the fact that, in its view, the
health of the natural environment cannot be adequately expressed in monetary
Various attempts to place dollar values on these 'ecological
services' have rarely succeeded in adequately capturing their scope and
importance over intergenerational time-frames, and in any case miss the point.
Just as indices of human health as a component of society's well-being cannot
be meaningfully reduced only to dollar values, but are nevertheless recognised
as a fundamental social priority, so too the health of the natural environment.
Dr Lori Lach emphasised this difficulty in reducing agricultural and
environmental damage to a common unit for the purposes of comparison:
I would say...that agricultural losses and cost are much easier
to quantify. When you are trying to get things down for comparison, you want to
get them down to the same unit. If that unit is dollars and you can only get
the agricultural side down to dollars it is pretty hard to compare. How many
more extinctions would we need to have from yellow crazy ants before somebody says,
'Actually, this is a big cost.' How do you put a dollar amount on the Cairns
bird wing butterfly going extinct?
The Australasian Network for Plant Conservation also commented on this
aspect of environmental biosecurity:
The value of native biota cannot be quantified in economic
terms, except in limited aspects. This last factor alone means they are often
undervalued when biosecurity priorities are decided. It does not however mean
that they are without recognised national value – the whole trend, over several
decades, of public opinion and of government environmental and NRM policy,
confirms the recognised importance of the natural environment. The question is
how to give this recognised social value more effect in the biosecurity area,
where the under-emphasis on environmental considerations remains systemic.
This problem is not of merely theoretical interest as decisions made
under the NEBRA regarding whether or not to undertake a national biosecurity
incident response require the preparation of a benefit-cost analysis.
As noted by the Queensland Government, Schedule 4 of the NEBRA includes a
national framework for biosecurity benefit-cost analysis. The framework
acknowledges the difficulty of incorporating environmental considerations into
The significance of 'non-market' (environmental and public
health) assets impacted, which will require application of environmental valuation
techniques, will place greater challenges on the analysis.
However, beyond this general acknowledgement in the NEBRA benefit-cost
framework there is no methodology agreed between jurisdictions for assessing
environmental impacts of invasive species. The Queensland Government submitted
that for invasive species that affect the natural environment this 'reduces
effective prioritisation of resources to these species compared to those that
affect the economy and to a lesser extent social amenity, where methodology to
assess costs are well established.'
The joint submission of the departments of agriculture and the environment
also acknowledged the lack of an agreed methodology for valuing the environment
in economic terms:
While it is possible to determine the economic cost in terms
of adverse effects on production; at present there is no agreed model to
measure the ecological cost to the environment of exotic pests and diseases in
The Department of Agriculture provided a description of the various
approaches ABARES currently uses to conduct benefit-cost analyses involving
environmental impacts. In most cases ABARES 'considers environmental benefits
qualitatively using a constructed scale (negligible, low, moderate)'. Where
suitable data is available, 'ABARES has estimated environmental impacts
quantitatively (in monetary terms)'. The department's response included
examples of the benefit-cost analysis approach used with regard to Siam weed,
black striped mussel and red imported fire ant incursions:
Where relevant data are available, ABARES quantifies the
environmental impacts. For example, in the Siam Weed BCA [benefit-cost
analysis], ABARES valued the environmental impacts using the loss of grazing
value in environmental areas because of competition from Siam Weed, and the
expenditure by environmental managers to mitigate such impacts.
In some studies, if it appears that environmental impacts are
large and likely to exceed the costs of management options, ABARES employs cost
effectiveness analyses to identify the least-cost management option. The
recently published Black Striped Mussel BCA is an example.
If it is not possible to quantify any of the environmental
impacts because of insufficient data, ABARES identifies the particular environmental
assets under threat and provides a qualitative assessment of the impacts. The
BCA conducted for the red imported fire ants (RIFA) incursion in South East
Queensland is an example of this approach. 
