Review of the Intergovernmental Agreement on Biosecurity

19th September 2024

Australian Melon Association Inc
338 Pelican Back Road
Chinchilla QLD 4413

Ph: 0407 023 023
Email: ceo@melonsaustralia.org.au

Dr Michele Allan AO
Independent Reviewer of the IGA
C/O Department of Agriculture, Fisheries and Forestry
GPA Box 858
CANBERRA ACT 2601

Via: igabreview2024@aff.gov.au

Re: Review of the Intergovernmental Agreement on Biosecurity

EXECUTIVE SUMMARY

Thank you on behalf of the Melons Australia Board and our membership for the opportunity to provide this submission to support the review of the Intergovernmental Agreement on Biosecurity (hereafter IGAB).

Melons Australia is the Peak Industry Body for the Australian melon industry, including Australian growers of watermelons and muskmelons (rockmelons, honeydews and other specialty melon varieties). In 2022/23 in excess of 226,000 tonnes of melons were grown in Australia valued at $248.2 million. Production occurs across all mainland States and in the Northern Territory, from approximately 140 growers. This production alone results in our industry contributing more than $330,000 per year to biosecurity through existing levies that fund preparedness activities and responses to incursions.

Melons Australia manages and implements the Melon Industry Biosecurity Project, under contract from Plant
Health Australia, and we are current members of Plant Health Australia and the Plant Industry Forum (PIF). As such we also fully support the IGAB review submission prepared by the PIF.

Having reviewed the documentation provided for public comment by the reviewer, we appreciate the opportunity to provide the below insight/comment on behalf of the Australian melon industry.

General Comments:

Biosecurity is crucial for the productivity of the Australian melon industry and our access to domestic and international markets. Effective biosecurity management relies heavily on government actions, particularly at

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borders, while the industry plays a key role in observation and reporting. Managing plant biosecurity systems is complex and often requires high-level oversight due to the concurrent nature of biosecurity incidents. Melons
Australia recognises IGAB as a vital framework for cooperative government efforts to achieve optimal biosecurity outcomes. Given the national significance of biosecurity, we advocate for a unified national approach under the
IGAB, while acknowledging the financial pressures that threaten the integrity of this system.

The independent reviewer must consider improvements to the IGAB which take a unified approach to a sustainable biosecurity model.

To the everyday Australian biosecurity is not something often front of mind and when our biosecurity system appears so complex is it any wonder. Melons Australia are not directly included in the IGAB and are represented only through Plant Health Australia, and therefore we have very little insight on the IGAB operation or its effectiveness. We firmly believe the independent reviewer should explore how a review of the IGAB could facilitate a more collaborative approach, allowing for shared responsibility to be properly implemented in all forms of decision-making and processes.

Guiding question 1. Is the IGAB functioning as intended?

From Melons Australia’s perspective we can only assume that the IGAB effectively serves as the mechanism for government engagement in delivering the national biosecurity system. Its successful operation is vital for protecting the profitability and sustainability of plant industries, as well as the environment and natural fauna and flora.

Melons Australia requests that the independent reviewer consider ways to enhance plant industry engagement within the IGAB, ensuring its perspectives are represented to the National Biosecurity Committee and its subcommittees. Additionally, the reviewer should evaluate the IGAB’s capacity to implement the National
Biosecurity Plan. As per concerns raised above, it is slightly concerning that there are only three clauses in the
IGAB that address biosecurity funding. Financial capacity of the melon industry to pay for biosecurity is a significant pressure being faced at present and therefore it is essential for the reviewer to assess the agreement's role in establishing a sustainable funding framework for biosecurity across all government levels—local, state, and federal—while also considering collaboration with other sectors such as importers, tourism, mining, and the environment to also create shared responsibilities.
We wish to raise concerns about clause 33c. “Each Party commits to: a nationally consistent approach to system activities, measures and components”. Through engagement in a series of responses in recent times it has become evident that this clause’s interpretation is not delivering a consistent approach to post border biosecurity. Parties to
IGAB apply different approaches and there is no consistent framework. We seek the reviewer further examine the federated state and territory model in Australia and provide recommendations to guide a truly national approach to biosecurity including responses.

