The Biosecurity Strategy for New Zealand

• Looking to the future
• Building our institutions
• Maori
• Stakeholders’ voice
• Measuring performance
• Capability gaps
• Science
• Addressing priorities
• Who should pay?
• Biosecurity Council’s first recommended steps

Consistent themes from stakeholders

Just over three years ago, the Government's biodiversity strategy, 'Our Chance to Turn the Tide', highlighted the need to improve the protection of our shores from the damaging effects of invasive species. Consultation began in June 2000, leading to an issues paper sent to nearly 2,000 individuals and groups (including schools, community organisations and environmental groups). This was followed by an extensive round of consultation including hui, meetings and workshops throughout New Zealand. These submissions were collated and analysed, and it soon became clear there were some strong views on the way biosecurity should evolve; even stronger views on the current system's flaws. This work led to the release of the draft biosecurity strategy, 'Guarding Pacific's Triple Star', late in 2002.

Nearly 150 submissions on the draft strategy were received by mid-March 2003 and our website (www.biostrategy.govt.nz ) received over 17,000 hits. These submissions were categorised in a 98 page analysis and an 18 page summary; both documents are on the website.

Since the beginning of the year, a group has been working on an implementation plan to support the final biosecurity strategy. Both the strategy and the implementation plan draw substantially on the plethora of biosecurity reviews and reports produced in recent years and listed in the appendix.

The consistent themes from the consultation with stakeholders on the draft strategy have been:

1. For clearer accountability of biosecurity performance;
2. To improve the coordination and management of the highly fragmented biosecurity system;
3. To consider the full range of possible impacts when making biosecurity decisions;
4. To have a consistent approach to assessing and managing risks across all sectors;
5. For biosecurity to be run far more strategically; and
6. For greater levels of funding for biosecurity activities and a consistent approach to funding those activities.

Looking to the future

A series of biosecurity reviews have focused on the system’s faults, looking at short-term fixes and responses, without necessarily looking to the future. This document, New Zealand’s first biosecurity strategy, proposes a fundamental shift in our approach to biosecurity.

Growing threats

Despite constantly improving technology we will have to ‘run harder to stand still’. Over the past 10 years trade volumes have increased by 76%⁵ and international passengers by 93%; a high level of growth should continue. This pressure on the border increases the chances of known pests and diseases entering New Zealand. It is imperative New Zealand remains free of diseases like Bovine Spongiform Encephalopathy (BSE), Foot-and-Mouth disease and Pine Pitch Canker and pests like fruit flies. Any one of these could cause major economic damage.

Additionally, new threats will emerge across all sectors; nature is not standing still. The past 10-15 years have also seen new biological challenges - BSE, Sudden Acute Respiratory Syndrome (SARS) and Rabbit Calicivirus Disease (RCD) have spread rapidly. We have also seen the arrival of Painted Apple Moth, Guava Moth, Scolliid Wasp and Tropical Grass Web Worm. These particular organisms couldn’t have been predicted on the basis of pest profiles in their home countries.

Changing climatic conditions mean the ranges for certain pests are steadily extending. Invasive pests are an emerging global problem threatening biodiversity everywhere; evolving and adapting as they spread. These emerging pests and diseases are likely to be carried along new and different pathways, and are more likely to be resistant to current treatments.

Meeting the challenge

Biosecurity will need to be adaptable, robust and competent to handle these growing threats. It will need to be built on a solid footing, which means addressing the six key themes identified by stakeholders in the box above (‘Strategy Background’). Currently, these foundations are not complete, as evidenced by the continuing stream of reviews. It is imperative this strategy (and the Government’s consequent decisions) allows biosecurity to address these concerns.

Building a biosecurity system to meet our future needs means an organisational mind-shift to embrace all the values at risk in the definition of ‘biosecurity’ and to deal with them strategically. This will not happen unless there are changes in systems, structures and decision-making processes – along with increased capability and capacity. New Zealand’s ability to manage biosecurity risk needs bolstering, support and challenge. It will require strong leadership from within – and oversight from stakeholders in providing feedback and constructive criticism.

Three key areas need developing:

1. The ability to prioritise across activities (pre-border to pest management) and sectors (conservation, agriculture and forestry, aquatic and human health);
2. Establishment of systems and standards to allow monitoring and continuous improvement; and
3. Building underpinning knowledge and decision support systems.

Biosecurity protects all our biological resources, which contribute to environmental quality, economic prosperity, health and lifestyle. Biosecurity is about controlling living systems, which requires ongoing effort. It is not enough to provide it for one day; it must be provided every day.

At agency level – central and local government – we have significant strengths built through the experience developed to protect primary production. These now need to be built on to address biodiversity and health threats, in a much more integrated manner.