The Department of Agriculture cited the benefit-cost analysis conducted
for the red imported fire ant incursion in south-east Queensland as an example
where expenditure on an eradication effort was supported by a quantitative
estimation of the market benefits of such action and also by a qualitative
assessment of the impact on identified environmental assets.
Finally, with regard to benefit-cost analysis and environmental impacts,
Mr Rodney Turner, General Manager Risk Management at PHA, explained that
even very expensive eradication programs can be amply justified when weighed
against potential damage to the environment at large:
In an agricultural environment, if the cost of eradicating
the pest—these are arbitrary numbers—is $100 million and the benefit is only $2
million or $3 million, then the industries and the government parties would be
very unlikely to commit that sort of funding. Using that same principle, when
you take into account environmental considerations and you look at the whole of
the Australian environment, the benefits would generally be very large. So,
even if it were $100 [m]illion to eradicate, you would probably have a
multibillion-dollar benefit and therefore you would go ahead...
The lack of emphasis on environmental biosecurity
Throughout the inquiry there was considerable discussion of the emphasis
that is placed on agricultural biosecurity in comparison with that placed on
environmental biosecurity. Most submitters and witnesses stated that
agricultural biosecurity is far better resourced than environmental biosecurity
and that this situation has arisen because of the readily identifiable economic
impacts of agricultural biosecurity threats.
Other submitters and witnesses put forward the view that it is not
possible to fundamentally separate biosecurity matters into environmental and
agricultural threats and that, for this reason, it is not correct to see
environmental biosecurity as receiving less attention than agricultural
biosecurity. The following discussion deals with these positions in turn.
The 2008 Beale review acknowledged that:
In the past, the environment—terrestrial and aquatic—has
received less priority than agriculture...a more significant effort is needed in
these two areas in the future...
The Beale review also noted that a number of submissions had linked the
low priority given to environmental biosecurity to the fact that there are no
stakeholders with a direct economic interest in protecting the environment from
...Australia has a relatively poor knowledge of the biosecurity
threats to its natural environment. This is largely a function of the absence
of commercial incentives to research and monitor environmental pests and
diseases. As a result, the principal responsibility for biosecurity research as
it relates to the natural environment lies with governments and the community.
These activities have not received a high priority for funding. Unlike
incursions that impact on primary production, where active engagement by
business is motivated by self-protection, the effort required to respond to an
incursion affecting the environment must be provided primarily by governments.
A similar argument was put to the committee during its inquiry. The
Invasive Species Council submitted that 'environmental biosecurity lags behind
that for industry' and that Australia needs a stronger focus on environmental
biosecurity. The Invasive Species Council was concerned that 'approaches to
environmental biosecurity tend to be tacked onto existing biosecurity
structures that prioritise industry interests'. The Invasive Species Council
acknowledged that 'many invasive species affect both agricultural and
environmental assets and warrant a joint approach', but nevertheless considered
that 'protecting nature differs in many ways from protecting industry assets'.
Dr Burbidge stated that 'better coordination is definitely needed
between agriculture and environmental biosecurity' and that:
There is a different emphasis in the two. Agriculture tends
to concentrate on the effects on a limited number of species of agricultural
importance in Australia and the things that may impact them, whereas
environmental biosecurity has a much wider requirement. Ideally, both would be
exactly the same and the objective would be to prevent the introduction of any
non‑indigenous species into Australia. But in reality, with limited
resources, that is not the case, I think, at the moment.
He noted that cost recovery is also an issue:
...the concentration on agriculture where there is cost
recovery required by the Department of Agriculture, in most cases for their
biosecurity work, does not benefit environmental biosecurity, where there is
obviously no body that they are going to cost recover from except the taxpayer.
The Plant Biosecurity CRC submitted that:
There is currently a lack of capacity and clear articulation
of responsibilities in the environmental area. This has led to a reliance on
agriculturally focussed organisations to lead responses when both environmental
and agricultural expertise must be employed in a timely and effective manner.
