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Parliament of Australia
Senate Environment, Communications, Information Technology
and the Arts References Committee
Invasive Species Inquiry
Submission by the Department of the Environment and Heritage
_____________________________________________________________________
Introduction
The Australian Government Department of the Environment and Heritage (the Department)
welcomes the opportunity to make a submission to the Senate Invasive Species Inquiry.
The Department develops and implements policies and programs for the protection and conservation
of the environment, especially those aspects that are matters of national environmental significance. In
addressing those issues, the following departmental functions are relevant to this inquiry:
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administering the Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act),
which includes provisions relating to threatened species and threatening processes
developing border control policy in conjunction with the Australian Quarantine and Inspection
Service (AQIS) and the Department of Agriculture Fisheries and Forestry (DAFF)
managing Australian Government terrestrial and marine reserves, such as Christmas Island
National Park and Kakadu National Park (managed jointly by the Director of National Parks and
traditional owners). Five reserves managed by the Australian Government are on the World
Heritage list
managing the Natural Heritage Trust
participating in the ongoing development of a National System for the Prevention and
Management of Introduced Marine Pests, and in interim policy co-ordination arrangements for
marine pests.
The Department works in close co-operation with a range of stakeholders to achieve these goals,
including industry, non-government organisations, community groups and state government
agencies. In particular, the Department works closely with the Department of Agriculture, Fisheries
and Forestry on invasives policy and operational matters, from risk assessment and border control
through to management of established invasives.
Comments in this submission specifically address the terms of reference for the inquiry.
1. The threat that invasive species pose to the Australian environment and economy
Invasive species are a significant, increasing threat to Australia’s environment.
The 1996 ‘Australia State of the Environment Report’ identified the impacts of introduced species as a
key threat to biodiversity, with every type of ecosystem in Australia and many native species affected
by these impacts. The 2001 ‘Australia State of the Environment Report’ reported that introduced marine
pests were continuing to threaten habitats and native species and that the risk of new introductions
was constant and significant1. Both reports noted that the pressure on terrestrial biodiversity from
invasive species was constant or increasing.
1 Australia, State of the Environment Report 2001 (pg 42).
The Prime Minister’s Science, Engineering and Innovation Council (PMSEIC) report ‘Sustaining Our
Natural Systems and Biodiversity’2 and background paper ‘Setting Biodiversity Priorities’3 reports that
Australia ‘may not yet have seen the worst of this biosecurity risk - there are still many potential
invaders waiting in the wings’. The report recommends actions to deal with biosecurity and early
detection and eradication of potential invasive species. The background paper notes that the risks that
invasive species pose to Australia’s biodiversity include:
 There are some 2,700 naturalised non-native plants species in Australia that can act as sources of
new weed outbreaks (pg 12)
 4 to 10 native plant species are threatened by each serious weed species (pg 14)
 16 native bird species are threatened or vulnerable due to weeds (pg 14)
 49 native bird species are threatened or vulnerable due to invasive herbivores (pg 15)
 28 native bird species are threatened or vulnerable due to invasive predators (principally foxes
and cats) (pg 15).
Under the EPBC Act nine species have been listed as key threatening processes that threaten the
survival, abundance or evolutionary development of native species or ecological communities.
Invasive species listed under the Act include the European red fox, feral rabbit, feral goat, feral cat and
feral pig. Several disease-causing organisms are also listed, such as Psittacine Circoviral (beak and
feather) disease and chytrid fungus infection in amphibians.
The Australian, State and Territory governments in 1999 agreed a list of Weeds of National
Significance. The list identifies 20 weeds from some 2,700 non-native naturalised plants4. Weeds of
National Significance were identified through a weed risk assessment process by analysing each
weed’s invasiveness and impact characteristics, the potential and current area of spread, and primary
industry, environmental and socio-economic impacts.
During 2000, the Department worked with consultants and technical experts to identify species to
include on a National Environmental Alert List. The alert list identifies weed species that are in the
early stages of establishment and have the potential to become a significant problem if they are not
managed. This list contains 28 non-native species that are, or are likely to be, significant threats to
biodiversity.
The case studies below provide some on-ground examples of the threats that invasive species pose to
Australia’s biodiversity.
Case Studies
Case Study 1: Foxes in Tasmania
The European Red Fox was recently introduced to Tasmania. Tasmania is home to many species that are extinct
on the mainland, and up to 77 native species are threatened by foxes. Of these species, 49 are restricted in
range or declining in distribution. Ten are listed or nominated for national listing as threatened species. Foxes
also pose an economic threat to the Tasmanian wool industry through lamb predation and to Tasmania’s nature
based tourism industry.
Case Study 2: Red imported fire ant in Queensland
The red imported fire ant, Solenopsis invicta, was discovered at two separate sites in Brisbane in February
2001. Modelling indicates they have the potential to spread across much of Australia. Nationally threatened
species such as the loggerhead turtle and many species of reptiles and ground-nesting birds could be negatively
affected if fire ants were to become established. Native animals stung by fire ants can be blinded or infected,
reducing their chances of survival or killing them outright. Fire ants could become a serious pest in agriculture,
as has happened in the United States. The Australian Bureau of Agricultural and Resource Economics has
indicated that the potential cost of Fire Ants to the agricultural sector is about $8.9 billion over a 30-year
period.
2 Sustaining Our Natural Systems and Biodiversity PMSEIC 2002 (pp 17-18).
3 Setting Biodiversity Priorities, for PMSEIC, by Possingham et al (2002)
4 The determination of weeds of national significance. Thorpe & Lynch (2000) (pg 1)
2
Case Study 3: Cane toads
The cane toad was originally introduced to Queensland to kill pests in cane fields in the 1930s. Since then, the
cane toad has spread south as far as Port Macquarie in NSW, reached Kakadu National Park in 2001 and
continues to expand its range southwards and north-west. Current estimates show cane toads are spreading in
the tropics at about 27 kilometres a year. Recent research undertaken in Kakadu National Park indicates that
cane toads cause substantial declines in northern quoll (Dasyurus hallucatus) populations. There is a significant
risk that quoll species across northern Australia may become locally extinct in areas invaded by cane toads. As
a precautionary measure, a representative sample of northern quolls have been moved to cane toad-free
islands off Arnhem Land to safeguard the species.
