Threats may be missed or species declared without clear reasons because the process for ‘declaring’ pests is not robust
The declaration of a pest by the Minister for Agriculture and Food provides the legislative mandate and formalises the need to undertake control action on a pest. Any individual or organisation can lodge a proposal to have an organism declared a pest or an existing declaration amended. The process leading to the decision to declare a pest should be transparent, consistent and robust.
Although DAFWA has reviewed its policies and procedures to declare pests under the BAM Act, policies are still ‘in draft’. There is also no publicly available information advising stakeholders how to submit a proposal or what criteria will be used to assess the threat. This increases the risk that inconsistent decisions may be made or that stakeholders will not lodge a proposal to declare a pest.
Stable Fly is the only species to be declared a pest since the BAM Act was enacted in 2007. Our review of the documentation supporting its declaration shows that it did not follow DAFWA’s draft workflows and authorisation process for declaring pests under the BAM Act. DAFWA advised that this was because a commitment to declare it was made at a community meeting. We were also unable to find evidence that an assessment of the Stable Fly’s impact had been conducted.
The status and priority of declared pests has not been subject to regular review to ensure responses match the threats
There are 169 declared pests listed in the Western Australian Organism List3. Of these, 26 have been categorised as C1 (exclusion), six as C2 (eradication) and 137 as C3 (management).
The declaration status should reflect:
- the pest’s spread, abundance and impact on both public and private interests
- an understanding of the public and private benefit in controlling the pest
- the capability, capacity, time and costs to control the pest.
To ensure that current threats are managed we expected to find a risk and cost benefit analysis supporting each of the 169 declared pests and ongoing review to ensure that declarations are amended when the characteristics of incursion change. For example, when the pest incursion is assessed as having become established or if eradication ceases to be practical and management becomes the only viable option.
In most cases the rationale for why a pest is declared is historical. There was little evidence that the threat posed by a declared pest has been subject to regular review. Information on threat, impact and spread of pests is poor and the basis for why one pest is prioritised over another is not well documented. It is therefore difficult to assess the current threat posed by a pest and we can only provide limited assurance that DAFWA has an effective process to prioritise pests.
With the BAM Act regulations coming into force on 1 May 2013, DAFWA has reclassified declared pests into the BAM Act categories. It has also started to review declared pest priorities and has advised that it plans to use impact assessment and cost benefit analysis for the highest priority pests. DAFWA has already used this analysis to support funding for the State Barrier Fence and to control pests such as camels, wild dogs and starlings. However, it has advised that its capacity to complete this analysis is limited by resources.
Without impact assessments to identify the priority pests and cost benefit analysis for guiding expenditure on pest control, assurance cannot be given that DAFWA’s limited resources are directed at the greatest risk and on the basis of greatest return.
3 The Western Australian Organism List includes 19 diseases and some pests that appear in more than one category.