The Plant Biosecurity CRC also stated that, in the case of environmental
biosecurity, 'it is difficult to identify individual stakeholders who have a
very strong vested interest and the money, resources or time to invest in those
problems.' This has led to a situation in which, 'despite all the agreements
and so on, most of the operational capability is in the agricultural sector and
most of the surveillance that is done is associated in some way with the
The CSIRO gave evidence that its capacity to conduct biosecurity
research is largely restricted to areas in which stakeholders possessed the
capacity to co-invest:
...as a collaborative and cooperative research body which tends
to do the majority of its research through co-investment with clients of all
backgrounds, our capacity to do research is very limited by what the market is
interested in supporting. Certain aspects of environmental biosecurity have
effectively been in decline over recent years as a result of that.
The CSIRO also submitted that the capacity of government departments to
effectively address environmental biosecurity is not adequate:
Government departments and agencies responsible for the
environment are struggling with reduced capacity to take full responsibility in
decision-making and responses to new incursions that affect the environment.
This area has traditionally been under the responsibility of Departments of
Agriculture or Primary Industries. These agencies are however primarily
focussed on direct agricultural, aquaculture and forestry threats. There is
clearer overlap with responsibility for the environment in native forestry and
fisheries management, but agricultural industry and Research Development
Corporation investment in environmental biosecurity remains extremely low, as
it is seen to be beyond their remit except for the Rural Industries Research
and Development Corporation. There is no longer an RDC focused exclusively on
natural resource management as was the role of Land & Water Australia in the
There are currently few resourced institutional arrangements
for environmental biosecurity to underpin a timely, coordinated and
collaborative approach to prevent and reduce the adverse impacts of invasive
species in Australia.
The committee also received evidence and submissions expressing views contrary
to those described above. Both the Commonwealth departments of agriculture and
the environment, as well as the Western Australian Department of Fisheries, put
forward the view that biosecurity cannot be usefully divided into industry and
environmental elements. They stated that in the vast majority of cases an
invasive pest or disease will have both environmental and agricultural impacts
and, as such, biosecurity threats ought to be addressed by a unified system.
Ms Victoria Aitken, Biosecurity Section Leader, Western Australian
Department of Fisheries, told the committee that, from their perspective, the
environmental aspects of biosecurity cannot easily be separated from the
agricultural and other aspects:
Our biosecurity is very much focused on that whole picture,
rather than separating out the two. There are very few pests we have identified
that would impact in only an economic or agricultural way and not in other
ways. There are several pests that impact environmentally but that might not
directly impact on an economic factor, but it is very easy to see the
connections between them.
Dr Klumpp, General Manager, Biosecurity Tasmania, stated that it was a
strength of its system that it dealt with all biosecurity matters within one
agency as this allowed a greater proportion of staff to be dedicated to front-line
The division has branches...which are devoted to the science,
risk assessment, project program development et cetera. But we actually have to
have people on the ground to do things. So we have various program branches: we
have an animal biosecurity branch, which essentially deals with the primary
industries—the livestock industries. We have a plant biosecurity branch, which
essentially deals with the plant industries—the plant agricultural industries.
We have an invasive species branch which essentially deals with environmental
biosecurity. And we have an operations branch that actually gets out on the
ground and do things to implement these programs. One of the advantages of
doing it the way we are doing it and in an integrated way is that that
operations branch is the majority of our division—around 100 people. One of the
advantages of doing it this way is that, on any given day, that ground force
can be directed to a particular element. If we were fragmented they would be
specifically targeting their individual area, and we would have to find ways to
In a similar vein, Ms Rona Mellor, Deputy Secretary of the Department of
Agriculture, told the committee that their biosecurity work 'does not just
cover agriculture' and that 'biosecurity risk is biosecurity risk':
We analyse risk from the perspective of risks to Australia.
That includes risks to human health, plant health and animal health and how
they play out in production and in our way of life. In doing that, the
environment is a key consideration...