Case Study 4: New Zealand Screwshell (Maroculpus roseus)
The New Zealand Screwshell is a sedentary organism that feeds by filtering particulate matter from the water
column, and grows up to 90 mm in length and 25 mm in width. It was probably introduced to Australia through
semi-dry ballast in timber vessels from New Zealand, or accidentally transported with live oysters during the
1920s. In Australian waters the species has spread out to the 80-metre depth contour off the eastern Victorian
and New South Wales coasts, as far north as Botany Bay 5. The Screwshell may occur in massive aggregations of
several hundred organisms per square metre, and is so abundant in some areas that the benthic habitat has
been altered from one of fine sand or mud to one with a dense cover of live and dead shells.
Although New Zealand Screwshell is widely distributed in southeast Australian waters, little is known about its
impacts. The Screwshell is thought to reduce numbers of native screwshells and scallops through direct
competition for food and space. It is reported that native screwshells as well as commercial scallop species
have declined in abundance since the appearance of New Zealand Screwshell 6.
New Zealand Screwshell has wide tolerances for salinity, temperature and depth, so has the potential to spread
around the southern Australian coastline in waters up to a depth of 80 metres, and possibly 200 metres.
Case Study 5: Northern Pacific Seastar (Asterias amurensis)
The Northern Pacific Seastar, Asterias amurensis, is a five-armed predatory seastar that can reach 40-50
centimetres in diameter. It is mainly found in coastal areas that are protected from wave action. In its native
Japan it has been recorded at a depth of 200 metres, although in Australia it is not found at such depths, but
on shallower (less than 25m deep) soft sediment habitats and reefs.
In Australia the Seastar feeds on a wide range of native animals and can have a major effect on the recruitment
of native shellfish populations that form important components of the marine food chain. Recent reports
indicate that the Seastar is now affecting oyster production on some marine farms in southeast Tasmania 6.
The Northern Pacific Seastar is thought to have been first released in Australia in the Derwent River, where it is
now established, from ballast water in the 1980s. It was translocated to Port Phillip Bay in the 1990s, where its
population is estimated to have increased from 340,000 in 1998 to 150 million in early 2000 before declining to
90 million in early 20017. This species has the potential to occupy and dominate suitable habitats around
Australia’s coast from Sydney to Perth and its depth tolerances would allow it extend to the mid and outer
continental shelf8.
Biodiversity is threatened in local areas that the Seastar invades, through direct predation on native species as
well as by out-competing native species for food. The Seastar has been implicated in the decline of spotted
handfish populations in the Derwent Estuary as well as two rare echinoderms and threatens the unique shallowwater community of Port Davey, Tasmania8.
The Northern Pacific Seastar has impacted on shipping, aquaculture (including a $1 million cost to Tasmanian
scallop farmers in 2000) and commercial and recreational fisheries. Although there has been no major fishery
collapse in Australia due to the Seastar, the costs are potentially large and multi-million dollar damage has
been reported in Japan, particularly in shellfish industries.
5 Bax, N.J., MCEnnulty, FR and Gowlett-Holmes, K. Distribution of the introduced Gastropod Maoriculpus roseus (Quoy and Gamard 1834) (Caenogastropha: turritellidae)
in Australia, Centre for Research on Introduced Marine Pests Technical Report number 25, CSIRO Marine Research.
6 NIMPIS (2002). Maoricolpus roseus impact details. National Introduced Marine Pest Information System (Eds: Hewitt C.L., Martin R.B., Sliwa C., McEnnulty, F.R.,
Murphy, N.E., Jones T. & Cooper, S.). Web publication <http://crimp.marine.csiro.au/nimpis>, Date of access: 1/09/2003
7 Parry G , Cohen B (2001) Asterias amurensis biomass, distribution and abundance in Port Phillip Bay following a survey during March-April 2001 , unpublished paper,
Marine and Freshwater Resources Institute, 30 May 2001.
8 Joint Standing Committee on Conservation / Standing Committee on Fisheries and Aquaculture National Taskforce on the Prevention and Management of Marine Pest
Incursions (1999) National Control Plan for the introduced marine pest Northern Pacific Seastar (Asterias amurensis), Final Draft 1999 in Report of the Taskforce, 23
December 1999.
3
2. The estimated cost of different responses to the environmental issues associated with
invasive species, including early eradication, containment, damage mitigation and inaction,
with particular focus on:
(i) the following pests:
(A) European fox (Vulpes vulpes)
(B) yellow crazy ant (Anoplolepis gracilipes)
(C) fire ant (Solenopsis invicta)
(D) cane toad (Bufo marinus),
(E) feral cat (Felis catus) and pig (Sus scrofa)
(ii) the following weeds:
(A) mimosa (Mimosa pigra)
(B) serrated tussock (Nassella trichotoma)
(C) willow (Salix spp.)
(D) lantana (Lantana camara)
(E) blackberry (Rubus fruticosus agg.)
(F) parkinsonia (Parkinsonia aculeata)
The environmental cost of inaction is high. However, at present there is no agreed model to measure
the ecological cost of invasive species in economic terms.
Where invasive species impact on agriculture, the cost to production can be more readily
demonstrated in economic terms. A report from the Bureau of Rural Sciences 9 noted the direct shortterm economic losses caused by 30 non-indigenous vertebrate pest species that have established wild
populations to be at least $420 million per year, mainly due to lost agricultural production. Estimates
of the cost of weeds, to agricultural industries alone, range from $1.1 to $3.3 billion per annum10.