Guiding question 2. What changes, if any, could be made to the current cost sharing and funding arrangements
for cross jurisdictional activities outlined in the IGAB?

Melons Australia supports the majority of the reviewers’ early observations in regard to funding arrangements.
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We concur that the biosecurity system is insufficiently funded at all levels and will be placed under increasing stress as climate change and globalisation increase the likelihood of more frequent, complex and severe incursions. However, we stress again that Australian Melon Growers have no further capacity to contribute more than the significant amount they already do towards biosecurity preparedness and responses therefore the future funding considerations require a rethink.

The IGAB currently contains only three clauses specifically addressing funding arrangements. The independent reviewer is encouraged to assess this limitation and to propose a comprehensive funding plan for the future national biosecurity system. In line with previous recommendations, the reviewer should consider conducting a stocktake of the overall funding situation for Australia’s biosecurity system. Melons Australia concurs with the reviewer’s observation that there is no clear understanding of total investment in the national system and we continue to advocate for greater transparency in government funding of biosecurity activities.

Melons Australia also supports the need for better prioritisation of biosecurity activities, beyond the National
Biosecurity Strategy, and that delays in response decision-making must be addressed moving forward.

Melons Australia, as per previous submissions on biosecurity funding, considers that a wider group of
‘beneficiaries’ of biosecurity exist outside those identified recently by the federal government – namely primary industries that are not contributing to biosecurity, the tourism sector, businesses further along the supply chain such as processors of primary produce, and retailers of fresh produce and plants.

Of greatest concern is the failure by any government to adequately address the disparity between those who create risk and those who pay for a response because they are singled out as ‘the beneficiary’. A levy on imported goods that builds to a war chest for use in directly related responses is an equitable way forward which the independent reviewer must consider recommending in this review.

Guiding question 3. How did COVID-19 affect the functioning of the IGAB

Melons Australia supports the reviewer’s early observations and agrees that the pandemic highlighted the magnitude of impact on Australia and shone a spotlight on the importance of biosecurity. The social and economic impacts of COVID-19 and subsequent biosecurity measures continue to affect the country. Supply chain disruptions during the pandemic raised serious concerns about crop protection and heightened the risk of plant pests and diseases, posing a significant threat to food security. While the worst-case scenario did not materialise, these events highlighted the fragility of economic stability when producers cannot perform their due diligence on farms. Industry functionality must be prioritised during crises, and this needs to be enshrined within the IGAB to enable producers to source inputs and carry out their operations. This is crucial to guaranteeing the nation’s food security.

Additionally, delays affecting on-ground biosecurity officers responsible for vital surveillance and response activities are a significant concern for our industry. A streamlined process and appropriate allowances for these workers across all jurisdictions are essential to prevent threats from being overlooked due to bureaucratic hurdles. We support the PIF recommendation, and encourage the independent reviewer propose adding language to the IGAB that emphasizes the importance of allowing government-approved biosecurity officers to operate with minimal interference during national emergencies, such as a pandemic.

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Guiding question 4. Previous and ongoing reviews

Melons Australia supports the implementation of any previous review recommendations that the reviewer believes remain outstanding and still appropriate for action.

Do you have any comments about the review of the IGAB?

As stated frequently throughout our response, we fully believe the need for sustainable funding is critical and there needs to be a true commitment to ‘shared responsibility’ to include industry within the broader IGAB and committee framework. Sustainable funding and inclusion cannot only be at commonwealth level, it must include all levels of government and go more broadly across departments into other ‘beneficiaries’ such as trade, tourism and environmental sectors.

Protecting Australia’s plant industries, environment, and social amenity to support both preparedness, response and on-going management activities should not fall on agriculture agencies and primary industries alone. All
Australians benefit from effective biosecurity and therefore everyone should contribute to sustainable funding.
The development of a sustainable funding model should be led by the IGAB, with industry inclusion, and this review must layout a pathway forward for it to be a meaningful and impactful exercise. On behalf of the
Australian melon industry, I thank the IGAB reviewer for this consultation opportunity, allowing us to provide our industry views. I would be happy to discuss any of the content of this submission with you in the progression of this matter.

Yours sincerely

Johnathon Davey
Chief Executive Officer
Australian Melon Association Inc, trading as Melons Australia

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