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Dear Valued Custommers, It has been brought to our attention that the Tasmanian Department of Primary Industries and Water (DPIW) is proposing to introduce new seed importation regulations (IR) into this state. Currently it is not illegal to import seeds into Tasmania nor is there a fee charged at the federal or state level. This new IR proposal will require. All importers of seed: - To submit to the assessment protocols which are currently confined to large-scale agricultural and horticultural businesses.
- To have their seed imports assessed regardless of whether they have been already assessed and passed at the federal level.
- To pay a fee for each item assessed.
DPIW says their new proposal will enhance biosecurity for Tasmania but there is no compelling argument for this claim. Currently all Australian states accept the federal seed importation IR as their biosecurity standard and they don't have in place addition blanket seed assessments at the local level, as Tasmania is proposing to do. These are simply judged as too expensive and disruptive and don't produce a discernable net gain in biosecurity. By seeking to put in place additional import requirements DPIW will take Tasmania out of step with all other Australian jurisdictions and we will be the poorer for it. Â Some of the most concerning negative impacts are as follows: Some specialist nurseries, like ours, will be put at competitive disadvantage to our mainland counterparts and may not be able to continue to trade. The gardening public might not have the same choice of variety of vegetable and flower plants and seeds available to them as citizens in other states. Or they may have to pay more for them. Organizations like seed-savers co-operatives, specialist gardening groups, as well as individual members of international gardening clubs will find it harder to import seeds and be faced with additional costs. Small, specialist mail-order nurseries will lose market share because in the face of these changes they are more vulnerable than large scale, mass production businesses. We are not opposed to good biosecurity regulations but this proposal is ill conceived, heavy-handed and poorly co-ordinated. We urge you to play your small part in stopping them. We recommend you to email or write or phone the Head of the Working Group for this proposal to voice your disapproval and seek further information and also to ask to be invited to comment on the draft regulations. | Â | Â Cindy Hanson, Department of Primary Industries and Water Mt Pleasant Laboratories, | We all have a right to have our say on this issue so please if you require any further background don't hesitate to call Marcus Harvey, "Hill View Rare Plants" on (03) 6224-0770 or email on
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. Kind Regards,  Marcus Harvey BACKGROUND PAPER AND TACTICS ON PROPOSAL FOR SEED IMPORTATION IMPORT REGULATIONS I have spoken to many people over the past week, including David Llewellyn's chief advisor, Simon Boughey, and this is what I have gleaned. PLEASE READ THIS AND KEEP IT. It also outlines my tactics in approaching this proposal.  Could you please get back to me if you have a problem with this? And can I suggest that you use it to focus some of your thinking regarding your questions to DPIW and the discussion points you will raise?  1/ It seems there is a prevailing concern about the amount and nature of plant product coming into the state - they have picked this up because of a new x-ray scanner that they have at the mail sorting office in Launceston.  2/They are concerned about this because it is perceived that it could be a threat to Tasmania's current disease free status and its GM free status.  3/They are also concerned because they see this as "unregulated", in particular, interstate product, a sample revealed some unclean product as well. They have a fixation on verification of product because that ticks the box for good biosecurity standards. I am sure that they would like to extend the sort of documentation that currently applies to bulk seed importers to this situation.  4/DPIW has noted that there is already provision in the Tasmanian Quarantine Plant Manual to do this. There are general references to documentation requirements for seed imports in this manual. While these appear to relate directly to bulk seed imports there is no mention of small lot importers nor exemptions for this group.  5/This documentation requirement has never enforced against small seed lot importers by AQIS Tasmania because their other boss, Biosecurity Australia, doesn't require it.  6/ DPIW will want to make their IR proposal as easy to administrate as they can so they will want to go as close to a "one size fits all approach" . This will enable them to catch as many imports in their net as possible. This makes their proposal look more attractive because it appears effective and cost neutral.  7/ It is up to us to force them to break down their position and get them to acknowledge that thei problem isn't as big as they are trying to make out.  8/ That is why it is very important from the start, to insist that they accept the current IR established by Biosecurity Australia and underpinned by the Permitted Plant List as Tasmania's biosecurity standard for overseas imports that have been quarantine passed at the national border.  9/If we can achieve the above, and there are no good arguments against this, we will have managed to get some clear air into the discussion so we can talk about the real problem areas i.e interstate imports and the regulations pertaining to that acitvity. It will also stop all the un-necessary flapping about in trying to find solutions to an major area that is already well and truely adequately covered |