Threat Abatement Plan for Predation by the European Red Fox
In ForceCTH
Jurisdiction
Commonwealth
Collection
legislative instrument
Plain English Summary
6/10 complexity
This Threat Abatement Plan sets a national framework under the EPBC Act to guide research, control and monitoring to reduce predation by European red foxes on native species. It lists five objectives and 20 actions (prevention/eradication on islands; priority regional control; improved knowledge; better control methods; stakeholder awareness) and applies to Commonwealth land and to cooperative work with states, territories, landholders and community groups. Implementation requires stakeholders to provide resources and carries ongoing costs (eg aerial baiting ~ $1.3m per 35,000 km2; exclusion fencing up to $10,000/km).
This instrument is a Threat Abatement Plan (TAP) titled Threat abatement plan for predation by the European red fox (DEWHA 2008). It was made under the earlier Endangered Species Protection Act 1992 (s 33) and continued in force under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) (see cover page and 1 Introduction). The TAP is a non‑regulatory, strategic document. It sets a national framework of objectives, priority actions and performance indicators intended to guide and coordinate Australian Government, state and territory, regional and private activity to reduce the impact of the European red fox (Vulpes vulpes) on biodiversity (see 1 Introduction; 2 Objectives and actions).
Mechanically, the plan:
Identifies a five‑point goal and corresponding objectives (pp. 4-9): prevent fox establishment in new areas and eradicate from high‑conservation islands (Objective 1); promote maintenance and recovery of affected native species and communities (Objective 2); improve scientific knowledge on fox impacts and interactions (Objective 3); improve effectiveness, target specificity and humaneness of control options (Objective 4); and increase stakeholder awareness and uptake (Objective 5).
Sets out 20 named actions, each assigned a priority (very high / high / medium / low) and a timeframe (short, medium, long term) for implementation (see Objective action tables 1.1-5.1).
Establishes performance indicators for each objective against which progress is to be assessed (see each Objective’s “Performance indicators”).
Describes implementation arrangements and institutional roles: the Department of the Environment, Water, Heritage and the Arts (DEWHA) will facilitate implementation, support a TAP implementation team, and the Australian Government will apply the plan to Commonwealth land; the TAP is to be implemented in the context of AusBIOSEC and the Australian Pest Animal Strategy and the Vertebrate Pests Committee (3.2).
Current sections
Direct links to the current provisions in Threat Abatement Plan for Predation by the European Red Fox.
1
Source text: opening excerpt
Sourced from the Federal Register of Legislation (legislation.gov.au), CC BY 4.0.
1 Threat Abatement Plan for Predation by the European Red Fox
Threat Abatement Plan for Predation by the European Red Fox
made under section 33 of the Endangered Species Protection Act 1992 and continued in force under the Environment Protection and Biodiversity Conservation Act 1999
Compilation No. 1
Compilation date: 1 October 2008
Includes amendments up to: F2009L00064
About this compilation
This compilation
This is a compilation of the Threat Abatement Plan for Predation by the European Red Fox that shows the text of the law as amended and in force on 1 October 2008 (the compilation date).
The notes at the end of this compilation (the endnotes) include information about amending laws and the amendment history of provisions of the compiled law.
Uncommenced amendments
The effect of uncommenced amendments is not shown in the text of the compiled law. Any uncommenced amendments affecting the law are accessible on the Legislation Register (www.legislation.gov.au). The details of amendments made up to, but not commenced at, the compilation date are underlined in the endnotes. For more information on any uncommenced amendments, see the series page on the Legislation Register for the compiled law.
Application, saving and transitional provisions for provisions and amendments
If the operation of a provision or amendment of the compiled law is affected by an application, saving or transitional provision that is not included in this compilation, details are included in the endnotes.
Modifications
If the compiled law is modified by another law, the compiled law operates as modified but the modification does not amend the text of the law. Accordingly, this compilation does not show the text of the compiled law as modified. For more information on any modifications, see the series page on the Legislation Register for the compiled law.
Self‑repealing provisions
If a provision of the compiled law has been repealed in accordance with a provision of the law, details are included in the endnotes.
Threat abatement plan
for predation by the European red fox
2008
Department of the Environment, Water, Heritage
and the Arts
This work is copyright. Apart from any use as permitted under the Copyright Act 1968, no part may be reproduced by any process without prior written permission from the Commonwealth, available from the Department of the Environment, Water, Heritage and the Arts. Requests and inquiries concerning reproduction and rights should be addressed to:
Provides a list (Appendix A) of named threatened and unlisted species that may be adversely affected by fox predation to prioritise control and conservation investment.