The process has started. The mind shift began with the Biosecurity Council’s formation in 1997; which brought together the chief executives of relevant government departments with representatives from regional councils, primary producers and environmental groups. The policies it developed are now used across agencies.

The mission of MAF’s Biosecurity Authority shows good intent: – "to protect New Zealand’s unique biodiversity and to facilitate exports by managing risks to plant and animal health and animal welfare." But the transformation to match this vision has not been made. In the past four years the Biosecurity Authority has made progress – but challenges appear to be arriving with greater vigour than the current arrangements can manage.

Hindered by a lack of legitimate authority, and insufficiently equipped to deal with the additional challenges, MAF largely continues to work to a vital but more limited mission – protection of primary production and trade. This is demonstrated by priorities still largely determined by risks to agriculture and production forestry.

Management of pathways where the main risk is to our indigenous flora and fauna and people has not been acted on with the same degree of urgency. There has been confusion in roles and responsibilities for some biosecurity functions relating to human health, for example responses to interceptions and incursions of venomous spiders.

Achieving multiple outcomes

Biosecurity is not an end in itself. Its origins lie in protecting our primary production; that remains vital to our economic welfare with an increasing range of threats to manage. But its scope is expanding. Our biosecurity system must now also embrace the protection of our flora and fauna, both on the land and in the sea; valuing our health; valuing aspects of our lifestyle and national identity and assessing how much we are prepared to pay to protect each of these. Although some submitters argued these values should be set in a hierarchy, the Biosecurity Council does not agree. Our biodiversity, economy and society are inextricably interdependent so all must be considered equally and consistently when making biosecurity decisions.

Outcomes supported by biosecurity activities

• Environmental - including protecting indigenous & valued introduced species, biodiversity ecosystems & landscapes;
• Commercial - including primary production, industry, tourism & service sectors;
• Safeguarding Maori cultural & spiritual values;
• Human health & well-being; and
• Social - including lifestyle & historical values.

Building our institutions

New Zealand has an internationally recognised strength in biosecurity because of the strong systems developed to protect our ability to produce and trade.

There is now considerable infrastructure (particularly at the border) to protect our access to international markets. MAF also has a strong reputation and presence in international negotiations – clearly, this needs to be maintained. But these strengths must be extended to protect us and our environment, and MAF needs to utilise the strengths built up elsewhere – within DoC, regional councils, the Ministry of Fisheries (MFish), MoH and with science providers.

This background plays an essential role in understanding our current position and future direction. Many submissions indicated concern about the proposed arrangements for government departments, although there was no consensus over alternative solutions, nor much useful analysis of their relative strengths or weaknesses. One general theme was the need to think about the system as a whole, with many concerns about fragmentation of effort, gaps in accountability and confusion of legitimate authority. These matters must be addressed but, most importantly, there must be a commitment to making decisions; rather than the current tendency to avoid them, simply because the decision faced is outside perceived agency boundaries.

Institutions require supportive legislation. The existing legislation has been heavily amended and remains far from perfect, but not imperfect enough to warrant a full-scale overhaul. Biosecurity is covered in many pieces of legislation, including the Biosecurity Act, Conservation Act, Fisheries Act, Wildlife Act, Wild Animal Control Act and Resource Management Act.

These Acts will all need to be reviewed incrementally in order to achieve this strategy’s expectations.

MAF as lead agency

The new proposal significantly simplifies arrangements. Government agencies have elected, subject to Cabinet approval, for one lead agency to take responsibility for end-to-end biosecurity, taking a whole-of-government and whole-of-New Zealand perspective. This agency will be responsible for pre-border and border activities, incursions and eradications, and the grey zone leading through to pest management.

MAF is the natural agency to take this lead role. The Biosecurity Council, however, recognises MAF needs to develop systems capable of protecting the wider interests in biosecurity and improve its connections with the aquatic, environmental and health sectors. MAF will have to make some big changes, largely to make its responsibilities and accountabilities more explicit and its decisions more transparent.

A number of mechanisms are proposed to support the expansion of MAF ’s biosecurity mandate. The key first steps will be the establishment of a ministerial committee and a chief executives ’ forum to develop the overall strategic direction for biosecurity,and monitor system performance. Other important mechanisms will include a central/regional government forum,and the Biosecurity Council reconstituted as a ministerial advisory group.

MAF will need to delegate (to other departments) where there is specific knowledge and advantage but the need to assume responsibility for that task can not be delegated; the Director-General of MAF will remain accountable. Further, departments will organise themselves into a cross-departmental grouping (a chief executives’ forum), taking collective responsibility across agencies with an interest in all outcomes.

