A letter from one of our members - use parts of this to write your
I am writing to express my concerns about how the Department of Agriculture
and Water Resources has failed to adequately consult with community
stakeholders in its important Vegetable Seeds Policy Review. Its
methodology lacks transparency, due democratic process, and consultation
with consumers and grassroots interest groups.
The first stage of the Vegetable Seeds Policy Review (Apiaceae
family) was conducted with little input from the general Australian
public. The draft was released on 12 September 20117 via departmental
website and emailed to a closed list of people who had pre-registered to
receive updates. It remained open for a 60 day “public consultation”
period before being closed for commentary on 13 November 2017.
It should not surprise you to hear that regular members of the
public are not in the habit of cruising your department’s website for
boffin documents. It can only be presumed that consultation was
The second stage of the Vegetable Seeds Policy Review
(Curcurbitaceous family) was conducted in the same vain. Its’ draft was
released on 6 December 20117 and closed on 19 February 2018.
The Brassicaceous family review is scheduled to close for
commentary on 19 April 2018, and the Solanaceae family schedule remains
‘To Be Advised’.
Keen gardeners, such as myself, were dismayed to hear about this
project through the grapevine of seed savers, organic gardeners, and
small family-owned seed suppliers. We are concerned about the potential
impacts on our activities and livelihoods.
I could not locate copies of the draft documents for past Apiaceae
or Curcurbitaceous reviews on your departmental website. These documents
are not displayed clearly for public reference. It is rumoured that the
following changes will be implemented:
- The cucurbit seed supply in Australia
(pumpkins, squash, watermelon, rockmelon, zucchini, cucumber) will
require increased mandatory testing. The costs of this will not be
borne by the government but will be passed onto seed supply
companies and consumers.
- The Department of Agriculture requires
additional systemic fungicide treatment on all rockmelon and
honeydew seed. But has failed to specify to the Australian Organic
Seed industry bodies which organic fungal treatments, if any, will
be considered adequate.
- An anti-competitive marketplace is being
promoted where heirloom, non-hybrid (F1) and organic seed providers
are placed at even further disadvantage compared to multinational
behemoths and large retailers.
- Farmers Rights and Consumer Choices are
being eroded. The diversity of seeds available to consumers will be
greatly diminished. This curtailment is driven by cost cutting. It
is cheaper to sacrifice consumer options than to staff on-shore
quarantine services to test for the actual presence of disease at
point of entry.
The Vegetable Seed Review needs to be redesigned and timeframes
reconsidered. A public awareness campaign should be rolled out so that
people who will be impacted by are able to engage and provide
As a minimum all aspects of the review should be re-opened for
commentary and following types of associations should be notified:
Organic Certification providers; market garden organisations; heirloom
seed retailers; Garden Clubs of Australia; Seeds Saver Networks, and
national gardening magazines.
The terms of reference of the review should be expanded to reflect
the following objectives for Australian agriculture:
- Defend Farmers Rights and Food
Australia has seen an increase in the number of grassroots food
movements in recent year such as school gardens, community gardens,
farmer’s markets, cooperatives and home producers. This upsurge has
occurred for many reasons including the desire:
- To avoid unnecessary or artificial
- To reduce environmental impacts of food
miles, packaging or water use;
- To re-localise community relationships;
- For increased ethnic and cultural
diversity and associated food trends; and
- To pursue healthy lifestyles and leisure
Departmental policy should demonstrate how it safeguards the
rights of Australian citizens to grow their own food and control their
food preferences wherever possible. For many home food producers this
means having access to a wide variety of heirloom, non-hybrid and non-GMO
These changes have favourable outcomes for Australian society.
However, it increases the need for the Department to consult widely with
producers and consumers. Grassroots stakeholders should be notified and
encouraged to participate at a national level in making decisions
related to the conservation and sustainable use of plant genetic
- Respect consumer choices.
Department of Agriculture policies should reflect the wide
spectrum of consumer preferences including organic seed providers and
farming practices. Policies should demonstrably attempt to incorporate
consumer preferences into its regimes.
Any changes to mandatory requirements should not unduly reduce the
range options available to consumers including open pollinated organic
seed supply. If there is a requirement, the department should clearly
demonstrate why this is required and withdraw restrictions as soon as the
- Encourage small-to-medium Australian
Many seed importers are small-to-medium Australia owned
businesses. The Department should assist them to easily maintain
accreditations. If a policy recommendation is concluded, the Department
should detail clear and appropriate courses of action for conventional or
The Vegetable Seed Policy Review proposes a requirement for
mandatory broad-spectrum systemic fungicidal treatment for seeds
of Brassica oleracea, Brassica rapa, Eruca vesicaria
and Raphanus sativus. Therefore, the review should also specify what
it would consider to be acceptable organic fungicidal treatment
alternatives for each category of vegetable seed.
Australian owned seed companies already face significant barriers
to entry and operation in the marketplace. Forcing Australian businesses
to absorb expenses for additional testing or quarantine services would be
anti-competitive. In most cases, it should not be incumbent on the
importer to provide the department with technical or trial data
- Adequately fund Australia’s biosecurity
In the CSIRO report on Australia’s Biosecurity Future (2014), Dr
Fisk identified that “an investment in biosecurity is just that an
investment, and not a cost.” I wholeheartedly concur with this statement
and oppose sub-optimal approaches to risk management such as:
- quarantine cost cutting;
- undue curtailment of consumer choice;
- pushing national costs onto Australian
- short-sighted overreliance on overseas
Failure to invest in nationally coordinated quarantine services is
a high-risk venture! Australia must enhance its onshore quarantine
service facilities. Inspecting seed and testing seedlings for viruses and
other diseases is proven technology. Cost cutting and job losses in
Quarantine must be reversed if we are to protect Australia’s biosecurity,
our diverse agricultural industries, and our food sovereignty.
Thank you for your time.
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