The departments of environment and agriculture submitted that it is not
desirable to manage specific sectors of biosecurity threats in isolation from
The biosecurity system is complex, and operates in an
environment characterised by the continual movement—in and out of the
country—of living things and goods. It is not possible or desirable to manage
biosecurity risk to one sector in isolation of another, or without a strong
network that includes different levels of government, industry, non-government
organisations and the community working together to achieve a common
objective—one biosecurity. Zero risk is not achievable—however biosecurity
threats are effectively managed using a risk-based approach.
Further, Ms Mellor stated in evidence that 'from the perspective of the
responsibilities of the departments we think that the environmental biosecurity
issues are well managed'.
The CPSU also stated that, in terms of the activities of the front-line
staff in the Department of Agriculture, agricultural and environmental
biosecurity are 'one thing':
We are trying to stop pests and diseases in the environment,
in agriculture and human health. There is no real focus on one or the other.
Proposal for Environmental Health Australia
The Australian Government is currently a party to three formal
agreements detailing response arrangements, including cost-sharing, for exotic
pests and diseases that are detected in Australia and have the potential to
affect animal, plant or human health or the environment. The three agreements
Emergency Plant Pest Response Deed (EPPRD);
Emergency Animal Disease Response Agreement (EADRA); and
National Environmental Biosecurity Response Agreement (NEBRA).
The Department of Agriculture and the Department of the Environment
noted that these response deeds and agreements by no means cover all sectors of
biosecurity risk. There are currently no nationally agreed response mechanisms
for weeds primarily affecting agriculture, aquatic diseases primarily impacting
on aquaculture industries and pests and diseases impacting on pastures of
In addition, these agreements do not address situations where a pest or disease
is found not to be eradicable but it remains in the national interest to
continue to act. The departments cited the myrtle rust and Asian honey bee
incursions as examples of this situation. In these cases 'transition programmes
were piloted to undertake activities to allow industry and/or the community to adapt
to living with the particular pest.'
To address this transition phase after a pest has been found to not be
eradicable, an IGAB working group has developed a national transition program
policy framework and consultations are underway about including this framework
in both the EPPRD and the EADRA.
Both the EADRA, signed in 2001, and the EPPRD, signed in 2005, are
contractual arrangements between the Commonwealth, state and territory
governments and, respectively, livestock and plant industry groups. These two
agreements set out management and funding responsibilities for emergency
responses to animal diseases and plant pests.
The share of costs to be borne by industry and government to implement
response plans under the EADRA and EPPRD vary from 100 per cent government
funding to 20 per cent government funding and 80 per cent industry funding,
depending on the extent to which the disease or pest affects the environment,
human health and national trade interests or specific industry assets.
Plant Health Australia (PHA) and Animal Health Australia (AHA) are also
parties to these agreements and act as their custodians.
As outlined in the previous chapter, both PHA and AHA are themselves jointly
funded by Commonwealth, state and territory governments and industry groups and
their focus is primarily on biosecurity to protect and enhance the prospects of
the livestock and plant industries.
The departments of agriculture and the environment described the roles
of AHA and PHA as follows:
Animal Health Australia and Plant Health Australia's roles
are to facilitate a national approach to enhancing Australia's animal and plant
health status, through government and industry partnerships for pest and
disease preparedness, prevention, emergency response and management. These
companies, and the emergency response agreements they administer... ensure that
national responses to emergency animal diseases and plant pests are facilitated
and that uncertainty over response management and funding arrangements is minimised.
The NEBRA was not established until 2012 and was 'developed to address
the gaps which existed in relation to responses to pests and diseases with
primarily environmental and social amenity impacts, for example weeds and marine
It sets out emergency response and cost-sharing arrangements between the
Australian and state and territory governments.
In contrast to both the EPPRD and the EADRA, the NEBRA is an agreement
between the Commonwealth and state and territory governments only; it does not
include industry groups. Furthermore, it is not overseen by a body equivalent
to PHA or AHA.