The purpose of the chief executives ’ forum will be to support MAF ’s Chief Executive in the delivery of end-to-end biosecurity,and its members will be accountable for working together to achieve this purpose. This will include,for example, contributing to the preparation of the MAF Statement of Intent as it relates to biosecurity, prioritising biosecurity-related new initiative bids, developing a biosecurity research strategy,and implementing a Maori responsiveness strategy.

As the officer responsible for end-to-end biosecurity, MAF ’s Chief Executive will lead the forum and ensure its effective operation.

This document clarifies the Council’s expectations and provides markers to assess MAF’s performance. There is a real expectation MAF will take its expanded roles seriously by protecting the aquatic and terrestrial environments and human health on behalf of DoC, MoH and MFish, and work with regional councils to ensure better pest management.

MAF is the proposed lead agency – strengthened, collating independent strategic advice for the Minister, and with a mandate for end-to-end biosecurity management in aquatic and terrestrial environments.

The other biosecurity agencies - DoC, MoH and MFish - will work with MAF through chief executives.

The Director-General of MAF will take lead accountability for biosecurity.

Expectations - Institutional arrangements

2. That a single agency (MAF) is accountable for ensuring the full range of biosecurity activities are delivered effectively and efficiently to meet the outcome expectations of agencies with a biosecurity interest.

Maori

Our biosecurity system must respond to the needs and aspirations of Maori. Understanding of Maori interests in biosecurity – the protection, sustainability and management of taonga for present and future generations – is pivotal to any effective relationship between Maori and the biosecurity agencies. Taonga are resources highly prized by Maori - including fisheries, indigenous flora and fauna and traditional food gathering areas on land, in rivers and in the sea.

Maori hold significant economic interests that are focused on primary production (spanning agriculture, horticulture, forestry, fishing, marine farming and tourism) so their interest in robust biosecurity is similar to any other producer. Maori cultural and social values and economic interests may favour particular solutions and disallow others. Maori, for example, may have specific issues with some methods of pest control, or concerns with the management of species such as the kiore (Polynesian rat) or a particular interest in marine biosecurity. The tradition of mahinga kai (food gathering systems) is pivotal to Maori culture so the loss of wetlands, pollution of waterways, introduction of exotic species and control of pests and weeds has particularly significant cultural and economic implications for them, not always adequately appreciated by the biosecurity agencies.

Maori are concerned at the lack of understanding by non-Maori of their customs and the value of traditional knowledge in managing indigenous species. Direct involvement by Maori in biosecurity decision-making processes would inform both biosecurity agencies and the wider community of Maori specific outcomes. Local iwi need to be involved in the protection of taonga. If taonga are threatened by incursions, kaitiaki (guardians) from local iwi can assist. Biosecurity agencies must have an ongoing process of review and responsiveness to Maori.

Expectations - Maori

3. That the Chief Executive of MAF is responsible for developing a Maori responsiveness strategy for biosecurity agencies;

4. That capacity and capability is developed within the biosecurity agencies with specific training (specialist skills and knowledge) to ensure Maori are involved meaningfully;

5. That existing channels (under the Resource Management Act, Fisheries Act, District Health Boards or conservancies) are used in consulting on pest management strategies and during incursions;

6. That kaitiaki are invited to work with central government and regional councils on biosecurity matters;

7. That Maori values are explicitly considered in decision-making criteria.

The Wananga tradition - a way forward

Maori as kaitiaki (guardians) and owners of land and resources have a vested interest in protecting taonga from imported pests and diseases for future generations. Te Whare Wä nanga o Awanuiä rangi, in a marae in Whakatane, offers a three-year Bachelor of Environment Studies degree that incorporates a Maori vision of the environment, together with science. The degree focuses on practical studies, including investigation of the region - mountains, rivers, and wetlands as well as coastal, estuarine and marine environments.

Awanuiärangi has relationships with Maanaki Whenua (Landcare), Te Papa Atawhai (DoC) and various regional councils. For example, students work on Moutohora (Whale Island), a reserve administered by DoC where imported mammals (goats, sheep, rats and mice) had destroyed the plants and bird life. After 20 years of management these mammals have been eliminated and a planting programme has regenerated its landscape.

Now Moutohora is covered with vegetation (mainly pohutukawa, mahoe and kanuka forest) and the birds are returning.

Ngati Awa Research Centre
Nobel prize winner Professor Alan McDiarmid with Pouroto Ngaropo opening the new Te Whare Wananga o Awanuiarangi laboratory at Poroporo Marae in February 2003. The $450,000 science laboratory is the first built specifically for Maori.

Stakeholders’ voice

It is imperative people trust biosecurity management, confident in its decisions; currently they clearly don’t. Many submitters doubted the ability of MAF and/or MFish to make the culture shift required to deliver an end-to-end biosecurity system.

