Submission on behalf of the Avicultural Society of Tasmania (AST)
re the proposed biosecurity legislation.
The Tasmanian avicultural community appreciates the opportunity to contribute to
the biosecurity framework however I have been requested to also outline the
reprehensible manner in which the avicultural industry has been treated under 2007
changes to biosecurity legislation where there was zero consultation, stakeholders
meeting or any opportunity for the larger community to comment. Where the two
Labour ministers at that time deemed the avicultural industry a “minority group and
unworthy of consultation” despite the large number of community members engaged
in that activity.
The AST is the major avicultural body in the state of Tasmania and has been in
being since 1971 and represents the majority of bird keepers in the State on
legislative matters – among these were the Federal Exotic Bird Record Keeping
Scheme (EBRKS), was a member of the Exotic Bird Advisory Group (EBAG) and the
Victorian Non-indigenous bird management policy.
Since 2007 it has also been lobbying for a repeal of the draconian legislation passed
by DPIPWE impacting on a number of commonly kept aviary bird species pending
real community consultation.
The AST also incorporates the Tassy Finch Club – a specialist finch breeding
association that was formed in 2007 as a response to this legislation that was
imposed without any form of public consultation.
As a result of a suggestion from the current minister’s office – Mr Matthew Groom re a canvas of people involved in the industry in Tasmania it is believed that there
are around 10,000 people actively keeping and breeding birds in the State. Further
to this sales of bird related products, feeds and sundry items amount to an average
of 20% of pet retail outlets income state-wide.
The majority of the people involved with the industry are active on social media
presenting a unique opportunity to disseminate information and for consultative
purposes – something the AST has offered to do should real consultation ever be
contemplated.
During the EBAG stakeholder meeting in Canberra it was reported that the
avicultural industry in Australia employs around 2.5million people – from farmers,
seed merchants, importers, metal and timber fabricators, professional bird product
companies (eg Vetafarm, Passwells, Mavlabs, Avione to name but a few) through to
pet outlets and professional breeders.
The Legislation:
In 2007 bird keepers throughout the State awoke one morning to find they had some
of the worst legislation imposed upon them without any warning or opportunity to
prepare submissions against such draconian “laws”.
A basic run-down:
• No stakeholder’s meetings or consultation with the avicultural community of any
sort which was in direct contrast to other Mainland states.
• Specie that had been freely imported into the states for in excess of a century
without any history of establishment or feral populations suddenly found themselves
banned overnight because of the adoption of a flawed, biased biosecurity model that
no-one had had the opportunity to challenge in open debate. All states incorporate
the Bomford Model but none have sought to use it such a biased manner so
removed from real-world scenarios.
• Because of this lack of consultation many species were omitted from the list of ‘bird
known to be legally in the state’ category causing huge financial hardship for those
that had legitimately imported many such high-end exotic species in good faith.
• Because of the lack of any warning of this legislation many committed to purchase
high-end exotic species only to find that they were then prevented from legally
importing them as was possible prior to the imposition of this legislation. This once
again caused a huge financial hardship for many and festered a loathing for the way
the Department does its underhanded ‘business’ without consideration of the
people/industry it impacts upon.
• Because of the arrogant, demeaning way this legislation was prepared and
implemented (basically in secret with a model so removed from the real-world
scenario as to be simply farcical in nature) many sought other avenues for importing
certain banned species thereby creating a biosecurity issue that was avoidable IF
public consultation was undertaken at the beginning. Your average bird keeper
cannot understand why they felt the need to do what they did and why they had no
opportunity to comment before the event and acted accordingly.
• The manner of the legislation has led to a loathing and distrust for the Department
that is certainly not going to help any Biosecurity matters – all of which could have
been avoided if public consultation and stakeholder’s meetings had ever been held
at the outset as is the norm in other Mainland states. Other states have recognised
this and have engaged with the avicultural community so as to gain their positive
involvement in event of any biosecurity issue related to aviary birds – here all that
exists is alienation and zero Departmental support.
