National Biosecurity Strategy Action Plan

20th August 2024

Dear Working Group,

RE: AMRRIC submission in response to the National Biosecurity Strategy Draft Action Plan

Thank you for the opportunity to contribute to the review of Australia’s National Biosecurity
Strategy Action Plan.

AMRRIC (Animal Management in Rural and Remote Indigenous Communities) is a national not- for-profit organisation that partners with remote Aboriginal and Torres Strait Islander communities to improve the health of their companion animals through veterinary services, capacity building education and training, ethical co-designed research addressing community- identified priorities and advocacy on issues relating to the health of companion animals, their communities and the environments in which they live. Through this work, we are working towards our vision of healthy animals, healthy, proud communities. AMRRIC is founded on a deep respect for the cultures of Aboriginal and Torres Strait Islander peoples. We promote a One
Health approach, developed over years of dialogue and engagement with remote Aboriginal and
Torres Strait Islander communities, where companion animals are recognised as being intrinsic to the fabric of the community; their health and wellbeing is inseparable from that of humans. For over 20 years, AMRRIC has existed to assist and empower communities to meet their needs for companion animal health, care and safety. AMRRIC is governed by a Board of
Directors and Aboriginal and Torres Strait Islander Advisory Committee, and is supported by the
Australian Government, National Indigenous Australians Agency, as well as philanthropic and grant-based funding.

In addition to our work within Australia, in collaboration with DFAT, AMRRIC has recently been supporting the Government of Nauru to develop an effective and sustainable dog population management program. This work draws on AMRRIC’s 20+ years of experience working in partnership with Aboriginal and Torres Strait Islander communities, our expertise in humane and sustainable companion animal population management programs, as well as experience in genuine and respectful community engagement. As a result of this work, AMRRIC is increasingly being requested to consider expanding its services to additional Pacific Island nations.

AMRRIC supports the Australian Government’s commitment to safeguarding Australia’s biosecurity through Australia’s National Biosecurity Strategy (NBS) 2022-2032, the National
Biosecurity Strategy Implementation Plan, and now the National Biosecurity Action Plan. We agree that the proposed National Biosecurity Action Plan necessitates a national and inclusive approach, across government, research institutions and academia, private industry, non- governmental organisations, in consultation and collaboration with broader stakeholders across
Australia. While our core work is focused on companion animals - predominantly dogs and cats – we acknowledge the importance of protecting Australia’s human populations, domestic animals, wildlife, and local ecosystems is vital for maintaining health and wellbeing, as well as social and
economic stability. We also acknowledge national biosecurity is crucial for preserving Aboriginal and Torres Strait Islander cultural identify, by protecting the natural environments and species that are essential to traditional practices, knowledge and spiritual connections to the lands and waters and sea. Our submission highlights the importance of inclusion of One-Health systems based approaches, Aboriginal and Torres Strait Islander engagement and co-development of biosecurity activities and respect for the principles of Indigenous Data Sovereignty and ethics around Indigenous Data in biosecurity surveillance, and collaboration and co-development of biosecurity frameworks and infrastructure with our Pacific Island partners as being foundational for Australia’s National Biosecurity Action Plan.

We would welcome the opportunity to provide further feedback about how our recommendations could be feasibly integrated within the plan. Please do not hesitate to contact me for further discussion.

Sincerely,

Dr Bonny Cumming Dr Jessica Hoopes

Head of Innovation and Strategy | AMRRIC One Health Research Coordinator | AMRRIC

mailto:bonny.cumming@amrric.org | Jessica.hoopes@amrric.org | 0417952834
0417697790

AMRRIC’s Response to the National Biosecurity Action Plan

One Health, Systems Thinking Approaches

Expanding on its mention under Priority 4 as an activity for future consideration, AMRRIC advocates that a One Health, systems-thinking approach should be foundational to Australia’s
National Biosecurity Action Plan. One Health is based on the understanding that the health of humans, animals and the environment are inextricably linked, thus necessitating trans- disciplinary, multisectoral responses to health management. Systems thinking approaches are founded on the recognition and understanding of the interconnectedness of different components within a complex system, which is inherent in the concept of One Health. Strategic
Priority 1 of the Australia-WHO Country Cooperation strategy 2018-2022 is enhancing health security, with a focus on strengthening resilience to threats such as priority infectious diseases, emerging disease outbreaks and other emergencies with health consequences. With changing land use, climate change and increased human/animal/environment interactions, there is growing recognition of increased risks of pathogen spill-over. This potential has been highlighted by the recent incursions of SARS CoV2, Japanese Encephalitis (JEV), and Ehrlichia canis, as well as outbreaks of avian influenza, with zoonotic potential, and the ongoing global threat of AMR. One

2
Health has also been identified as a key priority of the Australian Centre for Disease Control, and forms the foundation of the Quadripartite Memorandum of Understanding.