It is in this context that the Invasive Species Council put forward a proposal
that a national body entitled 'Environmental Health Australia' (EHA) be
established, along the lines of the existing PHA and AHA.
The Invasive Species Council suggested that such a body would 'improve
Australia's biosecurity preparedness, responses, capacity, and collaboration'.
The council proposed that the functions of EHA could include promoting more
ecologically informed approaches to biosecurity, enhancing community
involvement, and monitoring and reporting on biosecurity progress.
The Invasive Species Council explained:
With no body to take the lead on essential planning for
priority threats, environmental biosecurity currently suffers from a lack of
contingency planning for environmental threats. In contrast, the Australian
federal and state/territory governments have invested many millions of dollars
in developing plans and strategies to improve industry biosecurity – more than
$20 million over the past five years. Given how far environmental biosecurity
lags behind agricultural biosecurity, there is good reason for the federal
government to invest even more in an equivalent environmental body. A dedicated
environmental body is needed.
The Invasive Species Council further detailed this proposal in evidence:
Our proposal, which we first assembled in 2012, is to focus
on the prevention of new biosecurity risks which impact on the natural
environment. So, in itself, the body would be a collaborative body bringing
together state and federal governments and the community, in its many forms.
That is quite broad. We are talking about researchers, environmental land
managers, Indigenous land managers, Landcare and Bushcare groups, advocacy
groups like our own and also the industry, which has a stake in this too. We
are talking about bringing all these together at the table so that we are all
together identifying a way forward in a systematic way. The best model for us
is to look at Plant Health Australia and Animal Health Australia currently.
That work is excellent but it is focused on diseases and pests of plants and
diseases of animals. That work is not being done in a substantial way for the
full range of environmental risks.
The Invasive Species Council provided the committee with its 2012
proposal regarding the establishment of EHA. This document contains further
details on specific functions it proposes EHA could carry out.
The Invasive Species Council proposal was both supported and criticised by
other submitters and witnesses to the inquiry.
For example, the Wet Tropics Management Authority supported the concept of:
...a stand-alone environmental biosecurity body to work
alongside the established Plant Health Australia and Animal Health Australia.
This body should be appropriately resourced and empowered to focus on
public-good environmental values.
Other witnesses and submitters considered the proposal to establish a
body such as EHA worthy of discussion but raised difficulties. For example, the
Invasive Animals CRC pointed out that there is no equivalent in the environment
sector, in terms of resources and organisation, to the industry groups that are
members of AHA and PHA:
You are trying to ensure a coordinated national prevention
and surveillance capability as well as innovation capability. I think a key
point of difference is that Plant Health and Animal Health have their genesis
in trying to work out a cost-sharing arrangement between industry and
government. In the case of, say, the proposed Environmental Health Australia,
the market failure...is that there are no obvious industry beneficiaries. That
would therefore mean there would need to be some sort of cooperative arrangement
between the Commonwealth and the states.
The departments of agriculture and the environment opposed the EHA
proposal. The departments submitted that, although PHA and AHA primarily
focussed on primary production, 'environmental biosecurity considerations are
integral to their role.'
The departments further stated that, rather than establishing another
entity to manage preparedness, response and consultation for exotic pests and diseases
impacting on the environment, it would be preferable to improve on existing
Rather than establishing a new entity and funding stream,
however, a more effective approach is to continue to integrate environmental issues
into existing governance structures, functions and activities and to strengthen
collaboration and consultation with relevant stakeholders, including community
members. This approach builds on already strong arrangements through the
National Biosecurity Committee, its sectoral committees and other relevant
organisations, rather than creating a separate system.