• As a result of several meetings with Minister Groom we have prepared a case for
the removal of many of the bans through the use of the possession permit route
which would allow the Department a comprehensive record of what is in the state,
who has them and what their eventual fate is – this was supported by all the
agencies we met with but rejected by the Department making us wonder whether the
prevalent attitude is to simply impose these draconian laws and pretend that they
actually “protect Tasmania’s Biodiversity” rather than to admit that this legislation is
causing more damage than the system it replaced as a result of the way it was
imposed.
The Model:
The Bomford Model is accepted as one of the premier risk-analysis models for pest
analysis and is utilised by a number of states in Australia but none have sought to
present it in such a biased manner without also including a community consultation
period.
• Species are banned on their potential pest risk yet the majority of the records refer
to 19th Century introductions the majority of which were deliberate and performed by
various acclimation societies. One would seriously question their relevance to the
current Centuries thinking!!
• Many of the exotic species were banned using just such ancient data which is
based on the introduction of wild-blood individuals from one country straight into the
wild in another country – in the US they shot to extinction their only parrot (the
Carolina parrot) and imported large numbers of wild Quakers from Argentina to
basically ‘replace them’ in the wild and this is now used to ban them from Tasmania
despite them being in the state for decades without mishap – something not lost on
the average bird keeper!! The exotic birds currently present in Australia are so
removed from those wild-blood lines as to make such comparisons extremely
tenuous. Add to this the number of colour mutations that exist in these exotic species
certainly is suggestive of a gene pool in decline. It is also relevant to note that these
mutations do not even exist outside of aviaries!
• That species that have passed strict quarantine requirements for entry into
Australia are banned from entry to Tasmania because of the inane comparisons
outlined in the last paragraph made to these species feral history regardless of how
that eventuated or how far removed from wild blood line the proposed imports are –
again putting the state at odds with national biosecurity legislation.
• Even the Bomford Model cites that habituation, domestication and required
propagule pressure are important aspects of deciding a species pest potential yet
when the avicultural community met with wildlife and asked why these mitigating
factors were not an important part of any initial considerations when banning
species, we were told, and I quote, “that they did not have to consider such issues”.
Hardly likely to instil any sense of fairness or thoroughness into any biosecurity
matter. For the record these are strong reasons why other states have not banned
species that they consider may be potential biosecurity threats at some stage – this
was certainly the case in Victoria where we were able to meet and engage with the
proponents of such legislation which lead to positive engagement and a lasting
desire to support biosecurity issues as they arose in that state. The exact opposite of
what the heavy-handed approach here has caused with all that that entails for
biosecurity matters.
• When questioned initially about the draconian nonsensical nature of this current
legislation we were told that it is based around the potential advent of ‘some hitherto
unknown climatic disaster’ that may create an environment conducive to the
establishment of these birds in the wild. Banning species that have had zero impact
on Tasmania’s biodiversity on this tenuous “thread” we feel is akin to legislating for
all Hobartians to relocate above bend 6 on Mount Nelson in the event of potential
global warming associated sea rises!!
• Your average bird keeper is also at odds to explain why the birds that they have
held and bred for as long as they can remember were suddenly banned along
biosecurity lines when the hypocrisy of other species omission leaves them
flabbergasted.
The Rock pigeon or its derivation the domestic pigeon is considered as a pest of
global proportions yet was excluded from this witch-hunt that saw over 30 commonly
held specie banned. If fairness and thoroughness is to be shown then surely this
carrier of zoonoses, spreader of bacterial infections, global coloniser extraordinaire
and degrader or public monuments should be public enemy number one? Yet it is
excluded from any risk-analysis profiling and we wish to know why this is so?
Especially in light of the fact that they have been regularly imported from overseas
(bringing into question the wild blood lines debate) and once imported into Tasmania
(without any form of entry permit we stress!!) they are released into the environment.
Surely extreme double standards? The same is true for the Mallard duck which has
had an extremely deleterious effect on the Pacific Black Duck population in New
Zealand but can be imported into Tasmania without permit and released into any
waterway the importer desires!!
This is why the average breeder sees the 2007 import bans as totally without
foundation or sense when applied to birds freely held in other Eastern seaboard
states. They consider these people have attacked them as a ‘soft target’ and left the
serious potential biosecurity problems in the too hard basket. Who can blame them
for thinking thus.