Together with State and Territory land management agencies, the Australian Government is funding
projects to help address the impacts caused by all the species listed above. The Department works
closely with the Department of Agriculture, Fisheries and Forestry to support such management
activities, particularly through Natural Heritage Trust funding.
The Department undertakes on-ground eradication and control projects for several of these species in
reserves that it manages. In particular actions are undertaken to control feral pigs, feral cats, mimosa
and parkinsonian (survey only) in Kakadu National Park, yellow crazy ants on Christmas Island, feral
cats in Norfolk Island National Park and the European red fox in Booderee National Park.
The current cost of managing invasive species – for example through planning, research, on-ground
works and education – can be quantified. Tables 1 and 2 identify the Departments expenditure
through the Natural Heritage Trust national feral animal control program and the national weeds
program for the species listed in these terms of reference. These Trust programs also fund the
management of other invasive species not listed above. The Department provides funding to manage
invasive species which pose a threat mainly to environmental values. DAFF provides funding to
manage invasive species which pose a threat mainly to production values, which include some of the
species listed in the term of reference. The figures in Tables 1 and 2 do not include funding provided
for integrated multi-species pest management projects. For the national feral animal projects, such
integrated projects represent an additional $2.9 million in funding over and above the figures
provided in Table 1. For the national weeds projects these projects represent an additional $1.3 million
in funding to the figures provided in Table 2. Tables 3 and Table 4 outline the approximate on-ground
management costs for the Department.
9
Non-indigenous vertebrates in Australia. In Biological Invasions, ed D Pimental (2002), pgs 25-44.
The impact of alien plants in Australia. In Biological Invasions, ed D Pimental (2002), pg 13.
10
4
Table 1. Natural Heritage Trust funding provided by the Department (1996/97 – 2002/03) through the national
feral animal control program for the control of the animal species listed in term of reference 1(b).
This funding complements activity funded through State and Territory land management agencies.
On-ground
Works
Species
Research
European fox (Vulpes vulpes)
$2,421,978
$1,175,372
$0
$1,750
$3,599,100
Yellow crazy ant (Anoplolepis
gracilipes)
NA
NA
NA
NA
$0
Fire ant (Solenopsis invicta)
NA
NA
NA
NA
$0
$1,528,807
$24,000
$0
$0
$1,552,807
$572,981
$228,179
$69,978
$2,624
$873,762
$0
$22,400
$54,550
$24,070
$101,020
$4,523,766
$1,449,951
$124,528
$28444
$6,126,689
Cane toad (Bufo marinus)
Feral cat (Felis catus)
Feral pig (Sus scrofa)
Total
Coordination
Education
Total
Table 2. Natural Heritage Trust funding provided by the Department (1996/97 – 2002/03) through the national
weed control program for the control of the plant species listed in term of reference 1(b). This funding
complements activity funded through State and Territory land management agencies.
Species
Reduce impact
of Weeds of
National
Significance²
Prevent new
weed
problems¹
Framework &
capacity
building³
Total
Mimosa (Mimosa pigra)
$0
$4,855,305
$0
$4,855,305
Serrated tussock (Nassella trichotoma)
NA
NA
NA
$0
Willow (Salix spp.)
$0
$675,180
$196,920
$872,100
Lantana (Lantana camara)
NA
NA
NA
$0
Blackberry (Rubus fruticosus agg.)
NA
NA
NA
$0
Parkinsonia (Parkinsonia aculeata)
$0
$82,900
$0
$82,900
Total
$0
$5,613,385
$196,920
$5,810,305
¹ Goal 1 of the National Weeds Strategy is ‘to prevent the development of new weed problems’. This is usually
species on the National Environmental Alert List, not Weeds of National Significance.
² Goal 2 of the National Weeds Strategy is ‘to reduce the impact of existing weed problems of national
significance
³ Goal 3 of the National Weeds Strategy is ‘to provide the framework and capacity for ongoing management of
weed problems of national significance.
Table 3. Approximate on-ground management costs (1996/97 – 2002/03) incurred in reserves managed by the
Department for the control of the animal species listed in terms of reference 1(b)
Species
Research
Onground
Works
Coordination
Education
Total
European fox (Vulpes vulpes)
$3,230
$50,022
$21,997
$350
$75,599
Yellow crazy ant (Anoplolepis
gracilipes)
$227,405
$612,998
$275,413
$3,855
$1,119,671
$0
$0
$0
$0
$0
Cane toad (Bufo marinus)
$55,000
$0
$0
$0
$55,000
Feral cat (Felis catus)
$55,000
$162,943
$46,094
$10,850
$274,887
Feral pig (Sus scrofa)
$20,000
$1,680,000
$0
$0
$1,700,000
$360,635
$2,505,963
$343,504
$15,055
$3,225,157
Fire ant (Solenopsis invicta)
Total
5
Table 4. Approximate on-ground management costs (1996/97 – 2002/03) incurred in reserves managed by the
Department for the control of the plant species listed in terms of reference 1(b)
Species
Mimosa (Mimosa pigra)
Prevent new weed
problems¹
Reduce impact of
WONs²
Framework &
capacity
building³
Total
$5,040,000
$0
$560,000
$5,600,000
Serrated tussock (Nassella
trichotoma)
$0
$0
$0
$0
Willow (Salix spp.)
$0
$0
$0
$0
Lantana (Lantana camara)
$0
$0
$0
$0
$0
$0
$0
$0
$5,000
$0
$0
$5,000
$5,045,000
$0
$560,00
$5,605,000
Blackberry (Rubus
fruticosus agg.)