The Department of the Environment expanded on this position in evidence
by explaining that the present approach is the result of careful consideration
of how best to address environmental biosecurity given the limited available
Back in the late 2000s and early 2010s, there was quite a
deep consideration within the National Biosecurity Committee about the right
way to deal with environmental biosecurity. This was at the time that the NEBRA
was being developed. In fact the NEBRA was an outcome of those discussions,
more or less. We were looking at the challenges around dealing effectively with
environmental biosecurity in our national preparedness and response
arrangements. We drew the conclusion that going down the path of creating a
bespoke environmental biosecurity system would be a mistake when we had
enormous capacity that already existed in plant and animal health under the
national arrangements and that the better path, including because we were in a
cost-constrained environment, was to make the national biosecurity system work
more effectively to deal with environmental biosecurity by having the various
component parts of the national biosecurity system dealing substantively with
environmental biosecurity in equal consideration with production and human
health. Since that time, there has been a very comprehensive effort in the NBC
[National Biosecurity Committee] to make that transformation, and I think our
progress has been good.
Opposition to the EHA proposal was also expressed by PHA and AHA. PHA
stated that it looked at plants in general, rather than at agricultural and
environmental plants, and that it is difficult to identify pests and diseases
that do not have impacts in both areas. Furthermore, PHA stated that it works
with Commonwealth and state departments of agriculture and environment and
looks at both agricultural and environmental impacts in its research:
We look at plants in the broad concept of plants. If you look
at a number of the activities, it is often quite difficult to find specific
examples of environmental pests that do not have an implication for agriculture
as well. For example, we have been involved in myrtle rust, which I know you
heard about this morning. We managed the program. We worked with the
Commonwealth Department of Environment, we worked with Queensland, New South
Wales, Victoria departments of environment as well as with the agriculture
agencies in managing that program. There are a whole raft of pests such as
Asian gypsy moth, sudden oak death, Siam weed and Mexican pepper grass, which
was also mentioned this morning, which cut across agriculture and the
environment. We often take all of those into consideration when we are doing
AHA agreed, stating that the introduction of a stand-alone environment
biosecurity body would add 'another potentially bureaucratic level' without
adding to the 'biosecurity continuum'.
The committee notes that, although PHA's constitution does contain the
following reference to environmental biosecurity within its objects, 'contribute
to the sustainability of Australia's plant industries and native flora', AHA's
constitution contains no such explicit reference.
The committee further notes that PHA expressed support for the establishment
of an independent body focused on environmental pests in its submission to the
For environmental pests there are many more stakeholders
across government, industry and the community than is the case with commercial
specific pests. Major challenges lie ahead in forming links and partnerships
between these groups and along the continuum. Trust, goodwill and impartial
decision making will be important and consideration needs to be given to
establishing an independent body similar to Plant Health Australia to create
the framework and coordination for partnerships to operate.
Finally, objections to the establishment of EHA were raised on the
grounds of funding. As noted above, PHA and AHA are jointly funded by industry
and governments. The Invasive Species Council stated in its 2012 proposal that
funding would have to be provided by Commonwealth, state and territory
The Invasive Species Council also suggested in evidence that a levy on
industries that pose a threat to environmental biosecurity—for example,
industries that import risky plant species—might be considered, and that some philanthropic
funding could also be pursued.
The Invasive Species Council also submitted that, given the extent of
government funding devoted to PHA and AHA, which are primarily focused on
industry interests, it would not be unreasonable for an equivalent level of government
funding to be devoted to environmental biosecurity, which is a public good.
By contrast, Nursery and Garden Industry Australia strongly opposed the EHA
proposal on the grounds that, in its view, the EPPRD and the NEBRA can 'cover
all aspects of risk identification and or management' and that:
The drive or expectation by some 'Non Government Agencies'
that a new body 'to look after environment' needs to be established and that it
will be supported by Industry contributions as occurs with Plant Health
Australia is ludicrous.
Alternative proposals to strengthen environmental biosecurity
As noted above, several submitters expressed the view that, although
environmental biosecurity appears to be neglected when compared to
industry-focused biosecurity, the establishment of another body, such as EHA, may
not be the best way to address this problem.
