Review of the Intergovernmental Agreement on Biosecurity

12 September 2024

Dr Michele Allan AO,
Independent Reviewer of the IGAB

Via: igabreview2024@aff.gov.au

Re: Submission regarding the discussion paper “Is the Intergovernmental Agreement
on Biosecurity effective and fit for the future?”

Thank you for the opportunity to participate in the Review of the Intergovernmental
Agreement on Biosecurity (IGAB).

Engagement on issues related to biosecurity is a high priority for GrainGrowers. This reflects the priority placed on biosecurity by our members, along with a recognition of the cost of managing both established and new pests and diseases in farming systems1.

GrainGrowers is a national organisation working to enhance the profitability and sustainability of Australian grain farmers. We achieve this through our focus areas of policy and advocacy, grower engagement, thought leadership and active investment in future focused activities for all growers. Australian growers are at the heart of all that we do and the focus of our work. The grains industry is a regional Australian powerhouse with 22,500 farm businesses growing around 50 million tonnes2 of grains, oilseeds and pulses each year for domestic and global customers.

The grains industry, through the joint work of Plant Health Australia, the Grains Research and Development Corporation, Grain Producers Australia and GrainGrowers, has recently launched the Grains Biosecurity Plan3. This outlines specific actions the grains industry will take to address biosecurity challenges, is aligned with the National Biosecurity Strategy and identifies areas for collaboration on activities undertaken by commonwealth, state and territory governments. Effective biosecurity in the grains industry relies on effective relationships and a solid foundation for collaboration across all levels of government in
Australia.

In developing our response, GrainGrowers is drawing on recent discussion and correspondence we have had regarding the National Biosecurity Strategy Action Plan 2024 4,

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GrainGrowers 2024 Annual Policy Survey
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Based on the 5-year average to 2022/23 (ABARES)
3
Biosecurity Plan for the Grains Industry (2024), Plant Health Australia
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GrainGrowers submission to the National Biosecurity Action Plan (2024)
as well as our engagement on issues related to the development of the Biosecurity
Protection Levy5,6.

In our submissions and discussions with government GrainGrowers has continued to highlight the need for transparency and accountability in the way biosecurity is funded, as well as improved biosecurity outcomes for growers. The current arrangements make it difficult to understand how our National Biosecurity system performs, how it operates to ensure there is continuous improvement and learning, and the extent to which activities are funded appropriately. The development of a National Biosecurity Strategy has been a welcome step in moving towards greater national coordination, but effective implementation is critical. The Intergovernmental Agreement on Biosecurity (IGAB) provides a mechanism to help facilitate the delivery of the National Biosecurity Strategy.

GrainGrowers notes that the scope of the current review is significantly reduced compared with the previous review undertaken in 2018 (the ‘Craik Review’). The scope of the current review is focused on the governance arrangements related to IGAB, rather than the broader challenges of implementing a national biosecurity strategy. Restricting the scope of the review7 is a missed opportunity to consolidate outstanding and overarching issues identified in other reviews. It also misses the opportunity to provide a context for prioritising actions across the national biosecurity system. GrainGrowers notes that there are several unresolved recommendations from the Craik review, including the establishment of a
‘container levy’.

The current discussion paper focuses on three questions. GrainGrowers’ response to these questions is set out below.

Guiding question 1: Is the IGAB functioning as intended?
The publication of the National Biosecurity Strategy provides an overarching agreed strategy for the delivery of biosecurity in Australia. GrainGrowers has concerns that the level of coordination aspired to under the National Biosecurity Strategy will not be achieved by maintaining current arrangements as currently set out under the IGAB. The opt in/opt out nature of some elements of the agreement do not reflect the nationally consistent approach and commitment that is implied through the National Biosecurity Strategy. The review of the
IGAB should consider how a future agreement can better align with the outcomes sought through the National Biosecurity Strategy.

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?
Current funding arrangements for biosecurity at State and Territory levels are unclear, and funding is reported in a range of different ways that lacks transparency. A useful outcome of the Review of the Intergovernmental Agreement on Biosecurity (IGAB) would be for the publication of a breakdown of biosecurity funding from the various levels of government, as well as industry levy contributions, to provide transparency and a broader understanding of funding arrangements.

5
GrainGrowers submission on the design and implementation of the Biosecurity Protection Levy (2023)
6
GrainGrowers submission to the Senate Committee inquiry on the Agriculture (Biosecurity Protection) Levies
Bill 2024
7
Point 4 of Scope “not duplicate efforts from previous and ongoing reviews and assessments of the biosecurity system noting that consideration and implementation of some of the recommendations from these may still be underway.”

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It is also important to note that it is not just funding, but the way funding is structured that can have a significant impact on outcomes. Funding and support for staff, and maintaining technical and operational capacity, must be a key part of the discussion on resourcing.
Human resources are critical to biosecurity preparedness and in an incursion response.
Moves towards contract and funding arrangements based around projects and incursion response has the potential to drive high staff turnover, eroding our national capacity to prepare for and respond to biosecurity incursions. The balance of funding that occurs at a national level across enabling, preparedness, response and inspection activities is unclear, and there are concerns that there may be underinvestment in enabling activities that underpin the biosecurity system. A clear basis for funding allocation, and ongoing commitment to funding from various levels of government, is required to support the biosecurity system.

Guiding question 3. How did COVID-19 affect the functioning of the IGAB?
There are significant lessons to be learnt from COVID-19 and responding to a widespread human biosecurity issue. However, in recent years the grains industry has been impacted by the introduction of Fall Armyworm and Varroa mite, and our industry continues to watch the evolving responses to Polyphagous shot-hole borer and Red Imported Fire Ants. Learning from these incursion responses are fundamental to improving our National Biosecurity
System. Mechanisms that allow jurisdictions to review, share learnings and implement change in the light of ongoing biosecurity threats need to be fundamental to the continual improvement to our National Biosecurity System.

GrainGrowers would welcome the opportunity to discuss these issues further and would welcome the opportunity to speak to the IGAB review team regarding the issues raised. If you have any specific questions regarding the points raised, please contact our Technical
Policy Manager Sam Nelson via sam.nelson@graingrowers.com.au.

Yours sincerely,

Zachary Whale
General Manager, Policy and Advocacy
GrainGrowers

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