One Health approaches are essential in combatting threats posed by existing and emerging infectious disease, but beyond disease spill-over, One Health also offers opportunities for translational research (aging and cancer being good examples of this), and the use of animals as sentinels for not only zoonotic disease, but also environmental hazards (toxins, etc.) (Dujon et al.
2021). With increasing threats, there is an urgent need to strengthen the implementation of One
Health initiatives to help build more resilient and equitable systems, environments, economies, and societies. This necessitates collaborative and unified approaches, incorporating diverse perspectives to help identify actions which improve health across all sectors.

The impacts of emerging zoonoses are often disproportionately observed in marginalised and/or economically disadvantaged people, women and Indigenous communities (Mubareka et al. 2022), further exacerbating health disparities between Indigenous and non-Indigenous
Australians. The National Aboriginal and Torres Strait Islander Health Plan 2013-2023 recognises the crucial role of cultural and social determinants, including animal ownership and human- animal interactions, on the health of individuals as well as the health of the broader community
(AIHW, 2022a; WHO, 2017b; AIHW & NIAA, 2020). As a framework, One Health aligns to and borrows from Traditional Knowledge and Indigenous perspectives of health (Dudgeon et al.
2014). Through its adoption, One Health offers opportunity to integrate diverse perspectives to improve health, as well as biosecurity, in a holistic sense.

Having a One Health, systems-thinking framework for biosecurity as the foundation of the
National Biosecurity Action Plan, Australia can enhance its capacity, for early detection, prevention and response to emerging infectious diseases through improved surveillance, communication and collaboration across sectors. This approach not only protects biosecurity, but strengthens public health outcomes, protects biodiversity, supports sustainable agriculture and fortifies Australia’s economic resilience against biosecurity challenges.

AMRRIC strongly encourages the Department of Agriculture, Fisheries and Forestry (DAFF) to adopt a One Health, systems-thinking approach as a fundamental guiding principle for all activities across the National Biosecurity Action Plan.

Aboriginal and Torres Strait Islander Co-Development of Australia’s Biosecurity Activities

AMRRIC acknowledges and supports the Action Plan’s inclusion of enhancing partnerships and engagement with Indigenous Australians (IA2.1), as part of Australia’s National Biosecurity Action
Plan. While AMRRIC is strongly supportive of the Indigenous Ranger Program, we highlight that the proposed actions are limited to support of only this group, overlooking the importance of inclusive collaboration across relevant Aboriginal and Torres Strait Islander stakeholders that is necessary to drive comprehensive and effective outcomes. AMRRIC’s DAFF funded Biosecurity
Pilot Project is an example of expanding partnerships within Indigenous communities to include stakeholders such as Animal Managements Workers and Environmental Health Workers – roles which, in addition to Indigenous Ranger Groups, are pivotal to biosecurity.

AMRRIC strongly encourages DAFF, as an activity under IA3.3 or 3.4, to continue funding projects such as AMRRIC’s Biosecurity Pilot Project, which leverage AMRRIC’s extensive stakeholders networks to ensure genuine collaboration with all relevant stakeholders in remote Indigenous communities.

