National Biosecurity Strategy Action Plan

National Biosecurity Strategy Action
Plan 2024: Connected, Resilient, Shared
Consultation Draft

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Via email: nationalbiosecuritystrategy@aff.gov.au and online submission.

22 August 2024

To whom it may concern,

On behalf of WoolProducers Australia (WoolProducers), I would like to thank you for the opportunity to present this submission on the draft “National Biosecurity Strategy Action Plan 2024: Connected,
Resilient, Shared”.

I would also like to express thanks for the extension of the submission timeline, however, note that given the importance of the national biosecurity system, the extended timeline is still too brief to facilitate the depth of feedback that we feel is necessary to optimise outcomes from this initial action plan. To this point we would encourage the National Implementation Committee (NIC) consider direct engagement with relevant industry stakeholders (either individually or on a group basis) prior to finalising the Action Plan.

WoolProducers believes that the Action Plan as proposed appears to lack the expected level of engagement and leadership from the spectrum of stakeholder groups identified in the National
Biosecurity Statement (NBS). Further to this the draft Action Plan appears to lack ambition, with many of the proposed actions being either pre-existing programmes / projects, or initiatives that would, or should be undertaken independent of the Action Plan.

As a result of this the Action Plan requires amendments to support and drive the evolution of our national biosecurity system in a way that is genuinely connected, resilient and shared. The comments and amendments suggested in our submission will ensure that the Australian biosecurity system remains strong and delivers the outcomes necessary to protect the wellbeing and sustainability of our industries, communities and environment.

The following pages outline concerns and suggestions that WoolProducers has in relation to the draft Action Plan. Should you wish to discuss our submission further, please contact me on 0455 442
776, or via email (gm@woolproducers.com.au).

Yours Sincerely,

Adam Dawes
General Manager
WoolProducers Australia

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About WoolProducers Australia
WoolProducers is the peak representative body for Australian woolgrowers, representing and advocating on behalf of all woolgrowers in the country, rather than just certain sectors. Our mission is to develop constructive and profitable outcomes for woolgrowers nationally.

WoolProducers represents the single largest body of woolgrowers through our fee-paying State
Farm Organisation membership network and three democratically elected Independent Directors and is the only national organisation that can speak on behalf of the mainstream wool industry and represent the concerns and interests of all Australian wool producers. Our representation capacity includes the industry’s commercial, superfine, broad wool and stud breeding sectors.

WoolProducers plays a critical role in working closely with companies and entities funded by woolgrower funds including compulsory levies or fees for service.

WoolProducers is the sole woolgrower representative member of Animal Health Australia (AHA), and as such, makes recommendations on the levy collected for animal health activities on behalf of the wool industry and contributed to AHA programs, projects, working groups, committees and for a that support the national animal health and biosecurity system.

WoolProducers is also the Emergency Animal Disease Response Agreement (EADRA) wool industry signatory and therefore carries a significant responsibility for decision making on behalf of the industry in the event of an emergency animal disease outbreak.

On an international level WoolProducers is the representative of Australian woolgrowers at the
International Wool Textile Organisation (IWTO) and their relevant working groups, including the
Biosecurity and Trade Working Group.

WoolProducers also works closely with, and is recognised by, the Commonwealth Government on key issues. This is demonstrated through participation in Committees and Roundtables covering diverse issues such as animal health and welfare, biosecurity, pest management control, natural resource management, drought preparedness, emergency animal disease outbreak preparedness, workforce and industry development, including research and trade.

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Creating a biosecurity system that is connected
WoolProducers is concerned that there is little reference to aligned strategies and frameworks captured within the National Biosecurity Strategy Implementation Plan. It will be critical to ensure that the Action Plan links with each of these strategies and frameworks to ensure that we achieve an enhanced national biosecurity system that is truly connected. Some strategies and frameworks referenced in the National Biosecurity Strategy Implementation Plan that are of direct relevance to
Australian wool growers include:
• National Sheep Industry Biosecurity Strategy
• AnimalPLAN
• Decade of Biosecurity
• Commonwealth and State Government Strategic Plans and Strategies
• National Biosecurity Statement, Strategy and Implementation Plan
• Animal Health Australia Strategic Plan
• Sustainable Biosecurity Funding Panel

