Submission to the Rural and Regional Affairs and Transport References Committee re red imported fire ants in Australia.
Dr Pam Swepson
30th October 2023
My involvement with the National Red Imported Fire Ant Eradication Program
An officer in the Queensland Department of Primary Industries since 1987, in February 2001 I was seconded to the emergency response team in the week fire ants were first identified in Brisbane. My role was to liaise with communities and industries already affected by the pest. When the National Red Imported Fire Ant Eradication Program (NRIFAEP) was created in August 2001, I became the program’s Community Engagement Manager, then Senior Policy Officer – responsible for drafting program progress reports for the public and national funders. I based my reports on operational managers’ regular reports. I soon became aware that statistics in final reports never added up and serious issues threatening the program were not being reported.
In 2002 I raised my concerns with the program Director and the Director-General. In March 2003 I made a public interest disclosure to the Queensland Crime and Misconduct Commission (CMC) that ‘that the public, the Parliament, the Premier, the Governor and the Commonwealth and other States and Territories are being misled by reports that over-state the success of the program by omitting to report serious issues that continue to threaten the success of the program.’ I listed six serious issues. The CMC changed the terms of my disclosure to the program director misreporting to the Director-General, took three years to investigate it to find no substance to it. During that time, the Premier claimed he could not intervene into the program while it was being investigated: consequently, the mis-reporting continued and serious issues threatening the program have never been addressed. I escaped the Department’s vicious campaign of reprisal, aimed at retrenching me, by accepting a senior position in the private sector in April 2005.
When I retired in 2015 the program was still mis-reporting. I thought if I did not tell the public the truth, who would? I went from being a whistleblower to an activist. I up-dated my detailed knowledge of the beginning of the program by accessing all subsequent program reports and reviews and commenced posting blogs about the truth of the program on my website. www.swepson.com.au My evidence here is based on that work.
Term of reference: An evaluation of funding provided for the current or any proposed fire ant response plans.
The national funding formula for addressing incursions of invasive species – 100% of funding for an eradication program, in the national interest, but none for a State or Territory to contain and suppress an infestation within their borders, also in the national interest, creates an incentive for States and Territories to mount unscientific eradication program to access national funding. This is the case with the National Red Imported Fire Ant Eradication Program.
In 2001, international and national scientists said the two incursions of red imported fire ants in Brisbane were too entrenched to eradicate and recommended tightly containing and suppressing the infestations with systematic aerial baiting. Knowing the Queensland government would have to pay 100% of the costs of a containment program but only 10% of the costs of an eradication program, at a time when Queensland’s unemployment rate was over 8%, the Queensland government, with the support of the National Fire Ant Consultative Committee, announced an eradication program to create hundreds of jobs for unskilled workers. Chaotic management and an unsuitable workforce have resulted in high staff turnover and a boon for recruitment agencies. This situation continues.
Recommendation: National funding be made available for scientifically assessed eradication or containment programs of invasive species, both in the national interest.
Recommendation: Continued funding for programs be premised on evidence of progress and truthful reporting. This has never been the case with the National Red Imported Fire Ant Eradication Program.
The national program is oversighted by a national Consultative /Steering Committee, managed by the Australian Department of Agriculture and responsible to the Agriculture Ministerial Council (AGMIN).
A milestone set by AGMIN for the NRIFAEP in 2001 was a functioning information system to collect and report reliable and consistent performance data. It has never had one.
The first independent scientific review of the program in 2002 was concerned by the program’s lack of any sense of urgency, could not decide if the eradication attempt would be successful because the program did not have data on what areas had been treated or not and with what, listed many problems, made 23 recommendations and said if the ants were not virtually eradicated by 2004, the program should revert to one of containment.
Consultative Committee reported to AGMIN in April 2003 that the review team believed eradication was possible and the program had noted and addressed most of its issues.
In 2002 I reported to the Program Director and in 2003 I reported to the Director-General that the program did not have a functioning information system and was not reporting serious issues threatening the program. In March 2003 I made a public interest disclosure to the Queensland Crime and Misconduct Commission that the program was not reporting serious issues threatening the program to the public and national funders. The CMC changed the terms of my disclosure and found no substance to it. The misreporting and the serious issues continued.
In October 2003, the program auditor reported, ‘The scarcity of performance measures against outcomes prevents a more objective evaluation of operational efficiency…. (with regard to) indicators of program and function area efficiency, there was no measure of respective effort or cost associated with key outcomes.’ Consultative Committee reported to AGMIN in April 2004 that ‘progress towards eradication to date has been excellent.’