The new institutional arrangements need to recognise these concerns and ensure there is a means to provide stakeholder oversight of the full biosecurity system: from pre-border through to pest management.

The Biosecurity Council fits this role – partially. It was formed shortly after the ministerial portfolio was established in 1997 to coordinate the four government agencies and the regional councils. The Council’s mix of public servants, regional councils and stakeholders was an attempt at cohesion. The Council has guided this strategy’s development with government agencies and regional councils in order to find a way forward.

A reconstituted Biosecurity Council can continue its vital strategic role, monitoring system performance as new biosecurity measures and systems are introduced. Inevitably, today’s system will evolve as its management becomes more transparent and the needs of biosecurity change. The Biosecurity Council should be the vehicle through which stakeholders can have a voice.

The key objectives of the Biosecurity Council will be:

1. Providing independent advice to the Minister;
2. Evaluating the ongoing management of the system to ensure mechanisms work; and
3. Ensuring stakeholders have a voice in the system’s governance.

Membership of the reconstituted Biosecurity Council will be a decision for Government but an indicative list appropriate for representation is:

• Primary production;
• Maori;
• Regional councils;
• Environment;
• Health;
• Marine;
• Research;
• Transport (including ports and airports); and
• Tourism.

It would also be advisable to appoint individuals with strong strategic skills who are supported by, rather than advocating for, particular interest groups.

Partnership with regional councils

The Biosecurity Council agrees there is a need to establish tangible, ongoing and effective arrangements between central government and regional councils at a number of levels. The major issue is ensuring formal inclusion of regional councils in the strategic decisions responding to an incursion, or handling the new invader within pest management. Regional councils, together with DoC and private interests, often see themselves as the ‘victims’ of biosecurity failure, as they bear the costs of leakage across the border.

A regional council and central government forum needs to be formed to address the issues of pest management with a national perspective. The forum needs to set clear and transparent boundaries, for management of pests between those boundaries, and to facilitate a combined effort to manage pests. DoC must be part of such an arrangement.

Linking with industry

Industry’s role is critical, both as a significant funder of Crown-led activity and a major beneficiary. Industry needs to work actively in surveillance and eradication programmes.

There are considerable other points of connection for a biosecurity authority – indeed, there appear to be too many. Agencies need to look at the myriad committees, decide which ones are most important, then concentrate on making them work; generalised meetings of large groups with diffuse agendas are much less useful.

There clearly needs to be a specific vehicle that pulls together the various industry forums currently lying within the biosecurity agencies, to recognise the nature of their relationships and the need for a cooperative and clear policy environment.

Measuring performance

Biosecurity needs a full performance monitoring system - driven off high quality, published information - and discussed with stakeholders regularly. Government departments will drive its development through their statement of intent process, but ongoing evaluation is needed for daily management and ongoing monitoring.

There is some information on performance measuring in the system. For example, there is a measure identifying border leakage (it may need updating, but at least it exists) but the information is not used for higher-level decision-making. Even more worrying is the lack of activity reporting, and even basic accounting systems are unable to identify activity costs.

A public forum is needed to ensure ongoing monitoring, such as an annual review of biosecurity activity focusing on results. In its early stages, it is likely to comment on necessary developments to bring the system up to speed.

Implementing the next steps

MAF needs to take leadership of the next stage of development and the Biosecurity Council believes the Chief Executive should determine which direction to take. The Council sees its future role as one of giving independent advice and stakeholder comment. Clearly, there is a great deal to be done and the Council expects to be engaged in the process of development as it gets underway.

Expectations - Stakeholders’ voice

8. That the system encourages all New Zealanders to participate and support biosecurity;

9. That there is an annual review with external stakeholders on the performance and development of biosecurity, with an overall review in 2010;

10. That a reconstituted Biosecurity Council monitors this strategy’s implementation on behalf of stakeholders for the Minister;

11. That a central government/ regional council forum is established to address the joint issues of incursion response and pest management;

12. That appropriate links with industry are formed to address priorities and who should pay for what.

Capability gaps

The specialisation of many biosecurity activities makes them hard to replicate. For instance, New Zealand trains biosecurity detector (‘sniffer’) dogs for other countries and some of our science organisations have internationally recognised strengths in risk management – databases, applied technological and other intellectual capital. Risk management, surveillance and incursion responses require particular skills that can be applied across organisms and environments. This strategy focuses on the efficient development, astute deployment and utilisation of these specific skills to achieve the New Zealand most of us want.

