In general the government is commended for the development of the biosecurity strategy and the gaol of bringing greater attention to environmental biosecurity. The strategy could be improved by adopting clear targets, adopting key recommendations in Stopping NSW’s Creeping Peril, allocating new resources, better utilising the community, advancing a proposal for Environmental Health Australia and resolving the conflict between recreational hunting and feral animal control.
As a replacement for the century-old Quarantine Act 1908, the Biosecurity Bill 2012 represents a rare opportunity to bolster Australia’s capacity to protect the environment from invasive species, a major cause of extinctions, declines and degradation.
In economic terms – if biodiversity and the natural environmental were accorded appropriate value as national assets and essential infrastructure – Australia’s current approaches to environmentally harmful invasive species are guaranteeing future poverty.
The NSW government proposes to open 39 new State Forests to hunting for 10 years. The NSW Game Council justifies recreational hunting as economic and effective provision of feral animal control when the evidence clearly demonstrates this is not the case. Such policy can have the perverse outcome of preventing real pest control work from being funded.
Environmental offsets are widely regarded as licences for destruction. ISC advocates measures to ensure that proposed offsets (to compensate for the residual impacts of approved developments) are genuinely compensatory, including an independent scientific panel to assess offset proposals. Offsets focused on managing invasive species threats to biodiversity could achieve genuine compensation in some cases.
ISC has compiled evidence of threats to 28 species and ecological communities to support the listing of 'Ecosystem degradation, habitat loss and species decline due to invasion in southern Australia by introduced Tall Wheat Grass (Lophopyrum ponticum)' as a key threatening process under the federal Environment Protection and Biodiversity Conservation Act 1999.
ISC has compiled evidence of threats to 18 species and ecological communities to support the listing of 'Herbivory and environmental degradation caused by feral deer' as a a key threatening process under the federal Environment Protection and Biodiversity Conservation Act 1999.
ISC supports the proposed Regulation to reclassify the status of various exotic animals based on risk assessments by the Vertebrates Pest Committee. We recommend the Regulation should be strengthened by applying the classification scheme comprehensively and consistently.
In responding to the inevitable lobbying by those who want to keep or sell certain of the species proposed for reclassification, we urge the government to prioritise the long-term interests of the community and environment in preventing the establishment of yet more exotic species in NSW.
Weeds represent one of the biggest gaps in environmental laws. In a joint submission with other environment NGOs, ISC supports most of the reforms proposed in the Issues Paper and advocates several further measures. We compare the Act with other environmental laws and conclude that it lacks important elements of best practice environmental law. It needs more tools and accountability to achieve the desired reduction in weed impacts.
ISC supports and advocates the strengthening of recommendations of the 10-year Hawke review of the EPBC Act to improve approaches to invasive species. The recommendations fill some of the gaps and address some of the glaring deficiences in the Act.
ISC advocates a 'permittled list' approach to weeds, which permits the introduction of non-indigenous plants only after a risk assessment finds they are low risk. The framework is too narrow in its focus on 'high-risk' species and 'high-value' conservation areas. Climate change needs to be a recognised important context for reform. There needs to be recognition that native species are also invasive.
This strategy fails to provide a clear basis for effective action to conserve biodiversity and should therefore be redrafted to:
There is strong evidence that escaped garden plants are having a major adverse impact on Australia's biodiversity, including threatened species of national environmental significance. The threat from such weeds is likely to increase into the future, particularly under climate change.
Along with land clearing and climate change, invasive species are one of the top three threats to Australia's biodiversity. And yet the country's Environment Protection and Biodiversity Act does not provide an adequate framework to address invasive species threats, particularly those already established in Australia.
The draft management strategy for hog deer in Victoria proposes goals and strategies that are anathema to best practice management of threatening invasive animals and biodiversity conservation.
It is clear that the purpose of the strategy is to improve recreational hunting opportunities for hog deer, and that it will lead to expanded populations and range of hog deer.
In this submission ISC focuses on the threat of invasive species to Australian biodiversity, arguing that the Environment Protection and Biodiversity Act does not provide the basis for preventing, containing or managing the serious harms caused to Australia's biodiversity and matters of national environmental significance by invasive species.
The Invasive Species Council is concerned about a number of issues surrounding Australia's federal quarantine and biosecurity system, including:
While the Victorian Government's Land and Biodiversity at a Time of Climate Change Green Paper appropriately acknowledges that invasive species are a major threat to biodiversity and agriculture, there are a number of gaps, including:
Pathogens: Despite the considerable environmental harm pathogens cause in Victoria, including dieback fungus, which kills native plants, and chytrid fungus, a major threat to frog populations, they barely rate a mention in the Green Paper.
Exotic invertebrates: A large number of exotic earthworms are being spread in Victoria, with unknown consequences, and insects, spiders and crustaceans are becoming more popular as pets, a trend that will inevitably lead to them being released into the wild once owners tire of them.
Inquiry into the regulation, control and management of invasive species and the Environment Protection and Biodiversity Conservation Amendment (Invasive Species) Bill 2002.