The fundamental biosecurity principles (or system activities as referenced in the NBS) are common right across the biosecurity continuum, regardless of whether biosecurity activities are taking place at the international, national, regional, local or enterprise level. These principles are:
• Anticipate and Prepare
• Screen and Prevent
• Detect
• Respond
• Recover / Adapt

Through previous submissions to the NBS and the NBS Implementation Plan, WoolProducers has emphasised the opportunities to enhance biosecurity culture via both endemic and exotic pests and diseases. Unfortunately, the current federated model whereby the Commonwealth regulates exotic pests and diseases, and the states and territories regulate endemic pests and diseases of concern is not conducive to efficient uplift of biosecurity culture and embedding a sense of a shared responsibility across all biosecurity system stakeholders. Opportunities exist to leverage the messaging and outcomes of government and industry programs targeted at managing endemic pests and diseases to both minimise the direct impact of these diseases and improve the ability of our biosecurity system to prepare, detect and respond when needed.to an exotic pest or disease incursion.

The draft action plan has failed to acknowledge the role that Animal Health Australian (AHA) and
Plant Health Australia (PHA) can have in advancing the priorities of the NBS. Both AHA and PHA are member-based organisations comprising of government and industry members with an interest and responsibility for programs, projects and activities that support enhancement and delivery of the national (animal and plant) biosecurity and health systems. Utilising well established and respected organisations such as AHA and PHA within the delivery of Action Plan activities will ensure (through their diverse membership base) that the national biosecurity system remains connected.

Recommendation: That the NIC ensure that, where practical, action plan activities leverage pre-existing organisations/partners, strategies, frameworks and programmes to uplift biosecurity culture across all biosecurity system stakeholders.

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Creating a biosecurity system that is shared
WoolProducers supports and is an active advocate for the notion of a ‘shared responsibility’ framework for Australia’s biosecurity system. As per the National Biosecurity Statement (NBS), stakeholders in this system include the Australian government, state and territory governments, representative bodies (industry), research organisations and individuals.

While not wanting to discount the critical role that the Commonwealth and state and territory governments play in our national biosecurity system, the proposed action plan activities seem to be very government focused, with a disproportionately low number of actions being assigned non- government stakeholder groups. The Biosecurity Act 2015 emphasises the concept of “shared responsibility”. Further to this, the NBS emphasises the need for Stronger Partnerships (Priority
Area 2). Not a single one of the 52 draft action plan activities specifically lists industry as being directly involved in the delivery or leadership of the respective activities. Further to this 31 of the
52 listed activities are listed as being exclusive to the Commonwealth and / or state and territory governments. The action plan should include activities specifically assigned to each of the stakeholder groups identified in the NBS if we are to achieve an enhanced national biosecurity system that is truly shared.

As per the NBS there are “opportunities for meaningful change…through closer collaboration at regional and local levels. This includes industry, landowners and managers…and farmers... This collaboration will help to implement biosecurity priorities matched to regional needs, support prevention and preparedness activities, collect data and measure results consistently, coordinate mutually beneficial activities and maintain open and continuous communication.”

Recommendation: That the NIC consider including actions across all priority areas that include all stakeholder groups outlined in the NBS

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Creating a biosecurity system that is resilient
A biosecurity system that is genuinely connected and shared will be resilient, provided that sufficient resourcing is available to support the identified needs (i.e. the Actions of the NBS).
WoolProducers remains open to discussing funding and investment models for the national biosecurity system in order to ensure that the system is fit for purpose, targeted to our shared priorities, sustainable in the longer term and that all biosecurity participants contribute equitably.

The recently failed attempt by the Commonwealth to impose a Biosecurity Protection Levy (tax) upon Australian farmers was short-sighted, self-serving and did not align in any way to the actions of a stakeholder that is championing a biosecurity system that is connected, resilient and shared.

The attempt to address a budget deficit created by insufficient cost-recovery of regulatory activities by taxing Australian farmers was ill conceived and diminished goodwill and trust amongst biosecurity system stakeholders. WoolProducers remains concerned that the NBS Action Plan may be used by governments to impose further costs upon wool growers, without consideration towards the contributions that wool growers already make to the national biosecurity system through both cash and in-kind contributions.