Parkinsonia (Parkinsonia
aculeata)
Total
6
3. The adequacy and effectiveness of the current Commonwealth, state and territory statutory
and administrative arrangements for the regulation and control of invasive species
Under the Australian Constitution, State and Territory Governments have specific and clear primary
responsibility for the legislative and administrative framework within which natural resources are
managed. The Australian Government’s involvement in environmental matters focuses on matters of
national environmental significance, including:
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nationally threatened species and communities which are listed under the EPBC Act (note that
these species may not be the same as those listed under state legislation);
World Heritage properties;
wetlands which are listed as Ramsar wetlands of international importance;
migratory species that are listed under the EPBC Act (these are migratory species protected
under international agreements);
Nuclear actions, including uranium mining; and
the Commonwealth marine environment (which is generally Australian waters beyond the 3
nautical mile limit of State waters).
National heritage properties.
The Australian Government has responsibility in relation to the regulation of the import and export of
animal and plant material.
The Australian Government has an interest in the development and implementation of national
measures and agreed programs to control feral animals and weeds.
Reflecting these roles, the Department undertakes a broad range of activities to regulate and control
invasive species, as follows.
Risk assessment, quarantine and import controls
Prevention of the introduction and establishment of invasive species is the most cost-effective means
of pest management.
The Australian Government has established processes to assess the risk associated with proposed
imports to reduce the potential for the introduction of pests and diseases.
The Quarantine Act 1908 and the Environment Protection and Biodiversity Conservation (EPBC) Act 1999
regulate the entry of live plants and animals into Australia. The EPBC Act controls the import of live
specimens into Australia so that the likelihood of importing a non-native species with the potential to
have a significant impact on the environment is minimised. The Department of Agriculture, Fisheries
and Forestry administers the Quarantine Act.
Both the Quarantine Act and the EPBC Act require that live specimens be assessed for their potential
impacts. The Departments of the Environment and Heritage and Agriculture, Fisheries and Forestry
have worked closely to develop an integrated process for the assessment of specimens. This reduces
duplication and streamlines the assessment processes, both for the Australian Government and for the
applicant (or potential importer). The agreement of both Departments is required before a live
specimen can be imported.
The EPBC Act established a list of specimens suitable for live import (the live import list) and prohibits
the import of any species not on this list. The legislation provides for the possibility of a live import
being permitted under exceptional circumstances where the Minister is satisfied there is no risk to the
environment. The live import list is divided into two parts – Part 1 is a list of specimens that may be
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imported without a permit and Part 2 is a list of specimens that may only be imported with a permit,
often with conditions attached. It is an offence to import a specimen that does not appear on the list, or
a specimen on Part 2 without a permit.
An applicant wishing to add a species to this live import list must prepare an assessment report
examining the potential impacts on the environment of the proposed import. The draft terms of
reference for the report and the draft report are published on the Department’s website for public
comment, an email to registered stakeholders is sent out inviting comment on both documents, and a
letter is sent to the appropriate State, Territory and Australian government Ministers requesting
comment on the draft report. A species will be added to the live import list only when the Minister is
satisfied that it will not impact on the Australian environment.
The trade amendments to the EPBC Act have been in place since January 2002. To date, the
Department has received 112 applications to amend the live import list since commencement.
Based on an impact assessment report, the application process has been completed for 11 applications.
As a result there has been 9 species added to the live import list since commencement. In addition the
import conditions for 2 species have been altered to allow for release of the organisms as biocontrol
agents, although the species were listed on the live import list at its commencement.
Currently there are 62 applications which are being progressed by the applicant (eg development of
the assessment report, collating further information relating to their application etc), 36 applications
are being progressed by the Department, 11 have been completed, 2 withdrawn and 1 internal
amendment to the list relating to the listing of plants has also been completed.
During 2002-2003 Biosecurity Australia (part of DAFF), using the weed risk assessment process,
refused entry for 320 plant species. The weed risk assessment process showed that these species had a
high potential to become a weed of agriculture and/or the environment if they were to be imported
into Australia.
On-ground action in reserves managed by the Department
The EPBC Act identifies the statutory arrangements for the control of invasive species in
Commonwealth reserves. The EPBC Act requires each reserve to have a management plan in place as
soon as practicable after the reserve has been declared. The Department has prepared management
plans for terrestrial Commonwealth reserves that outline feral species and weed control actions.
These arrangements are very effective. For example, Kakadu National Park contains the most
significant mimosa-free wetlands in the Northern Territory.
Matters of national environmental significance
The EPBC Act is the Australian Government’s legislative framework for managing environmental
invasive species. The Act provides for the listing of key threatening process and the creation of
national threat abatement plans.
The development of threat abatement plans involves wide consultation, with an initial workshop
being held, where representatives covering the range of all stakeholder interests are invited to attend.
The workshop provides an opportunity for participants to discuss and consider the goals, objectives
and actions that the threat abatement plan should contain. Draft plans are circulated for public
consultation for a 3-month period.
The current EPBC Act arrangements concerning the development of national threat abatement plans
are adequate and effective in developing the initial framework for identifying the range of research,
8
education and on-ground control activities required to manage a national key threatening process. The
EPBC Act requires that each national threat abatement plan must be reviewed within five years.
National coordination
Coordinated action across Australia is often critical to prevention, rapid response and control of
invasive species. Cooperative arrangements have been developed between the Australian, State and
Territory governments to ensure that this action is effective.
The Australian Weeds Committee provides an inter-governmental mechanism for identification and
resolution of weed issues at a national level for Australia. The Committee manages the
implementation of the National Weeds Strategy. This strategy provides a national approach to the
management of the Weeds of National Significance and those species listed on the National
Environmental Alert List. The achievements as at February 2002, against the goals and actions of the
National Weeds Strategy are identified in Box 1.
The Vertebrate Pests Committee identifies nationally significant vertebrate pest issues, recommends
appropriate management actions, and develops principles, national policies, strategies and programs
relating to vertebrate pests to ensure the conservation, sustainable use and management of Australia’s
land, water and biological resources.
Unlike the National Weeds Strategy, there is currently no national strategy for invasive animal species.
As part of a review of the functions of the Vertebrate Pest Committee, the Committee is currently
considering the development of a national strategy that would address the impact and management of
all invasive animal species, similar to the approach developed for weeds.