The second science review team in August 2004 was concerned the Director was planning to reduce the number of treatments the area received each year and were surprised by the Director’s claim that the program was killing 99.4% of nests when they could see fire ants surviving near ‘ground zero’ that had been heavily treated. They too complained about the program’s lack of data. They said, ‘It is not clear what properties have been surveyed and not treated or treated and not surveyed (and) we would like clarification on these activities.’
In April 2005 Consultative Committee reported to AGMIN that the over-riding comments of the review were very positive, it drew attention to a number of areas of concerns and made 26 recommendations but that progress towards eradication had been excellent.
By June 2006 the third science review team could see that fire ants were making a resurgence: properties had become re-infested and infestations had been detected outside the treatment area. They said the treatment program had been ‘poor and ineffective’ and recommended starting the program again and doing what was recommended in 2001: treating the entire infestation (approximately 50,000ha) by air, six to nine times each year for two-to-three years at the cost of approximately $70-100m. They said if 40 new inliers and 40 new outliers were detected over the next 5 years, there was no hope of eradication.
In April 2006, Consultative Committee reported to AGMIN that only 6,000ha of the 72,000ha had been treated during 2005-6, and only twice instead of three times. But progress towards eradication had been excellent, large areas were now nominally free of fire ant infestation, the program was removing movement controls from large parts of the restricted area and the few remaining infestation were just the tail of the infestation.
In November 2006 Consultative Committee reported to AGMIN that the program was making satisfactory progress against agreed milestones and remained positive about the chances of eradication but did report that the program was at a critical stage: it was not clear if eradication could be achieved ‘with existing resources.’ This was the start of the program blaming poor performance on funding issues. The science review team categorically rejected claims that program failures were due to funding issues and squarely blamed management decisions.
In April 2007, the Consultative Committee reported to AGMIN it remained positive about the chances of eradications – with additional funding.
By 2008 the infestation was so huge the program could not fully treat it and computer modelling showed that the rate of detection was less than the rate of spread. Nevertheless, Consultative Committee reported to AGMIN that eradication could still be achieved with existing methods and the bulk of the original infestation had been eradicated. AGMIN ordered another review.
In October 2009, the fourth scientific review of the program was alarmed that the Fire Ant Restricted Area was at ‘an all-time high’ of 93,000ha and said ‘Current surveillance methods are inadequate for defining the limits. Treatment methods are questionable. Fire ants cannot be eradicated using current techniques. Revert to containment and suppression for 18-24 months.’ And they were sceptical about the program’s proposal to use remote sensing surveillance technology to detect fire ant nests. They said fire ants would spread faster than the technology could find them. In April 2010 Consultative Committee told AGMIN they ‘believed that it was premature to cease the pursuit of eradication and proposed that the program be one of containment with a view to eradication’ and did not commission another independent scientific review until 2015.
In April 2011 AGMIN endorsed a program of suppression and containment for 18-24 months but requested the results of trials of the remote-sensing surveillance technology. Trials of the technology between 2012-15 identified thousands of rocks and cow pats as nests, found just 38 nests and missed actual nests.
In 2013, the auditor said program reports were just ‘narratives’ that did not report against a set of specific, measurable and fit-for-purpose performance indicators of key aspects of the program and did not provide trend analyses, making it difficult for the oversight committees to track the progress of the Program, or any robust cost-benefit/return on investment analysis to enable the oversight committees to assess the benefits of any program initiatives and to decide if they should proceed.
The auditor was concerned that ‘without complete, clear and accurate information to support decision making, governance committees may be unable to provide appropriate oversight and guidance to the program as required, leading to an increased risk of inappropriate decisions being made, or undue delays in the decision-making process or difficulties in being able to critically examine the performance of the program.’ And further ‘without fit-for-purpose performance measures and target benefits, including appropriate tracking of project benefits to realisation, there is a risk that the expected value of a project may not be achieved or that the program may be unable to demonstrate due care has been taken in utilising public money’ Consultative Committee did not commission another audit of the program until 2019.
In 2015, the independent review of Biosecurity Queensland, the agency implementing the National Red Imported Fire Ant Eradication Program, noted that national funding arrangements do not support good financial decision making and government funds are always limited, but that Biosecurity Queensland creates problems for itself because it cannot mount credible cases for on-going funding because it does not collect performance data and analyse it to show how it has and will use funds and staffing to best effect.
In March 2017 the Queensland Audit Office reported that Biosecurity Queensland could not report on program effectiveness or efficiency because it did not have a functioning information system and did not collect data on specific, measurable performance indicators.
In December 2018, the program’s Risk Management Sub-committee said the program’s lack of any accurate performance data, poor operations and poor governance by the oversight committee posed extreme and long-standing risks to the program.
In 2019, the auditor noted the program’s lack of any outcome focussed performance indicators and the lack of an information system to provide data to support decision making.