Biosecurity faces increasing demands from growing risk and increased volumes of activity, at the same time as coping with high profile incursion responses. The system has been holding together, but at some cost to its core abilities. The system has not become strategic; the identification and management of risks has become increasingly reactive - while the cost escalates. The full consequences can be seen in the recent failure to contain the Painted Apple Moth incursion when it was first discovered.

The fragmentation of biosecurity activities across several agencies makes identifying overall gaps difficult. There has been no attempt, nor incentive, for agencies to assess all the gaps across the entire biosecurity system, nor determine the sequence in which they should be addressed. The system operates in isolated silos designed to address sector interests, with no overview.

Different sectors of the biosecurity system are at different stages of development. In some sectors there are critical gaps in baseline knowledge,in others capabilities are lacking (such as diagnostic and treatment tools),while some need to refine existing programmes to ensure high impact risks are effectively managed.

Gaps in the system

More than 80 gaps have been identified during the strategy and cabinet paper development process. These range from pre-border to pest management activities, affecting environmental, economic and human health outcomes. Some are simple and can be readily addressed (for example, enhanced Saltmarsh Mosquito surveillance), others are complex (for example, management of marine risks) and will take significant resources and time to resolve.

Here are some examples:

 

1. Important biosecurity data is stored in a range of information systems run by different groups. This results in gaps and duplication, inconsistency and poor accessibility of information. A coordinated information strategy is needed to ensure this information is shared;
2. A more proactive approach is needed in assessing emerging threats, to enable identification of potential pests and pathways and implementation of measures to prevent their entry, spread and establishment;
3. Effective tools are needed to implement responses to a range of pests and diseases. In some areas, such as ballast water testing and treatment, no effective tools have been developed. In other areas existing tools are under threat due to health, environmental and humanitarian concerns; for example, 1080 poison, methyl bromide for fumigation and ‘leghold’ traps for possum control. Some tools are no longer available, for example, effective anti-fouling paints;
4. There is a major knowledge gap in marine biosecurity, including information about the marine environment’s current status, high value marine ecosystems and potential pest threats (other than a few high impact species);
5. There is a range of exotic species of animals and ornamental plants held in zoos, private collections, fishponds and even suburban gardens. Some have the potential to become serious environmental pests. There is inadequate knowledge about New Zealand’s baseline – the range of species present and where they are located – yet this information is necessary to develop effective surveillance and response programmes;
6. There are unresolved regulatory issues which could delay access to imported vaccines in the event of a FMD outbreak;
7. There are significant knowledge gaps in risk analysis, for example the likelihood of different products carrying pests or viruses and their response to various treatments (such as heat). Such gaps can only be addressed by research that, since the agents are always exotic, could be carried out in research institutes abroad or under suitable containment provisions in this country;
8. Reference laboratories have coped with a three-fold increase in investigations, primarily related to indigenous biodiversity over the past five years. This trend will continue so increased capability is needed urgently; and
9. Targeted surveillance systems for exotic pests & diseases,in forests and plant nurseries.

 

Evolving systems

Technology will create many opportunities for improved management of biosecurity threats; these must be harnessed to ensure an evolving biosecurity system. Rapid improvements in x-ray and luggage tracking technology were adapted to increase border security in the past decade. New technologies (such as automation, sniffer detection, data management systems, improved profiling methods and other anti-terrorism tools) will provide improved border protection. The same will happen with surveillance and incursion response capabilities. New, targeted biological control (possibly using GM technology), improved pesticides and herbicides, and new ecological approaches will add to the pest management toolbox.

Building strategic capability

A strengthened, more strategic and strongly led biosecurity system should be better at coping with emerging threats. Attempts to forecast the future are likely to fail, so foresight and flexibility must be built into all systems. Belief that change can be addressed, and challenges met, is more important than fortune telling.

Much of the operational capability exists but there is a lack of strategic capability to look ahead, identify all the gaps and agree priorities across the system. Investment is needed to integrate the different pieces. then to close gaps through a rational and prioritised process.

New Zealand must do the most important and achievable things first, recognising that lower priorities may not be achievable in the near future.

Standardisation of process

There is a lack of consistency in most activities, sometimes for valid reason with good result; mostly due to the haphazard nature of development. Areas of significant concern are risk management methods and the approaches to surveillance and incursion response by the different agencies. Biosecurity activities have developed reactively, learning only partially from past experience. For instance, a specific team standing to one side of MAF is dealing with the Painted Apple Moth incursion – it has essentially rebuilt incursion management systems.

Beyond the obvious risks of duplication of past effort, the lack of attention to systems and standards is wasteful of scarce time and effort, with inconsistency of lower level management decisions, incursion response processes and surveillance.

The first major point of leverage is to standardise risk management,then ensure the following repeatable processes are much more consistent – diagnostics surveillance, eradication, pest management strategy development, Import Health Standards (IHS), etc.