3
AMRRIC also supports the Action Plan’s inclusion to increase the use of citizen science,
Indigenous knowledge and on the ground insights (IA6.7), but notes that it is important to recognise that Australia’s biosecurity measures can sometimes conflict with Aboriginal and
Torres Strait Islander values. For example, biosecurity strategies necessitating or prioritising strict control and eradication of animals or plants deemed to be a biosecurity threat may inadvertently impact local communities if the cultural or ecological significance these species may hold for Aboriginal and Torres Strait Islander peoples is not fully considered. Plants or animals targeted by biosecurity measures may be integral to Aboriginal and Torres Strait
Islander practices, Traditional Knowledge or to local ecosystems that have been sustainably managed by the Traditional Custodians of the lands for generations. As outlined in the National
Aboriginal and Torres Strait Islander Health Plan 2021-2031, Aboriginal and Torres Strait Islander peoples know what is best for the health of their communities, underscoring the need to prioritise community self-determination and leadership in identifying and driving local biosecurity priorities and initiatives. Through the actions outlined under Priority 2, the National
Biosecurity Action Plan should aim to support Aboriginal and Torres Strait Islander communities in developing multisectoral, place-based biosecurity partnerships that are determined by the needs of each community. This would then necessitate supporting the development of an Aboriginal and Torres Strait Islander One Health workforce (relevant to priority area 3), ensuring that Traditional Knowledge, lived experience and community connections are incorporated into local biosecurity systems, and facilitating the development and implementation of culturally safe and responsive Aboriginal and Torres Strait Islander biosecurity programs. Relevant to IA2.3, the governance arrangements supporting the development of an Aboriginal and Torres Strait Islander One Health workforce should ensure representation from Australian Indigenous Organisations and peak bodies as key stakeholders in Australia’s biosecurity activities and commit to co-development of national and regional planning for addressing key threats to biosecurity. Aboriginal and Torres Strait Islander ethnoecological knowledge of Country, Australia’s native flora and fauna transcends the Western recorded history and can play a key role in enhancing biosecurity surveillance in local ecosystems. As Indigenous knowledge of the interconnectedness between humans, animals and their shared environment precedes the development of the One Health concept, consideration of Aboriginal and Torres Strait Islander Traditional Knowledge is also an essential component of the broader One Health approach, as reflected in the Quadripartite Joint Action Plan (2022).

Effective collaboration with Aboriginal and Torres Strait Islander communities must acknowledge the holistic concepts of Aboriginal and Torres Strait Islander health and wellbeing, which recognises the close connections between the physical, mental, cultural, environmental, and spiritual health of Aboriginal and Torres Strait Islander people and communities. To ensure respectful, culturally informed policy and practice that reflects community priorities, Aboriginal and Torres Strait Islander leadership and decision making (relevant to IA2.3) must be embedded into all aspects of data collection, analysis, use and interpretation (e.g. IA 4.6, 4.7, 6.3, 6.4 and
6.7). Australia’s National Biosecurity Action Plan should aim to maximize community benefit from research and data by developing and expanding partnerships across existing Aboriginal and
Torres-Strait Islander One Health and research networks, and community-controlled research organisations, animal health and environmental health programs, in addition to existing collaborations with Indigenous Ranger Groups. Such partnerships should also be leveraged to facilitate the implementation of knowledge translation for return of any data collected from
Indigenous communities.

While high quality data is required for effective biosecurity surveillance, and the inclusion of
Traditional Knowledge has the potential to enhance opportunities for biosecurity surveillance, the collection and use of Aboriginal and Torres Strait Islander data and knowledge should

4
respect and operationalise the principles of Indigenous Data Sovereignty (IDS), (for example, see Trudgett et al. 2022), and ensure alignment with the principles outlined in the National
Agreement (Priority Reform 4), the Australian Indigenous Data Governance Protocols and
Principles, and Mayi Kuwayu: The National Study of Aboriginal and Torres Strait Islander
Wellbeing. Aboriginal and Torres Strait Islander communities must retain ownership, access, and control over their data and Traditional Knowledge, with a focus on building local capacity and facilitating self-determination to empower and support communities to access and utilise data to effectively address local biosecurity priorities and make informed decisions on programs and policies that address local need. AMRRIC finds it concerning that “Incorporate
Indigenous cultural heritage protection into all relevant biosecurity activities including risk assessments and priority risk lists.” has been identified as an activity for future consideration rather than committed as an initial action within this plan. AMRRIC strongly encourages DAFF to prioritise the incorporation of Indigenous cultural heritage (and intellectual property) protection into all relevant aspects of the National Biosecurity Strategy Action Plan.