Dr Sophie Riley provided the committee with information on institutional
arrangements for environmental biosecurity in the United States and Great
Britain and argued that having a single peak body to implement an invasive
alien species biosecurity regime is important:
I argued that these bodies are well-placed to consider the 'big
picture' and take the lead in implementing initiatives that can draw IAS [invasive
alien species] regimes together, including: developing overarching policy,
defining an IAS, providing services such as one-stop information portals, and
fostering community engagement.
In evidence, Dr Riley explained how such peak bodies work in the US and
The way that this works in America, in the USA, is really
different. In America, for example, their National Invasive Species Council
only works on matters that the federal government has an interest in. For
example, it applies to federal agencies; it applies to work that the federal
government does, federal areas. It does not directly apply to anything where
the states are interested. The federal government can select anybody that they
like to sit on that, but the actual ramifications of that council are only
relevant for the federal government.
Where it becomes important for the states is, it sets an
example and it also facilitates dialogue, so you have always got the
invasive-species issue on the agenda. In the UK, because it is a different
parliamentary system and you have not got the same state governments, if you
like, that applies more directly to what happens in the UK. That is much more
of a hands-on approach. I do not think that would work in Australia, because of
the fact that we do have the state and territory governments. That was put in
there just as an example of another model. I think the US one would be more
appropriate for our parliamentary system. For example, I could not see that it
would be effective for the federal government to take over what the states are
doing. They have got expertise, for example; you have staff that have got
expertise. I think there would also be political tensions there as well.
In the light of these discussions on the importance of centralised
coordination, Dr Riley commented with regard to the EHA proposal:
If it gives the environment equal status, I think that is
good. At the end of the day, however, you still need something that coordinates
all these bodies. The problem is how you balance them.
Dr Judy Fisher, Theme Leader, Ecosystems and Invasive Species, IUCN Commission
on Ecosystem Management, suggested that we need to think carefully about how
the biosecurity system can be better coordinated.
She suggested that we need a coordinated body that encompasses both
biodiversity and agriculture:
We all need to be working together on this topic. It should
not be segregated...Segregating it is continually a reason for not doing
Dr Fisher also told the committee that environmental biosecurity is
often 'sidelined' and that agricultural bodies often do not want to take
responsibility for environmental biosecurity.
At the same time, she expressed caution about 'segregating' these issues:
From my years of experience, by separating this topic out,
nobody is ever going to be a winner. That is what I have seen happen here in
this state [Western Australia] for 20-odd years. Our department of agriculture
says that they are the lead agency for biosecurity, but they say, 'We're not a
biodiversity agency', and the biodiversity agency says...'Well, we're not the
lead agency; they are'—the department of agriculture is the lead agency—'so
it's not our responsibility'.
The Wet Tropics Management Authority was supportive of the EHA proposal
but also saw the dangers of further fragmenting the governance of biosecurity
Our submission endorses the notion of an entity called
'Environmental Health Australia' that would sit alongside Plant Health
Australia and Animal Health Australia, and have similar roles. And I guess that
is the advice that we are giving formally. I am alive, though, to the
countervailing view: that there is then the risk that environmental biosecurity
issues will be assigned to a new body which would be marginalised. I confess to
being somewhat in two minds about that. In some ways the best outcome might be
for the existing entities to strengthen their capacity and commitment to
achieving good outcomes for the environment alongside of plant health and
animal health issues they have for industry.
In response to questioning on this issue, Dr Burbidge cautioned that,
while there needs to be something that brings the 'environmental side of
biosecurity together with the agricultural side and make both more efficient',
he 'would not support anything that fragments existing departmental
Dr Burbidge also acknowledged that:
...the same sorts of rules that apply already in the
agricultural area are really effective in the environmental area as well. It is
just upping that level a little bit more that is required.