Developing knowledge systems

The biosecurity system’s fragmentation is reflected in its underpinning knowledge and decision systems. Key information systems for decision-making do not communicate, or are incomplete. People who need access to systems do not have it. One small example of the need for a substantially better approach is the lack of an agreed list of recent incursions.

The processes for evaluating consequences and assessing external impacts (for example, global warming) are either missing, rudimentary, or operating in isolation – hardly what would be expected in such a complex system.

Expectations - Capability gaps

13. That central government is committed to maintaining a clear and effective role as overall steward of the biosecurity system;

14. That funding baselines for biosecurity are increased over the next five years specifically to close the gaps in the system;

15. That immediate funding is provided to ensure sufficient capacity and capability for rational and strategic management of the total biosecurity system;

16. That all significant hitchhiker pathways are controlled where possible;

17. That central government develops a comprehensive set of possible initiatives for increased expenditure each financial year - clearly prioritised across all agencies, sectors, environments and functions;

18. That the IHS for risk management of sea containers is fully implemented; and

19. That pre-border and border measures to reduce risks to the marine environment are being addressed as a high priority.

Science

Science is a critical element underpinning biosecurity; it can have an enormous input to managing the risks and uncertainties, and ultimately the effectiveness of any decision. It can provide key information for many questions and can help determine which questions should be asked. Identifying the right advice is the key to making good decisions so scientific input must be considered, in conjunction with public and stakeholder opinion.

Scientists from the agencies, Crown Research Institutes (CRI) and private science providers are involved in some way in virtually all aspects of biosecurity, from researching the implications of pre-border trade agreements to judging the most acceptable and effective means of eradicating pests. Scientists provide advice at many stages: during incursions, on medium to long-term pathway mitigation and on responses to eradicate or control pests.

Tensions are inevitable at times between the need for rapid decisions (with clear accountability) and the need for adequate information; tension is also likely in managing relations with commercial science providers such as the CRI. Processes are, however, just a means to an end; the goal must always be the best possible decision in a timely manner.

New Zealand's biosecurity is held in high regard internationally but the thousands of biosecurity policy and funding decisions taken every year could be improved through more effective application of scientific techniques.

The following key issues have been identified:

• Connections: the need to integrate science into biosecurity policy and decision making, not just in the implementation of incursion responses;
• Capability: the need to protect/develop science capability across the spectrum, from pre-border through to pest management, with proper funding of those involved; and
• Balance of Investment: the need to move more investment into pre-border (ie: prevention) and to develop whole-of-government priorities for spending.

It is apparent:

• A Biosecurity Research Strategy needs to contain some overall agreed medium to long-term research priorities to guide Foundation for Research, Science and Technology (FRST) and the agencies;
• Scientists should be included more actively in a wider range of decisions, not just brought in on a piecemeal basis to help with incursion responses. The ad-hoc and reactive use of science needs to be reviewed, as it risks poorer decisions and reduced science capacity;
• Work needs to be undertaken to assess the benefits of pre-border and border interventions and related research, and combined with the prioritisation work to ascertain whether a case can be made for more research funding;
• Greater emphasis is needed on developing long-term partnerships with scientists to build capability and knowledge, although cost control remains important; and
• There is a need for all parties to be open in exchanging information. Scientific information for biosecurity management is a public good and a critical component in decision-making, yet access to it varies across the spectrum.

Expectations - Science

21. That science is closely involved in the development of biosecurity strategy;

22. That the purchase of science is integrated across providers;

23. That investment in science is long term to ensure maintenance of key capabilities; and

24. That the priority for research to improve biosecurity is understood.

Federated Farmers of New Zealand (Inc.)
Despite being a major sheep producer,New Zealand is one of very few countries to have remained free from scrapie, a sheep disease with major trading ramifications. On the rare occasions when scrapie has been detected in imported sheep the animals have been slaughtered immediately,with the carcasses burnt. Infected flocks experience significant production losses,making it impossible to export breeding stock,semen,and embryos to many other countries.

Addressing priorities

The Biosecurity Council sees the need for central government to ensure significant increases in funding over the next three to five years, based on carefully justified priorities, supported by all biosecurity agencies.

There is considerable concern whether the resource allocation is optimal. Similar concerns exist over funding allocations across agencies, sectors and environments. Often money is spent on known risks and activities, in preference to recognised threats about which we know very little. This disparity may be sensible in minimising the potential damage from incursions or spread of pests and diseases; equally it possibly reflects a tendency to devote resources to areas most understood, or a tendency to repeat what has been done before.

The priority must be to ensure sufficient capacity to enable the system to function as a whole. Capacity is needed to gather information, analyse it and execute change in an orderly manner. As indicated already, some gaps are apparent.

