National Biosecurity Strategy Action Plan

To the Department of Agriculture, Fisheries and Forestry Have Your Say:
Feedback on the draft National Biosecurity Strategy Action plan (Action Plan)
Submission from the Centre of Excellence for Biosecurity Risk Analysisi (CEBRA)

1. Comments the first set of activities outlined in the Action Plan that will be delivered under the National Biosecurity Strategy
We commend the set of projects that will be delivered and have the following comments on several of the pieces of work.
• Activities for Priority Area 1: Shared biosecurity culture
- IA1.2 Drive positive biosecurity behaviours and incentivise compliance
o Promote and expand the Highly Compliant Importer Scheme.
We note the important role that incentives play in driving positive biosecurity
behaviours, and in achieving compliance with biosecurity rules and regulations.
We also note that incentives must be created with caution—careful thought must
be given to the design of rules and regulations to ensure they create incentives
that will result in the desired stakeholder behaviour (rather than
counterproductive behaviour).
It is not yet common practice in biosecurity agencies to check the incentive
properties of rules and regulations such as the Highly Compliant Importer
Scheme, before they are rolled out. We hope this will change following the
development of an ‘Incentive diagnostic tool’ by CEBRA in partnership with
DAFF. The tool will enable biosecurity agency staff to check incentives inherent
in each rule/regulation/policy/scheme in the design stage, and refine incentives
as necessary. Creating the correct incentives will lead to efficiency gains and
avoid costly responses related to correcting counterproductive stakeholder
behaviour.

Centre of Excellence for Biosecurity Risk Analysis
School of BioSciences
The University of Melbourne
Victoria 3010 Australia
T: +61 3 8344 4405
W: www.cebra.unimelb.edu.au
• Activities for Priority Area 6: Integration supported by technology, research and
data
- IA6.3 Actively share data and research widely, and
- IA 6.4 Enhance the accessibility and use of surveillance and interception data
We are in strong support for improved data sharing across governments, industry
and other stakeholders. We also support a viability assessment of the
surveillance aggregation database AusPestCheck and the risk analytics platform
Biosecurity Commons.
Changing climate and increasing globalisation of human movement and trade
has dramatically increased the exposure of countries to new pests and diseases
that can have devastating economic, environmental, and social impacts.
Consequently, governments and industry must become smarter and more
efficient in how they estimate and manage these risks. To meet this ever-
increasing challenge, significant government and industry investment has
focused on the development of standardised biosecurity databases, new
surveillance technologies and greater community and stakeholder awareness.
However, a critical gap remains – the need for a standardised, easy-to-use risk
analytics platform that harnesses existing data (e.g. AusPestCheck), estimates
risk, and ultimately, informs policy and operational decisions focused on
managing biosecurity risk. Currently, cutting-edge risk analytics are developed
by academics, for academics. Consequently, these tools are largely inaccessible
to the people who need them most – surveillance practitioners, policymakers,
and decision-makers. This lack of access has resulted in national inconsistencies
in how risk is estimated and managed, with different jurisdictions and industries
utilising different models and datasets for informing operational decisions such
as where to allocate finite surveillance resources.
To address this critical gap, the Centre of Excellence for Biosecurity Risk
Analysis (CEBRA) in collaboration with EcoCommons, Griffith University,
Department of Agriculture, Fisheries and Forestry, the Queensland government,
and the Australian Research Data Commons (ARDC) have developed a platform
called Biosecurity Commons (www.biosecuritycommons.org.au) – an open-
access, cloud-based platform for modelling and analysing biosecurity risk and
response, developed specifically for the Australian biosecurity sector, but usable
anywhere.

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Through a series of user-requirement workshops with biosecurity practitioners,
Biosecurity Commons has taken cutting-edge published risk analytics and translated it into easy-to-use tools. The workflows it currently includes are:
1) Species distribution modelling – for predicting the environmental suitability of a biosecurity threat.
2) Risk mapping – for determining likelihoods of establishment potential as a function of pathway entry likelihoods, climate suitability and habitat requirements.
3) Dispersal modelling – for simulating the potential spread of a threat. Useful for determining how quickly a threat may spread and to where.
4) Surveillance design – for determining where to optimally allocate surveillance resources based on budget constraints, or desired levels of detection.
5) Proof of freedom – For determining the statistical confidence a threat is absent from a region of interest.
6) Impact assessment – For determining what the expected impact may be on different assets overtime.
7) Resource allocation – for simulating incursion scenarios and assessing the effectiveness of different management strategies.
Each workflow is reproducible and sharable among users. Fostering a transparent and collaborative environment among its userbase. This is especially important given that multiple stakeholders across governments and industry use risk analytics to make decisions that can have economic ramifications. In fact, the platform offers many critical benefits to the Biosecurity sector (see below).