Box 1. Achievements as at February 2002 against the goals and actions of the National Weeds Strategy
Goal 1:
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More effective border control
The development of a Weed Risk Assessment system for screening the importation of new plants and the
ongoing review of the list of plant species that are permitted entry to Australia
Reviewing the weed risk assessment of plant species held in Australian genetic resource centres
Developing a national reporting system for all newly naturalised plants, including risk assessment and
incursion management processes
Alert/sleeper environmental weed list –Ministerial endorsement of the Alert List
Developing improved weed identification tools such as the ‘Weedeck’ for use by community groups and
individuals
Goal 2:

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




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To reduce the impact of existing weed problems of national significance
Establishment of a process for prioritising and determining the Weeds of National Significance (WONS) list.
Gained Ministerial Council endorsement of the list of Weeds of National Significance
First round of projects funded for WONS and alert/sleeper weeds focused on on-ground outcomes and on
protecting matters of national environmental significance, eg. Ramsar wetlands and protected species
Goal 3:

To prevent the development of new weed problems
To provide the framework and capacity for ongoing management of weed problems of national
significance
Developed administrative processes for managing WONS and national strategies developed for their
management
Contributed to the establishment of a reconstituted Australian Weeds Committee
Established a network of people working with weeds across Australia
Internet site providing information about weed management
Developed national training competencies for weed management
Developed guidelines and procedures to enable a reporting and early warning system on new weed
outbreaks
Promoted complementary laws in relation to weeds at Commonwealth, State, Territory and local
government levels
9
In 2000 a national Coordinating Committee for Introduced Marine Pest Emergencies (CCIMPE) and a
National Introduced Marine Pests Coordination Group (NIMPCG) were established as interim
mechanisms pending the development of a comprehensive National System for the Prevention and
Management of Introduced Marine Pest Incursions.
The Coordinating Committee for Introduced Marine Pest Emergencies (CCIMPE) oversees a national
emergency response network for marine pests, and considers State or Northern Territory requests for
access to a national contingency cost-sharing arrangement. Under this arrangement, up to $5 million
may be made available to combat an introduced marine pest outbreak of major concern that is
amenable to eradication. CCIMPE consists of relevant agencies of the Australian Government,
including CSIRO, and the States and Northern Territory.
There have been four cases where the CCIMPE has been required to consider the reported outbreak of
a potentially serious marine pest, and several cases where an initial report was not substantiated or
did not require action. There has been one case where the emergency cost sharing arrangement has
been accessed. In this case, during cleaning of a seized foreign vessel in Trinity Inlet, Cairns, an
infestation of the Asian Green Mussel (Perna viridis) was discovered. CCIMPE determined that the
first, investigatory, stage of an emergency response was appropriate. This was implemented by the
Queensland Government, with the support of $50,000 from the contingency cost sharing arrangement,
and involved the inspection of high-risk vessels, and the removal of any Asian Green Mussels found,
as well as ongoing monitoring. A total of 16 mussels were found during March - June 2002, and a
further 21 mussels have been discovered subsequently.
The National Introduced Marine Pests Coordination Group (NIMPCG) was established to recommend
detailed reforms to implement a National System for the Prevention and Management of Introduced
Marine Pest Incursions, including:
 Prevention systems operating at the pre-border, border and post-border levels
 Coordinated emergency response to new incursions (implemented through CCIMPE under
interim arrangements)
 Ongoing control of introduced marine pests already in Australia
 Supporting components for research and development, community preparedness, education and
training
 Explicit agreement on the statutory framework of the National System, and secure funding
arrangements
Preliminary work on the national system has included identifying the requirements for a system to
regulate the ballast water of both international and coastal shipping, and on a framework for
management of biofouling pests. Further development is contingent on finalising the agreement
between governments on the legislative and financial framework. These matters are being considered
by the Natural Resources Management Ministerial Council in October 2003, as well as by the
Australian Transport Council.
Reforms introduced over 2000-2003 include the introduction of mandatory ballast water management
requirements for international vessels introduced by the Australian Quarantine and Inspection Service
in July 2001; the establishment and operation the national emergency response network overseen by
CCIMPE; and an increased focus on scientific research aimed at control of introduced marine pests
already in Australia, notably the Northern Pacific Seastar.
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4. The effectiveness of Australian Government funded measures to control invasive species
An indication of the level of expenditure by the Department on measures to control invasive species
was given earlier in section 2.
Funding is directed to the objectives and actions of the threat abatement plans for key threatening
processes listed under the EPBC Act. A number of the projects, such as the development of biological
controls for invasive animal and plant species, are long term in nature.
Natural Heritage Trust funding is being provided to CSIRO Sustainable Ecosystems to support
research into the development of a biological control for cane toads in Australia. A recent review of the
project concluded that excellent progress has been made with respect to identifying genes capable of
blocking cane toad metamorphosis.
A similar research project is being undertaken to develop an immunocontraceptive vaccine for the
control of fox populations in Australia. This ongoing project aims to develop a bait-delivered
immunocontraceptive vaccine to compromise the fertility of wild foxes. The vaccine is intended to
provide a humane measure for the biological control of foxes to be integrated with existing on-ground
control programs. The outcome of this component of the project will be a bait-deliverable
immunocontraceptive candidate vaccine with significant antifertility in foxes, that is ready for
evaluation in larger scale trials.
The Department also had a significant role in efforts to control the Yellow Crazy Ant on Christmas
Island. The invasion of crazy ants on Christmas Island had the potential to wipe out the worldrenowned red crab population. The control program started with a research program followed by field
trials and ground baiting. In 2002, research and control efforts culminated in a major aerial control
campaign that devastated the crazy ant super colonies. The Department and the Invasion Biology
Group from Monash University were awarded a 2003 Banksia Foundation award for the Protection of
Australia's Environment in recognition of their efforts. Knowledge gained from the Christmas Island
program is being used for invasive ant control programs on the Australian mainland and has already
helped to successfully eradicate yellow crazy ants from Cairns.