Addressing the gaps will require a broad approach to ensure risk management is commensurate with the level of risk being faced.

Where the Government spends our money

Around $500million is spent annually on biosecurity in New Zealand, with activities undertaken by central government, regional councils, industry and private landowners. It is estimated government agencies are responsible for $304 million of this.

Other' includes assurance (1%), audit and enforcement (1%) and international (0%). Figures do not add to 100%, due to rounding

It is not clear whether this spending and activity is a good fit with the objectives of biosecurity; most stakeholders strongly believe more resources are needed. The Biosecurity Council agrees but has deliberately stopped short of offering specific recommendations on the necessary level of increase. Experience suggests decisions on overall funding levels are best taken in incremental steps rather than as a single exercise.

Integrating decisions

Lack of agreed, high-level outcomes is an obstacle. Central government biosecurity agencies need to establish priorities and be able to assess the relative contributions of different activities.

The four main central government biosecurity agencies have made concerted efforts over recent years to improve their decision-making practices, but their processes for assessing and prioritising activities are in varying stages of development with considerable inconsistency in criteria and methods. Despite the complexity of decision-making in biosecurity, information limitations can be severe, requiring over-simplification and major assumptions.

This significantly limits the scope for comparison of spending alternatives or different approaches to managing a particular risk. These problems result in inconsistent decision-making that undermines the public’s confidence. Decisions must be robust, consistent and accurately reflect relative priorities, rather than the undue influence of the assessment method chosen. Put bluntly, departments must join together to form a pan-departmental view of biosecurity priorities.

This is still a long way from being achieved – during the development of Cabinet papers to accompany this strategy, for example, officials were unable to agree the table of top priority gaps to plug.

To address these problems, the Council expects a framework for prioritising investments across both the spectrum (pre-border to pest management) and sectors (conservation, agriculture and forestry, aquatic and human health).

This framework must be sufficiently flexible to accommodate the required wide range of applications, the complexity of biosecurity decision-making, the inherent uncertainty, and the inevitable trade-offs between risk and benefit.

Benefits and costs are a key consideration, bringing together biological risk analysis with operational capability and effectiveness in assessing measures to manage the risks facing what New Zealanders value.

This field of endeavour is fraught with difficulties. Valuation of environmental and cultural effects is particularly tricky when assessing benefits and costs. Other areas of difficulty include uncertainty, society’s changing risk preferences, long-term effects resulting in discounting of major impacts far off and the impossibility of reversing some decisions. In addition, individual assessments are limited in reflecting the aggregate and cumulative risks posed by multiple pests and pathways. These complex difficulties require progressive improvements to information bases and assessment methods.

Priorities framework

The Biosecurity Council proposes a generic, integrated framework comprising an initial intervention test, followed by prioritisation of activities according to a range of criteria, including benefits and costs.

The intervention test should assess whether activities are:

• Justified & appropriate - for central government biosecurity agencies;
• Consistent - with domestic legislation & international agreements (trade, environmental & human health); and
• Mandatory - under domestic legislation or international agreements.

The proposed prioritisation criteria are:

• Technical - feasibility, suitability & probability of success;
• Practicality - logistics, resourcing, timing, opportunities & risks, past achievements & stability;
• Benefits and costs - encompassing the full range of effects across all sectors;
• Strategic - contribution to goals & key priorities, long-term benefits, synergy & coverage; and
• Acceptability - stakeholder concern, international interests, distributional considerations & risk preferences.

The criteria for benefits & costs across all sectors, should be:

• Environmental - including indigenous & valued introduced species, biological systems & biodiversity;
• Commercial -including primary production,industry &service sectors;
• Maori cultural &spiritual values;
• Human health &well -being; and
• Social - including personal property.

Expectations - Priorities

25. That there is an integrated framework for establishing whole-of-system priorities and providing greater transparency and accountability in risk management; and

26. That the criteria for assessment of benefits and costs includes the full range of effects across all sectors and in particular consequences for the environment, human health & well-being, economic production, and Maori cultural values.

Who should pay?

The Government has overall responsibility for funding biosecurity, in particular border, surveillance and incursions.

Government agencies are responsible for $304 million of spending on biosecurity; central government responsible for 90% and regional councils for the balance. Taxpayers are not entirely liable, 20% is recovered from third parties and 9% from ratepayers. Industry contributes through fees and levies. There is no clear rationale in the level of third party funding and the allocation is wildly inconsistent - prevention 40%, surveillance 24%, and response 18%. Within these general activities there is further variation. In prevention, for example, there is full cost recovery for cargo and container clearance but no private contribution to costs for aircraft and mail clearance, nor any third party contribution to the funding of research.