Biosecurity Commons also contains an extensive database with over 60,000 individual datasets that span climatic, environmental and landuse spatial datasets. Moreover, it has API connection to a variety of species occurrence databases such as the Atlas of Living Australia, and the Global Biodiversity
Information Facility. Users can also easily upload their own data.
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A huge potential exists for integrating (via API) surveillance data available in
AusPestCheck and other government & industry held data. Information about
where surveillance is being undertaken, and how much, can be used in risk
analytics to determine confidence a threat is absent for the purposes of
international market access, incursion delimitation or confidence in eradication
success. It can also be used to identify gaps in post-border surveillance networks
and allow governments to further optimise their surveillance designs.
A significant challenge that faces both Biosecurity Commons and
AusPestCheck is the sustainability of funding. Currently both are on short-term
funding, with the latter funded largely by ARDC with minor contributions from
industry and DAFF, and the former through a 12-month extension on cost
sharing among jurisdictions. As such, while we endorse the viability assessment
of both, we strongly recommend a sustainability funding plan is developed for
both AusPestCheck and Biosecurity Commons as both are likely to be critical
pieces of infrastructure moving forward.

2. Comments on future proposed activities

Again, there are an excellent set of future proposed activities listed for future consideration.
We highlight two priority areas that we would recommend be actioned.
• Priority area 5: Sustainable investment.
- Build on findings of CEBRA work investigating feasibility of an insurance
scheme to raise funds to address biosecurity risks caused by international
shipping and other international risk creators.
We are in strong support for continued work on a sustainable biosecurity funding
model along the lines of recent CEBRA work, where methods from actuarial
science are used to design a risk-based approach to funding biosecurity system
costs—an actuarial levy imposes higher levies on higher risk activities.
An actuarial levy has three advantages:
• Equitable—It is only levied on risk creators. Those not creating risks would not
pay a biosecurity levy.
• Financially sustainable—For a given pathway, the pool of funds accumulated
from levies will cover biosecurity agency costs and the cost of responding to
incursions if they occur. Actuarial methods would raise revenue needed to cover
expected losses and biosecurity agency costs.
• Economic efficiency—An actuarially-defined levy will also reveals the efficient
price of biosecurity risk, and creates an incentive for risk creators to change
behaviour (i.e., seek out strategies that lower biosecurity risk in order to lower
their levy) thereby reducing Australia’s overall risk exposure.
Actuarial methods are used as standard practice to manage classes of risk (e.g.,
natural disasters, financial, cyber risk etc.) in other domains of the economy, and
could be applied in biosecurity in order to improve efficiency. This would add value
to the excellent science undertaken in the department.
Further, the Department can apply actuarial models to improve allocation of
biosecurity effort within the biosecurity agency through systematic assessment of
the value of an activity (e.g. additional surveillance) relative to other biosecurity

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interventions. The actuarial methodology and model developed by CEBRA can
identify the expected returns from additional investment of biosecurity effort.
- Investigate a national model for routinely co-investing in biological control
Established pests, such as the European wasp, have widespread impacts. In the case
of the European wasp, impacts continue to rise. The potential impacts of V.
germanica on horticulture, apiculture, tourism, outdoor social activities, and
biodiversity were recently estimated to be AUD 2.6 billion over 50 years, should
V. germanica continue to spread unhindered. Recent research has also shown
significant benefits of a European wasp biocontrol program, however more
research is required to understand growth and effectiveness of biocontrols agents.

3. Expression of interest to collaborate on activities outlined in the Action Plan.
CEBRA would like to express an interest in assisting with implementation of the National
Biosecurity Plan, including via the projects discussed above.

Thank you for the opportunity to comment on Action Plan. We would be happy to further discuss any of the above.

Yours truly

Associate Professor Susan Hester, on behalf of the Centre of Excellence for Biosecurity Risk Analysis i
CEBRA: Background and conflict of interest declaration
The Centre of Excellence for Biosecurity Risk Analysis (CEBRA), an initiative of the Australian government, is a research group supported the Australian Department of Agriculture, Fisheries and
Forestry (DAFF), the New Zealand Ministry for Primary Industries (MPI), and by the University of
Melbourne (the university), at which it is based. CEBRA supports DAFF and MPI in protecting
Australia and New Zealand’s agriculture, natural environments, and human health from biosecurity threats. CEBRA delivers practical solutions and advice related to the assessment, management, perception, and communication of biosecurity risk. CEBRA enjoys a unique relationship with DAFF and MPI, occupying a research / policy nexus that provides access to and leverage upon the key challenges faced by science-based regulators.
Consequently, CEBRA declares a conflict of interest in its commentary on the Australian biosecurity system because of the nature of its financial support and its operating model. CEBRA works very closely with DAFF, which is a key actor in the biosecurity system, and a large proportion of CEBRA research is funded by DAFF or biosecurity regulators in the states and territories, including
BiosecurityCommons.

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