Other biological control projects are being funded through the Natural Heritage Trust in an attempt to
develop long term, cost effective methods of controlling a number of Weeds of National Significance.
CSIRO Division of Entomology has been involved with a national project, ‘Biological control of
Mimosa pigra and integration with other control options’. The results from this project have been
encouraging and have shown that the suite of biological control agents and other management
practices can have a significant impact on Mimosa pigra. This work will assist with the on-ground
management of Mimosa pigra in the Northern Territory (including Kakadu National Park) and at sites
where new outbreaks have occurred such as at Peter Faust Dam in Queensland.
Infestations of Mimosa pigra broke out over 80,000 hectares of the Top End in the 1970s, threatening
both agriculture and the wetlands of Kakadu National Park, managed by the Department. A vigilant
and systematic approach to mapping and eradicating the weed at a cost of $500,000 a year has
controlled this pest and work continues to prevent new outbreaks. As a result, Kakadu remains the
most significant mimosa free wetland region in the Northern Territory.
The Department is funding the CSIRO Division of Entomology to conduct research into the release
and redistribution of three bridal creeper biological control agents. One of these agents, the bridal
creeper rust fungus, was approved for release as a biocontrol agent for bridal creeper in June 2000.
Recent informal reports from field researchers working in Esperance and Bremer Bay in Western
Australia note the excellent on-ground results that the rust is achieving in controlling this weed of
national significance and the high level of community support in helping achieve these results.
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5. Whether the Environment Protection and Biodiversity Conservation Amendment (Invasive
Species) Bill 2002 could assist in improving the current statutory and administrative
arrangements for the regulation, control and management of invasive species
This Bill aims to prevent the introduction of further species in Australia and to eradicate or control
those already here. Comments are provided on issues raised in the Subdivisions of the Bill.
Subdivision A – Issues to do with listing processes
As previously noted, the EPBC Act establishes a list of specimens suitable for live import (the live
import list) and prohibits the import of any specimens not on this list. The legislation provides for an
import being permitted under exceptional circumstances if the Minister is satisfied that there is no risk
to the environment.
Before a species can be added to the live import list an assessment of its potential impact on the
environment, including extensive consultation, must be undertaken, to the satisfaction of the Minister.
If approved, the amendment to the live import list is made by instrument published in the Australian
Government Gazette. The amendment must be tabled in both Houses of Parliament and may be
disallowed.
The list of species permitted for import required by this Bill (s266AA(a)) exists under the EPBC Act. A
species not appearing on this list is not permitted for import. Therefore the list of species prohibited
for import required by this Bill (266AA(b)) also exists under the EPBC Act.
Under section 266AC (2) the Bill categorises the following as prohibited imports: pasture grasses;
ornamental plants and aquarium fish. As a number of these species are currently in trade (though
controlled by the wildlife trade provisions to the EPBC Act) banning them outright could have
negative economic impacts.
The listing process in the Bill is modelled, for the most part, on the listing process that is used for
listing threatened species, key threatening processes and ecological communities under the current
EPBC Act (see Part 13, subdivision A).
The timeframes used in the process of listing invasive species will be the same as that currently used
for listing threatened species. These additional listing processes would have significant resources
implications.
While it is difficult to estimate the number of nominations that may occur, in the case of weed species
this could include up to 2700 species that have been highlighted in other papers referred to in this
submission (see footnote 3), requiring assessment (both by the Department and the proposed Invasive
Species Advisory Committee), preparation of listing advice and possible listing as an invasive species.
The Bill includes genetically modified species under the definition of 'invasive species' (s266AB(1)(b)).
There is already a detailed and comprehensive nationally agreed and consistent scheme for the
regulation of 'dealings' with genetically modified organisms (GMOs). The Gene Technology Act 2000
(GT Act) (which came into force on 21 June 2001) and corresponding State and Territory laws
constitute this nationally consistent scheme. The object of the GT Act includes the protection of the
environment. The Bill does not appear to repeal or recognise current gene technology statutes.
For each application for the intentional release of a GMO into the environment, including imported
GMOs, the GT Act assessment process is rigorous and detailed. It involves wide consultation by the
Gene Technology Regulator (GTR) with a wide range of sources, including the expert Gene
Technology Advisory Committee and the federal Environment Minister, as well as the public.
Specifically, under the GT Act, the Environment Minister is consulted by the GTR on two occasions
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before finalisation of a scientific risk assessment and risk management plan for each intentional
release. The GT Act provides for independent decision-making by the independent GTR.
There is no scientific basis for assuming that all GMOs are 'invasive'. The GT Act evaluates the
environmental safety of genetically modified species case-by-case, and only in respect of potential
risks "posed by, or as a result of, gene technology". The approach to include GMOs in the scope of the
Bill, by defining GMOs as 'invasive species' (s266AB(1)(b)), may duplicate the environmental risk
assessment under the GT Act.
The Bill's provision in respect of GMOs, may be inconsistent with the intergovernmental Gene
Technology Agreement (GT Agreement) on the current regulatory scheme for GMOs. This agreement
commits to the gene technology regulatory scheme being based on a scientific assessment of risks
undertaken by an independent Regulator. Under the GT Agreement, there is a commitment that
changes to the current scheme should be agreed by a Gene Technology Ministerial Council (GTMC)
that is recognised in the GT Act.
If the GMO is a species newly introduced to Australia, other Australian Government statutes such as
the Quarantine Act 1908, and in some instances the EPBC Act, currently apply and would include
evaluation of environmental risks.
Subdivision B – Issues to do with Permit System processes
This section of the Bill duplicates the current regulatory framework. It is currently an offence to import
a live specimen into Australia unless it appears on the live import list. It is an offence to possess an
illegal import, either for personal or commercial purposes. Further, if a species appears on Part 2 of the
live import list, a person currently wishing to import that specimen must apply, and pay, for a permit.