• Perhaps it is also prudent to state that the Tasmanian bush is alive with mid-order
birds of prey, large aggressive wattle & miner birds, native cats & tigers not to
mention feral cats which are completely absent from some areas where feral bird
populations have established. Again completely ignored in the Tasmanian ‘model’ as
a mitigating factor!
The Avicultural Community:
Residing as it does in one of the harshest environments for keeping and breeding
birds that is in Australia there exists within its ranks a level of expertise that is
unrivalled throughout Australia. Many within that community have always assisted
the Department with any bird/aviary related problem or question.
However, the imposition of the existing import bans and attempts to impose a
seriously flawed licensing system upon them has sent them a strong message.
Throughout this episode the one fact that has shone through is that the Department
knows little about the avicultural industry, the species involved in it and the quality of
life that it imparts on those engaged in it. We were told in recent correspondence that
there were problems with the repeal of any species because “This approach may be
criticised by key stakeholders, including the TFGA and the Tasmanian Conservation
Trust due to concerns over biosecurity.” The obvious reply is how would anyone
know given there have been no stakeholder meeting or organised discussions of any
sort!!
We would ask when is someone going to allow fairness and equality for Tasmanian
aviculturists to present a case for species that have posed no threat to Tasmania’s
Biosecurity for in excess of a century that as a result of slanted biased models find
themselves banned?
In regards captive species management, the success of Tasmanian aviculturists with
the breeding of the endangered Swift parrot is well documented. This lead to a
rewriting of the husbandry manual in regards this species and its place is safe at
least in aviculture because of this.
Given the well reported problems with the Orange-Bellied parrot breeding program
perhaps the involvement of avicultural community is more to be encouraged than
discouraged through the actions of those that ’developed’ this repugnant legislation.
Conclusion:
The average Tasmanian bird keeper has no wish to endanger Tasmania’s
biodiversity nor, in recorded history has it ever been responsible for the
establishment of feral species in the State. Even the hype concerning the Rainbow
lorikeet was dispelled as being a natural range extension by a Departmental Wildlife
scientist on national TV at the October 2015 Threatened Species day coverage. Still,
not unexpected as the Wood duck is also another self-introduced species.
Throughout the past 9 years we have sought to engage with the Department and to
also alert them to the problem they have caused with the way they imposed this
legislation. To that end they have always hidden behind their “extreme” pest rating
as a guide for disallowing entry of commonly kept species prior to the 2007 embargo.
Wild blood individuals may be an extreme risk but birds closeted for decades and
longer in captivity surely cannot be the even considered an extreme risk. Only in
Tasmania it appears where mitigating factors can be ignored in favour of a biased
view that would not hold up to public scrutiny IF that was ever allowed.
Might we suggest that if you are really serious about protecting Tasmania’s’
biodiversity this is an example of the worst possible way of doing so – apply ancient
data to current situations and ignore any mitigating factors ‘because you can’ and
then refuse to give the industry most affected by it any opportunity to object to it.
Given the way this legislation was imposed we seriously doubt that it has
constitutional legality and are keen to explore this avenue given the Departments’
steadfast refusal to amend any of the species requested for return to the legal import
list.
Again we thank you for the opportunity to address the proposed Biosecurity
legislation and for the opportunity presented for public comment – something denied
to the public of Tasmania re the 2007 import bans and associated legislation.
Hopefully our experience will serve as a how not to treat the community and that you
will continue to engage with all Tasmanians to ensure our unique island life is
protected by involving us all in the decisions made and allowing us to challenge
those aspects of it we believe you might have gotten wrong. Also please remember
that the quality of life in Tasmania is to many of us the freedom to engage in our
hobbies or at least have the platform to defend them from the sort of ‘convenient
science’ that was foisted upon the community in 2007.
This 2007 legislation has caused some to leave the state and for many more not to
choose to relocate here which is a sad yet totally avoidable scenario.
Marcus Pollard
Spokesperson for the AST’s Import Bans Committee.