The auditor said while there had been major changes to the program, Consultative Committee had not produced a long-term plan and did not have a set of outcomes focussed performance indicators, because the program did not have a functioning information system and did not collect reliable performance data. He recommended Consultative Committee start acting like a Board of Management and manage the budget short-fall.
In July 2023 the Queensland Audit Office said expert advice on the feasibility of eradicating the fire ants was varied and questioned the ability of the program’s information system to collect data on specific, measurable program performance indicators.
Term of reference: the effectiveness of eradication efforts and the spread of fire ants.
Without a functioning information system the NRIFAEP has no data to support any claims it has eradicated any areas of infestations or contained or slowed its spread.
But in terms of dollars and hectares:
The first National Red Imported Fire Ant Eradication Program, between 2001-2016 spent approximately $400m of public money and the infestation blew out from 40,000ha to approximately 400,000ha – given the boundary of the infestation has never been defined.
The second National Red Imported Fire Ant Eradication Program, planned for 2017-27. exhausted its $411.4m budget by 2022 while the infestation blew out to approximately 600,000ha – again given the boundary has never been defined.
Despite the program spending ~$1b of public money, fire ants now infest an area of eastern Australia, of approximately 800,000ha, that takes in the Sunshine Coast in the north, the islands in Moreton Bay in the east, Toowoomba on the Range in the west and highly likely into northern New South Wales in the south.
Term of reference: An assessment of the current and any proposed fire ant response plans for achieving the eradication of red imported fire ants.
Two unscientific fire ant eradication programs from 2001 to 2023, at the expense of a scientifically advised, cheaper and more effective fire ant containment and suppression program, have arguably done more harm than good. A third eradication program, 2024-28, is likely to do the same.
The scientific foundations of any pest control program are:
Failure to control human-assisted movement of fire ants – the main cause of spread.
In 2001 the Queensland Department of Primary Industries had authority under the Plant Protection Act to declare a quarantine area around a fire ant infestation and to control the movement of high-risk materials out of infested areas. Fearing a containment program would suggest Queensland was not confident it could eradicate the pest, and consequently threaten funding, and fearing a back-lash from industry, the Queensland Government allowed residents and businesses within the Fire Ant Restricted Areas to manage their own risk of spreading fire ants.
At the beginning of the program, approximately twenty biosecurity worked with community-minded high-risk enterprises to develop Approved Risk Management Plans and audit those plans. But during a time of massive property development in south-east Queensland, the inspectors could not identify all the high-risk businesses operating in an ever-expanding area. The program abandoned the use of Approved Risk Management Plans, downgraded its team of biosecurity inspectors and dumped the responsibility for containing the movement of fire ants onto industry and the public.
The Queensland Biosecurity Act 2014 imposes a General Biosecurity Obligation on all Queenslanders to take all reasonable precautions to not spread fire ants. Industry representatives at a program Stakeholder Forum in May 2018 said they were happy to accept their General Biosecurity Obligation if Biosecurity Queensland accepted its own by:
When the program was audited again in 2019, the auditor noted that the Queensland Biosecurity Act 2014 provides regulations to control the movement of fire ant carriers and penalty infringements notices for non-compliance. Consequently, he was critical of the fact, with the infestation then covering 600,000ha, the program had only 13 compliance officers and 5 vacancies. He said the program needed to keep compliance staffing at funded levels to meet compliance check targets.
With no estimation of the number of high-risk enterprises operating inside the program’s 600,000ha operational area, the reviewer noted that in 2018-19, the program conducted only 912 compliance checks on the transport of fire ant carries to outside the operational area, which was at least up from the just 534 checks conducted in 2017-18. The auditor found 30% of cases found non-compliant were not resolved within a month. Staff told the reviewer that most non-compliance was minor and not a significant threat. The auditor said that attitude was unacceptable. The auditor also noted, that for the first time, three infringement notices were finalised in November 2018 but, as yet, no offender had been prosecuted for non-compliance.
He said the program’s response to regulating the movement of fire ant carriers was inadequate and failed to understand the role of compliance inspections and the use of penalty infringement notices to make it clear that not meeting regulations and weakening controls is not acceptable and recommended the use of penalty infringement notices and prosecution provisions to improve compliance with movement controls.
The auditor also noted what had been apparent from the beginning: fire ants are attracted to land being cleared for the development of new suburbs and transport corridors in south-east Queensland. He made a priority recommendation for the program to develop regulations to impose costs on those responsible for creating suitable fire ant habitation.
The auditor was also concerned about the transport of fire ant friendly materials across the program’s operational boundary, including interstate, potentially enlarging the area of infestation and recommended the program introduce regulations requiring compliance officers inspect loads of fire ant carriers destined to cross operational boundaries, at their place of origin, and impose a levy to cover that compliance cost.