The information required by the Bill - in section 266BD (3) (a) - is already a mandatory requirement in
the assessment that is undertaken before a new species is added to the live import list. All applications
for additions to be made to the live import list undergo an assessment, including extensive public
consultation.
Subdivision C – Issues to do with Invasive Species Threat Abatement Plans processes
The relationship is not clear between the invasive species threat abatement plans as proposed by the
Bill and threat abatement plans established for key threatening processes under the EPBC Act.
The proposed process removes the decision-making ability of the Minister to agree to make or revoke
an invasive species threat abatement plan. A number of the processes outlined in Subdivision C of the
Bill do not vary significantly from the matching provisions of the EPBC Act.
The number of listed invasive species that may require threat abatement plans to be established under
the provisions of the Bill could be very high. The preparation, implementation and review of high
numbers of invasive species threat abatement plans will require significant human and financial
resources to be applied to these tasks if they are to be completed in the timeframes set out in the Bill.
Threat abatement plans for invasive species or key threatening processes or both?
The Bill proposes to broaden the role of threat abatement planing so that two types of threat
abatement plans will exist: (a) key threatening process threat abatement plans and (b) invasive species
threat abatement plans.
Under such a regime it is possible that a species is listed as both an invasive species and a key
threatening process. This could require two threat abatement plans for the same species. These plans
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would go through separate development processes with the content of the invasive species threat
abatement plan (s266CE in the Bill) being different to the key threatening process threat abatement
plan (s271 of the EPBC Act). This duplication would not achieve a better conservation outcome.
The Minister’s decision to have or revoke a threat abatement plan
Under the EPBC Act (see s270A) once a key threatening process has been listed the Minister must
decide whether or not to have a threat abatement plan for the process. This decision is based on the
Minister’s agreement that ‘having and implementing a threat abatement plan is a feasible, effective
and efficient way to abate the process.’
Under the Bill (see s266CD(2)) the Minister must make a written invasive species threat abatement
plan for any species listed as eradicable or substantially containable. Under the Bill it is assumed that
an invasive species threat abatement plan is a feasible, effective and efficient way to abate the process.
Under the EPBC Act (see s283A) the Minister may revoke a threat abatement plan, for example if the
plan no longer identifies a feasible, effective and efficient way to abate the process. There is no such
provision to revoke an invasive species threat abatement plan in the Bill.
No threat abatement plan for invasive species listed as ‘beyond eradication’?
As noted above the Bill will require invasive species threat abatement plans to be established for
species listed as ‘eradicable’ or ‘substantially containable’ (see s266CD(2)). It is not clear why a threat
abatement plan (or alternative process) is not required for an invasive species that is listed as ‘beyond
eradication’. As recognised by the criteria for the ‘beyond eradication’ category of listing (see
s266AC(4)(c)), these invasive species would continue to be a significant threat to Australia’s
biodiversity and production values. The Department considers that it would still be important to have
a threat abatement plan to manage these ‘beyond eradication’ species. Based on current management
tools available, a number of species currently being managed under the EPBC Act would fall into this
category (eg. foxes, rabbits, mimosa). As a starting point the threat abatement plans for these species
must clearly show:
(a) why these species are considered as ‘beyond eradication’;
(b) what would be required to have the listing of this species re-categorised to ‘substantially
containable’ or ‘eradicable’. This may be possible with the development of biological control
technologies;
(c) the required actions and objectives to:
 protect key areas of high biodiversity (such as habitat for threatened species) and
production values from these species, and
 provide a strategic national framework that would guide the ongoing land management,
research and monitoring and evaluation activities required for this species.
Differing timeframes for making and enforcing threat abatement plans
Under the EPBC Act (see s273(4)) a key threatening process threat abatement plan, where the Minister
decides to develop one, must be made and in force within three years of the decision to have the plan.
Under the Bill (see s266CD(3)) threat abatement plans must be prepared within two years of listing for
eradicable species and within five years of listing for substantially containable species. Note that this is
only concerns the preparation of the plans, it does not define when the plans come into force. This
timeframe ensures that the plans required for eradicable species are given a higher priority than
species listed as substantially containable.
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Under the Bill (see s266CF) it is not clear when a plan would come into force. It could be (a) the day on
which it is made (not defined) (b) the day on which it is adopted (not defined) (c) a later day specified
by the Minister in writing and published in the Gazette. No time frame is set in which the Minister
must specify this date.
Under the Bill it could be possible for a threat abatement plan for an eradicable species to be prepared
within 2 years, but then delayed coming into force. The EPBC Act (see s273(4)) provides clear
timeframes for when all threat abatement plans must be made and come into force.
Preparation of threat abatement plans for native species outside their natural range
Under the Bill (see s266CD(5)) the Minister may prepare an invasive species threat abatement plan for
any other species currently present in Australia. This allows the Minister to pre-empt the listing
process and proceed directly to the creation of a threat abatement plan. In such a situation it is not
clear if or how such a species would be included in one of the categories of listing (see s266AA). Such a
process could result in a confusing and ad hoc approach to threat abatement planning for invasive
species, with inconsistent standards for the identification of invasive species.
If this section is designed to provide a mechanism for the management of native species that occur
outside their natural range and are invasive species in these areas, then the existing process under the
EPBC Act provides a mechanism for native species (or groups thereof) that have become invasive in
areas outside of their natural range to be considered as a key threatening process. This was
demonstrated in the proposal to list the 'Introduction of Live Fish into Waters Outside their Natural
Range after 1770' as a key threatening process under the EPBC Act.
Contents of threat abatement plans
The EPBC Act also ensures that the key threatening process threat abatement plan must give regard to
issues such as minimising any significant adverse social and economic impacts, Australia’s obligations
under international agreements and the role and interests of indigenous people in the conservation of
Australia’s biodiversity (see s271(3)). These issues are not considered in the contents of invasive
species threat abatement plans established under the Bill.