As noted above, the Department of Agriculture and the Department of the
Environment did not favour the EHA proposal as they believed it might in fact
make the biosecurity system worse. Ms Mellor, stated:
My view would be that most of the issues, from our
perspective of what we manage, are about plant and animal health and how we
assess those from a way of life, environment or a production perspective. I
would venture this concern: that if you disaggregate that to a different
governance model, you might cause harm. So you actually would need to weigh up
the risks and benefits of both a different model that is being proposed by
others and the risk of disaggregation of capability that does not distinguish
science risk to each of those three things as a different perspective. It looks
at the plant and animal health risks.
In light of the departments' position that a better approach is to
strengthen existing arrangements rather than create a new body, the committee
raised with PHA and AHA the prospect of taking on a greater role in
environmental biosecurity. PHA responded that it would be possible with
As long as there was adequate funding available because,
obviously, like most organisations, we haven't got any spare funds at the
moment. Funds are a necessity. As far as weeds go, it would also have to be
exotic weeds. There are so many different bodies looking after endemic weeds
and trying to remove them in Australia at the moment that that would just be
reinventing the wheel.
PHA further stated that although the objectives of the company include contributing
'to the sustainability of Australia's plant industries and native flora', as
noted above, no governance arrangements currently exist to undertake such work.
In response to questions about altering the structure of AHA and PHA so
as to allow involvement of environment and conservation groups, and perhaps even
to afford them voting rights alongside the current government and industry memberships,
PHA responded that this would entail some major organisational changes:
That would mean changing our whole constitution, because
there are no conservation industries that are members at the moment. We would
have to think through that. One consideration would be to include weeds in the
Emergency Plant Pest Response Deed, which is an avenue that we perhaps would
not go down because of existing signatories to that deed. We would think more
about a new deed perhaps for weeds, based very much on the existing deed. But
there obviously are differences. Industry is not involved so much. It is more
the environment. That is basically where we are at the moment in our thinking
and our discussions.
Mr Thompson, First Assistant Secretary, Sustainability and Biosecurity
Policy Group, Department of Agriculture, also clarified that, although the departments
of agriculture and the environment believed that strengthening existing
arrangements was preferable to creating a new body, this should not be taken to
mean that the burden of improving environmental biosecurity should fall
entirely on AHA and PHA:
In the submission when we talk about not favouring
Environmental Health Australia, some people may interpret that that somehow means
that Animal Health Australia and Plant Health Australia could do that job
alone. The way we were trying to express it in our submission was: there is a
role for Animal Health Australia, there is a role for Plant Health Australia,
there is a role for the environment department, there is a role for the agriculture
department, there are consultation mechanisms, there is research funding. It is
that whole system which, together, can enable us to work in the environment
space, not just say that Plant Health Australia and Animal Health Australia
will do it alone. We were not implying that.
With regard to other bodies that could play a more substantial role in
the environmental biosecurity system, both the Invasive Animals and Plant
Biosecurity CRCs argued that their research organisations could form the
institutional basis for long-term focus on environmental biosecurity, with
suitable expansion of their mandates, as they have brought together a great
deal of expertise. However, both groups noted that CRCs are funded for a finite
period and there is no guarantee that they will continue to exist beyond their
present terms. For these bodies to play a long-term role in environmental
biosecurity along the lines suggested in the proposal for EHA both their scope
and funding arrangements would have to be altered.
Further discussion of the funding arrangements for biosecurity research
organisations is contained in chapter 6.
Evidence presented to the committee suggests that Australia's
environmental biosecurity capacity lags behind that of industry biosecurity.
There appear to be several causes for this situation, including: the greater
complexity of environmental biosecurity; the historical emphasis on industry
biosecurity; difficulties in translating environmental impacts into economic
terms, and the lack of stakeholders with economic resources that can be drawn
Conflicting evidence was presented about the proposal to establish a new
body, Environment Health Australia, to address these apparent shortcomings in
environmental biosecurity. Proponents suggested that such a body could, if
provided with sufficient resources, implement a more coordinated approach to environmental
biosecurity. Opposition to the proposal focused on its potential cost and the
danger that it might further fragment the biosecurity system, which is already
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