The auditor noted the program acknowledged the risk human-assisted movement created for infesting and/or re-infesting areas and was in the process of reviewing its biosecurity zones and movement controls but had not completed that work. The auditor recommended they complete that work urgently and Consultative Committee agreed to further investigate regulations to impose costs on those creating fire ant habitat, and to inspect loads of fire ant carriers crossing the operational area boundary. I do not know if that investigation has been finalised or reported.
In December 2020, CSIRO said the program’s movement control advice was not consistent with the Regulation and there was a worrying non-compliance with the Regulation in Queensland. In November 2020 the New South Wales government announced it would no longer accept Queensland issued interstate certification of fire ant free potted plants. In June 2021 the Victorian government made the same announcement.
It can be argued that Consultative Committees, by persistently approving an unscientific eradication program, at the expense of a scientifically advised containment program in an area of property development that was creating massive habitat for fire ants, have done more harm than good: allowing the infestation to become so bad it now threatens most of the country. I believe all Consultative Committees from 2001 to now need to be held to account.
What to do next? A professionally managed fire ant management plan implemented by local councils.
Do not allow Biosecurity Queensland to manage any future fire ant program.
In 2001, the Queensland government was criticised for using national funding to create a jobs program for 400 unskilled workers.
In 2005, the program auditor said the workforce was difficult and costly to manage because the recruitment process did not select the most suitable candidates. Consequently, the efficiency of the program was compromised by poor attendance and a high rate of disciplinary incidents – resulting in varying rates of effort and quality across the program.
For over two decades, the NRIFAEP has created thousands of jobs for unskilled workers with no background checks and the latest proposal to employ another 350 unskilled workers is more of the same.
The National Red Imported Fire Ant Eradication Program, managed by Biosecurity Queensland and oversighted by a national oversight committee, has been a magnificent success in creating a jobs program, a boon to recruitment agencies, bait suppliers, and helicopter contractors but an utter failure at either eradicating or containing any infestation of one of the world’s worst invasive species because of poor governance, poor science and poor procedures.
Poor governance
Most of the 2019 audit of the program related to the Steering Committee appointed in 2017. The reviewer said for a program that had been operating for nineteen years, the deficiencies were astounding and the performance of the oversight committee appalling.
The program lacked outcome focussed performance indicators – difficult to achieve without a functioning information system able to collect reliable and consistent performance data.
The oversight committee did not meet frequently enough or long enough to assess progress with actions.
The committee lacked expertise in governance, finance, communication, information technology and technical skills.
The Committee was too close to the program and needed to act like a Board of management to manage the budget shortfall, progress regulatory reform, consider the costs if remote sensing surveillance or reduction in treatments were not effective and consider the cost of permitting the public to self-treat.
Poor science
A review of the program’s science by CSIRO in 2020 said the program’s scientific principles were a mish-mash of poorly referenced biological details and management actions which have failed to respond to a major change in the fire ant population.
When first detected, the infestation was dominated by the polygyne type of fire ant which spreads relatively slowly as young queens build their nests close to their birth nest to create a slow spreading, dense infestation. That population has reduced over time and the program’s Scientific Advisory Group claims that as evidence of the program’s success. However, the polygyne type has been replaced by the monogyne type where young queens fly many kilometers from their birth nest to create their own and create wide-spread, low density infestations. CSIRO says this creates significant challenges for the program:
Poor procedures
In 2019, the program’s risk management subcommittee listed the program’s procedural risks:
What to do next?
Local councils with Invasive Pest Management Plans or Biosecurity Plans and licensed pest management companies were originally intended to be part of the program. Meetings were held with industry representatives and a representative from Brisbane City Council attended fire ant program management meetings. The Queensland Government chose not to involve them to keep control of the national funding.
‘Managing Imported Fire Ants in Urban Areas’, authored by Professor Bart Drees and Mr Charles Barr from Texas A&M, who both inspected the fire ant infestation in Brisbane in 2001, list the essentials of a fire ant management program.
2 Hold national over-sight committees of any future fire ant program to account for accurate and truthful reporting against performance indicators to AGMIN and the public.
Term of reference: The expected costs and impact if red imported fire ants are able to spread across Australia, on human health, social amenity, agriculture, the environment, infrastructure and regional workers.
The 2015-16 science review was unable to conduct a cost benefit analysis of continuing with an eradication attempt or reverting to a containment program because the program has no performance data. That remains the case.
The costs to human health, social amenity, agriculture, the environment, infrastructure and regional workers in the USA, which does impose quarantine restrictions on the movement of fire ant carriers, are huge. Two failed eradication attempts that have not effectively detected, treated or contained the spread of fire ant are likely to make those costs in Australia far worse.
Thank you for the opportunity to make this submission. If I can assist the inquiry further, I would be pleased to do so.