The threat abatement plans established under the EPBC Act have evolved since the first four plans
were published in 1999. All of the plans focus on the objectives and related actions required to abate
the key threatening process. The more recent plans include performance indicators for each objective.
As the older plans are reviewed they will be updated to include performance indicators. The threat
abatement plans have, where required, considered issues such as animal welfare as part of the plan.
Issues, such as animal welfare issues may be considered under existing provisions of the EPBC Act.
Review of threat abatement plans
Under the EPBC Act (see s279(2)) each key threatening process threat abatement plan must be
reviewed every five years. This gives enough time for policy makers, researchers and land managers
to set in place and achieve a range of activities to address the objectives and action set out in the plans
before their review.
Under the Bill (see s266CL(2)) each invasive species threat abatement plan must be reviewed every
two years. This short timeframe will not allow significant progress to be achieved since the plans
introduction. The review period for all threat abatement plans should be the same.
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Subdivision D – Issues to do with Miscellaneous issues – particularly the ‘Register of Traders in
Non-indigenous Species’ and the ‘Warning Requirement system’
The register of traders in non-indigenous species is similar in concept and design to the National
Exotic Bird Registration Scheme (NEBRS), which was established in 1996 to manage the possession
and trade in exotic birds. In the absence of other means, the principal benefit of NEBRS was the
compilation of most, if not all, exotic birds known to be in Australia and better knowledge of their
numbers and location. It enabled the States and Territories to regulate the holding and movement of
exotic birds within their jurisdictions using a much-improved base line set of data. Federal authorities
used the scheme in relation to import controls and risk assessment requirements. The 2001
amendments to the EPBC Act require the defendant to provide evidence in relation to whether an
exotic bird is held in accordance with the EPBC Act. Thus it was found that NEBRS was no longer
necessary to manage the possession and trade in exotic birds. The scheme was discontinued in January
2002 when the Environment Protection and Biodiversity Conservation (Wildlife Protection) Amendment Act
2001 came into effect.
Registration of non-indigenous species traders is not necessary to control the possession and use of
non-indigenous species for commercial purposes. The size of the register could be very large, the cost
of its administration high and enforcement unlikely to be cost-effective. Most breaches are likely to be
minor and undiscovered, and the cost of any prosecutions high relative to the offence. Effective
regulation of non-indigenous species is arguably better achieved through a defendant having the
evidential burden (already in place), greater and more effective co-operation between jurisdictions (in
place and under constant review) and increased state and territory efforts.
The pest warning requirement will be difficult to enforce and compliance is likely to be low.
Division 1 Part 19 – Issues to do with the establishment and functions of the Invasive Species
Advisory Committee
The operation of the current Threatened Species Scientific Committee (TSSC) established under the
EPBC Act will be used to provide some comparison of the workload and costs that are likely to be
involved in establishing a similar Invasive Species Advisory Committee (ISAC) to advise on the listing
of invasive species.
The Department has received over 200 threatened species nominations for listing under the EPBC Act
from 1 July 2000 – June 2003. In addition to these species nominations, nominations for threatened
ecological communities and a number of key threatening processes have also been received. The TSSC
meets three times a year.
The number of species nominations likely to be received by the ISAC could be substantially greater (in
the case of weed species this could include up to 2700 species that have been highlighted in other
papers referred to in this submission (see footnote 3), particularly in the first three years should the
Bill be adopted. Consideration must be given to how the ISAC will manage such a workload in the
time frames set out in the Bill.
Related to this issue will be the requirement to prepare invasive species threat abatement plans for
some of the species listed. Finding the resources within the Commonwealth, State or private sector to
enable the development of such a large number of plans in short time frame could prove difficult.
Threat abatement plans for key threatening processes cost an average of $30,000 each to prepare.
The Remuneration Tribunal sets out the fees appropriate to a Ministerial appointed Committee such as
the TSSC. These costs are currently $458 per day for members and $687 per day for the Chair including
both preparation time and sitting days. In addition travelling allowances are also provided for
interstate members. The average cost of a TSSC meeting with all members (10) attending is $38,000.
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As the ISAC would probably need to meet bimonthly to manage the initial workload, it is estimated
that the ISAC will cost $228,000 per year to operate (6 meetings at an average cost of $38,000 each).
It is unclear what role the ISAC would have with the existing coordinating committees and
mechanisms identified in section 3.
Section 301A of the EPBC Act
The EPBC Act provides for further regulations to be made to control non-native species. Section 301A
of the EPBC Act provides that regulations may:




provide for the establishment of a list of non-native species which may or would be likely to
threaten biodiversity in Australia
regulate or prohibit the import of species on the list, and the trade of species on the list
between Australia and other countries and between State and Territory jurisdictions within
Australia
regulate or prohibit actions involving species on the list
provide for making plans to eliminate, reduce or prevent impacts of the listed species on
Australia’s biodiversity.
The EPBC Act provides for strict controls on the import and possession of non-native species and the
scope of s301A grants additional powers that may be established and implemented as appropriate.
Section 301A of the EPBC Act would appear to address much of what is proposed in the Bill.
Legal advice indicates that regulations could be made under Section 301A to control species listed
under Section 301A(a) by legislating for offences relating to the transport or possession of a listed
species that would be enforceable under the EPBC Act.
The development of such regulations under Section 301A of the EPBC Act would be a significant
challenge. It would require significant resources to be applied by the Department, other Australian
Government agencies, State, Territory and Local Government agencies and relevant industry and nongovernment groups and organisations. These regulations could result in significant changes to a
number of national industries particularly those associated with the nursery and pet fish trades.
The Department’s current approach to managing invasive species combines a range of statutory and
non-statutory methods. The Department believes that this approach, which includes working with
State and Territory jurisdictions and a range of other stakeholders, provides land managers with an
adaptive and effective approach to the management of invasive species in Australia.
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