Inconsistent funding leads to erratic development of capability to prevent and manage risks. The European Foot-and-Mouth disease outbreak, for example, provided the spur to gain additional funding for x-ray machines and sniffer dogs – this provided some reduction in the risk of Foot-and-Mouth disease (by increasing meat interceptions) but the principal (yet unintended effect) was to reduce risks to biodiversity and plant health.

The Privy Council recently ordered MAF to repay passenger clearance charges to Freedom Air, Hamilton and Palmerston North airports. It ruled MAF's charges at regional airports were unlawful because taxpayers funded the cost at the established international airports of Wellington, Auckland and Christchurch. Charges from 1995 to June 2003 totalled $3.296m.

This ruling has implications for other regional airports.

Transparent framework needed

The Council expects central government and regional councils to apply a clear framework for determining who should pay for a particular service, and to review existing activities to ensure consistency with this framework.

The principles of funding have been dealt with over the years with clear policies espoused in different areas of government; the ground has been well trodden. Broadly speaking, it is a cascade principle: charges on exacerbators should be investigated and applied if possible; if not possible, levies on the beneficiaries should be investigated and implemented if they are practical, fairer than taxpayer funding, and capable of implementation at reasonable cost. Finally, taxpayer (in some instances, ratepayer) funding is relevant.

This cascading decision rule, if applied consistently, will ensure the funding source is the best way to ensure consistency with goals such as minimised risk, minimised costs, fairness, consistency with international obligations and ongoing improvements.

There is wide support for the development of a clear and consistent set of funding principles (based on transparency, accountability, equity and practicality) and strong support for the ‘polluter pays’ principle rather than ‘one size fits all’; many feel their sector should not have to pay more.

There is, however, moderate support for recovering the costs of increased activity at the border through charging for passenger and cargo inspection activities – except, unsurprisingly, from the tourism and transport sectors. There will also need to be a set of ongoing discussions with the primary sector about cost sharing (where relevant and fair) on activities around incursion management and surveillance.

The Biosecurity Act has punitive powers, allowing government agencies to pursue individuals and companies who breach it. Individuals may be fined up to $100,000 in addition to possible prison sentences of five years⁶; companies face maximum fines of $200,000. But enforcement is difficult, as the exacerbator must be identified and intent proven. Investigation and prosecution costs are expensive, and prosecution capacity is limited. The direct costs of an incursion are so high that no punishment reflects the potential damage to our economy and lifestyle. No culprit can be identified for any of the major recent incursions (Painted Apple Moth, Southern Saltmarsh Mosquito or Varroa) yet combined they cost the taxpayer over $150million – with much larger potential costs for primary industry.

The Crown will continue to bear substantial costs for biosecurity, as it must retain responsibility due to the complex components - the crosscutting nature of benefits, the difficulty of identifying beneficiaries and the difficulty of levies.

The Minister of Biosecurity is recommending Cabinet adopt the following ‘cascading decision rule’ for officials to develop recommendations on future funding arrangements for services for which the Government is responsible:

1. Costs should be recovered from the users of each service, or those whose actions caused the need for the service or function to be provided, where this is practical and cost-effective;
2. Otherwise the funds required should be raised through the imposition of levies on those who benefit from the provision of the service or function, where they are an identifiable individual or class of individuals and where the cost of doing so is reasonable;
3. Otherwise taxpayer funding should be used.

Expectations - Funding sources

27. That central government and regional councils are applying a clear and consistent cascading framework for determining who should pay what; and

28. That funding arrangements for all existing activities are progressively reviewed to ensure consistency with this framework.

Biosecurity Council’s first recommended steps

1. Make MAF clearly accountable for overall management of the whole biosecurity system, on behalf of all New Zealanders;

2. Put in place the necessary systems, structures and capabilities within MAF to support its role - starting with strong strategic capability;

3. Establish governance mechanisms (including a reconstituted Biosecurity Council and chief executives’ forum) to support this strategy’s implementation and monitor performance;

4. Encourage all New Zealanders to support and participate in biosecurity through a social marketing programme;

5. Identify ways to involve Maori fully in biosecurity issues and decisions, nationally and locally;

6. Identify, prioritise and review current and emerging risks– from pre-border to pest management and across aquatic and terrestrial environments;

7. Establish national leadership and coordination of pest management;

8. Recognise the contribution of science to biosecurity (strategically and operationally) and fund it properly;

9. Ensure decision-making processes take account of risks to the economy, biodiversity, taonga, human health and lifestyle in setting priorities; and

10. Increase funding over the next five years for priority areas and build organisational capability across the system.

The Biosecurity Council recommends immediate implementation of these steps, in addition to identifying and plugging the most immediate gaps.