WoolProducers acknowledges that need to reset our funding and investment frameworks to ensure that our biosecurity system is resilient. The review of biosecurity funding must be system-wide and not isolated to Commonwealth biosecurity activities.

Recommendation: That the NIC identify actions that can enhance biosecurity system resilience
(i.e. sustainable funding). These actions should seek to identify funding needs across the entire biosecurity system and involve all stakeholders in discussions to resolve funding shortfalls.

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NBS priority areas for action
Given the relatively short consultation period, WoolProducers is unable to offer specific feedback on the individual actions proposed in the draft action plan. Comments provided below provide guidance for the NIC to consider in amending and adding to the proposed actions. WoolProducers would welcome the opportunity to elaborate on these points in future consultation activities.

NBS priority area 1: Shared biosecurity culture
Action plan activities assigned to this priority area are too focused on activities led by the
Commonwealth. Biosecurity culture needs to be addressed at a national system level and can only be improved if all relevant stakeholders are involved. Actions must also include activities that are led by state and territory governments, AHA / PHA and industry groups.

Five of the six action plan activities listed to this priority area are promotion, extension or review of existing initiatives. The actions should be more ambitious and commit to more new initiatives that will progress the development of a shared biosecurity culture.

NBS priority area 2: Stronger partnerships
Action plan activities assigned to this priority area are too focused on activities led by the
Commonwealth. The development of stronger partnerships must utilise organisations such as
AHA and PHA in bringing together government and industry stakeholders.

The development of stronger partnerships will also be advanced by leveraging (where possible) the existing strategies and frameworks listed in the National Biosecurity Strategy
Implementation Plan.

Many of the action plan activities listed to this priority area are the continuation, enhancement or review of existing initiatives. The actions should be more ambitious and commit to more new initiatives that will progress the development of stronger partnerships.

NBS priority area 3: Highly skilled workforce
Action plan activities assigned to this priority area are solely focused on activities led by the
Commonwealth and state governments. The development of a highly skilled workforce to undertake activities across the national biosecurity system must also include the education sector, industry groups and producers.

NBS priority area 4: Coordinated preparedness and response
Action plan activities assigned to this priority area are too focused on activities led by the
Commonwealth and state governments. Uplifting the ability of the national biosecurity system to be prepared and ready to respond to biosecurity incursions must involve industry, environment and community groups.

Industry are continually investing in meeting consumer needs, particularly in relation to traceability and supply chain transparency. These investments could be leveraged to improve our ability to respond to a biosecurity incursion. These investments could also be utilised to

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improve our ability to establish, protect and / or restore market access under changing certification requirements that may arise in the future.

NBS priority area 5: Sustainable investment
WoolPorducers is alarmed that none of the proposed actions appear to have been discussed with the Sustainable Biosecurity Funding Advisory Panel that was established by the former
Minister for Agriculture. This calls into question either the effectiveness of either the
Sustainable Funding Panel or the commitment to genuinely progressing this NBS priority area
(or perhaps both).

WoolPorducers is concerned that all actions listed under this priority area are being led by the
Commonwealth. The recently failed attempt by the Commonwealth to impose a Biosecurity
Protection Levy (tax) upon Australian farmers was short-sighted, self-serving and did not align in any way to the actions of a stakeholder that is championing a biosecurity system that is connected, resilient and shared. The attempt to address a budget deficit created by insufficient cost-recovery of regulatory activities by taxing Australian farmers was ill conceived and diminished goodwill and trust amongst biosecurity system stakeholders.

WoolProducers remains concerned that the NBS Action Plan may be used by governments to impose further costs upon wool growers, without consideration towards the contributions that wool growers already make to the national biosecurity system through both cash and in- kind contributions.

Actions under this priority area must address funding of the national biosecurity system for activities undertaken by ALL stakeholders (not just activities undertaken by the
Commonwealth pre, at and post-border) taking place at the border.

NBS Priority area 6: Integration supported by technology, research and data
Action plan activities assigned to this priority area are entirely focused on activities led by the
Commonwealth.

This priority area must reference actions either underway, or actions that could be implemented by other stakeholders or stakeholder groups as referenced in the NBS
Implementation Plan (e.g. AnimalPLAN).

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