Pacific Partnerships to Improve Biosecurity Capacity in the Region

AMRRIC supports DAFF’s intent to Incorporate Pacific Island partnerships into Australia's
National Biosecurity Action Plan (i.e. IA2.6), recognising that collaboration with neighbouring countries is essential for fostering a comprehensive and effective regional response to biosecurity threats. The interconnected nature of ecosystems and trade across the Pacific means that biosecurity threats in one area can quickly transcend national borders, resulting in broader biosecurity impacts across the region. By establishing and strengthening partnerships with
Pacific Island nations, Australia can help ensure support a unified and collaborative approach to detecting, preventing, and responding to these threats. While there is clear benefit to Australia and Pacific Island partners in building Pacific Island biosecurity capacity, it is not clear within the
Action Plan how Pacific Island priorities for biosecurity will be supported (as opposed to
Australia’s priorities for Pacific partners), nor how Pacific Islands will be represented in governance arrangements for relevant activities. AMRRIC strongly advocates that for genuine partnerships, it is essential that partnering Pacific Island nations are represented in governance arrangements, and that the action plan incorporates mechanisms to enable Pacific partners to identify and, with Australia’s support, pursue their own biosecurity priorities.
Further, to avoid potential duplication of effort and leverage existing collaborations, the action plan should seek to expand partnerships and facilitate collaboration with other stakeholders that play a supporting role in the Pacific, such as DFAT, the Pacific Community (SPC) and many non-government organisations.

Building local capacity across the Pacific is critical in addressing Pacific partners’ and Australia’s priority biosecurity challenges. Empowering Pacific nations with the tools, knowledge, internal governance and infrastructure needed to manage biosecurity risks will not only protect their unique ecosystems but also contribute to the overall security of the region. Helping to address critical gaps in the local workforce through One Health focused training and capacity building, and supporting development of local governance frameworks for biosecurity roles, coupled with the provision of ongoing support and mentorship for those involved in biosecurity activities can help to enhance regional surveillance, support networks for communication and allow for coordinated responses to health threats across the region. Building local capacity (both within
Australia and our work in the Pacific) is a key priority for AMRRIC; the organisation is experienced in the development and delivery of non-accredited companion animal biosecurity and population management training and is currently developing VET-accredited capacity-building

5
training that is relevant to both Australian and Pacific audiences. We would welcome discussion on collaboration in this regard.

AMRRIC advocates that any capacity-building training should:

• Be co-designed with intended audiences, ensuring the training reflects local priorities
and is contextualised to address local cultural, social, environmental, political, legislative,
and economic influences
• Be conceptualised and developed within the context of, and with reference to the
community/jurisdiction/country’s broader workforce strategy and capacity objectives
• Be accessible to and contextualised for culturally and linguistically diverse audiences
• Ensure the training suite includes entry-level pathways that are appropriate to local
educational levels (including those from rural or remote regions)
• Incorporate mechanisms to provide ongoing mentoring and support for training
participants, as well as ensuring governance arrangement exist to provide effective and
appropriate supervision and regulation of the roles
• Lead to genuine employment that has sustainable and internationally competitive
remuneration, as well as funding to support the operating budgets necessary for such
roles.

AMRRIC strongly encourages the National Biosecurity Strategy Action Plan to incorporate the above in its approach to the para-veterinary training outlined under IA2.6. Ultimately, all of the initial actions identified under priority area 3 should be undertaken before any specific training programs are developed for national or international audiences.

Additional Considerations: Priority area 4 - coordinated preparedness and response

AMRRIC is strongly supportive of IA4.1 and takes this opportunity to remind DAFF of proposals submitted by AMRRIC in 2022 to DAFF’s Biosecurity Innovation Program, around a remote
Indigenous community-based rabies incursion response exercise, bringing together human, animal and environmental health authorities and community-based stakeholders. AMRRIC believes the need for such an exercise is still pressing and would welcome the opportunity to collaborate with DAFF and other stakeholders to see these proposals come to fruition.

For IA4.5 – support the introduction and maintenance of a horse traceability system for
Australia, AMRRIC highlights that many remote Indigenous communities have strong historic, contemporary and cultural relationships with horses, however for many remote Indigenous communities, horse populations are free-roaming and not necessarily ‘owned’ (by western definitions of animal ownership). The management of these horses would require careful consideration (informed by extensive community consultation) in regard to any proposed horse traceability system and associated biosecurity activities.

In principle, AMRRIC provides support for IA 4.6 - advance region-based biosecurity preparedness planning, however notes that it is difficult to make an assessment of the suitability of such activities given the details on the specific surveillance and preparedness activities to be implemented by NAQS and collaborators are lacking within this plan. Given Northern Australia encompasses so many remote Indigenous communities, it is essential that Aboriginal and Torres
Strait Islander representatives are among the stakeholder contributing to these activities.

6