The TAP does not create new criminal offences, statutory duties or permit regimes within its own text. Instead it operates as a policy instrument under the EPBC Act framework: DEWHA “develops TAPs and facilitates their implementation” (1.1). The document links to other statutory and non‑statutory frameworks (e.g. NRMMC monitoring framework, Australian Pest Animal Strategy) and anticipates state/territory and regional natural resource management (NRM) plans as the operational scale for on‑ground work (1.1; 3.2). The plan explicitly accepts that continental eradication is not feasible with current methods and funding and therefore focuses on suppression and targeted eradication on islands and Tasmania where practicable (1.2.3; Objective 1).
Main concepts
The TAP’s architecture is conceptual and pragmatic rather than prescriptive. Key concepts used repeatedly in the text are these.
Threat abatement plan: defined in the glossary as “a plan providing for the research, management, and any other actions necessary to reduce the impact of a listed key threatening process on affected species and ecological communities.” The TAP is the instrument that sets out those actions for the red fox (Glossary; 1 Introduction).
Key threatening process: fox predation is a process listed under the EPBC Act. The TAP attaches to that listing and directs targeted responses to reduce its impact (1.2.1).
Prioritisation: the TAP instructs decision‑makers to target resources to “priority areas” selected by evidence of species significance, degree of threat posed by foxes relative to other threats, feasibility of action and cost‑effectiveness (Action 2.1). Actions carry explicit priority ratings and timeframes to guide resource allocation (Objective tables).
Scale and integration: the TAP repeatedly emphasises that regional NRM plans and site‑based plans are the best operational scale for implementation; it promotes integrated pest control (multi‑species programs) because single‑species control can produce unintended ecological outcomes (1.1; Objective 3, Actions 3.2-3.4).
Prevention, containment and eradication: the plan distinguishes three strategic responses. Prevention and monitoring at invasion edges is important; eradication is targeted at islands and Tasmania where feasible and cost‑effective; containment and long‑term suppression are the pragmatic response on the mainland (1.2.3; Objective 1 Actions 1.1-1.4).
Monitoring and evaluation: the TAP places significant emphasis on development of simple, cost‑effective monitoring protocols for foxes and affected native species (Actions 3.1 and 3.5) and on alignment with the National Monitoring and Evaluation Framework (NRMMC 2003) (3.3).
Technical development: the TAP identifies specific R&D priorities: improved bait media, canid‑specific toxins, M44 ejectors, bait delivery stations, fertility control and genetic monitoring (Objectives 3-4, Actions 3.1, 4.1-4.2). It also promotes the use of genotyping of scats/hairs and population genetic analysis to track invasion routes and abundance (1.2.3; Action 3.1).
Humaneness and standards: the plan requires promotion of humane methods and adoption of model codes of practice and the National Competency Standards for Vertebrate Pest Management (Action 4.7; Objective 4).
Cost focus: the TAP acknowledges that implementation is resource dependent and provides concrete cost examples to frame expectations: aerial baiting of ~35,000 km2/year costs about $1.3 million, and exclusion fencing can cost up to $10,000 per km (3.1).
Species focal list: Appendix A lists named threatened and unlisted species and ecological communities potentially affected by fox predation. The list is “indicative and not comprehensive” and is intended to guide prioritisation (Appendix A; 3.3).
Collectively these concepts create a plan that is action‑oriented (20 specified actions), evidence‑oriented (priority based on species significance and feasibility), and designed to be implemented through coordination rather than top‑down regulation (1.1; 3.2).
Who it affects
The TAP identifies a broad range of stakeholders who will be affected in practice, explicitly naming categories rather than creating legal obligations.
Australian Government (DEWHA and Commonwealth land managers)
DEWHA’s role is central: it develops TAPs, facilitates implementation, establishes a TAP implementation team and will implement the plan on Commonwealth land (1.1; 3.2). The Australian Government may allocate funds for key national environmental priorities and relevant TAP actions (3.1-3.2). DEWHA also establishes national databases, extension material and coordination mechanisms.
State and territory governments and statutory agencies
The plan anticipates coordination with state/territory conservation and pest management agencies, and with the Vertebrate Pests Committee under the Australian Pest Animal Strategy (1.1; 3.2). State TAPs (for example NSW NPWS’ red fox TAP is referenced) and local programs are the vehicle for on‑ground work (1.2.4).
Regional NRM bodies and local government
The TAP designates regional NRM plans and site‑based plans as the best operational context for developing and implementing control programs and contingency plans; regional bodies will therefore be implementers and decision‑makers for local actions (1.1; Objective 2).
Private landholders and leaseholders
The plan expressly recognises the role and limitations of private landholders and leaseholders in on‑ground control and asks that implementation supports their efforts through incentives, negotiated agreements and partnerships (1.1; Action 2.3). It also flags the need to consider Indigenous communities’ views in implementation (3.2).
Researchers and industry
Universities, CRCs (the text mentions the Invasive Animals Cooperative Research Centre), and other R&D providers are affected by the plan’s research priorities (genotyping, bait development, fertility control) (1.2.3; Actions 3.1, 4.1-4.2).
Community groups and volunteers
The TAP anticipates community groups and volunteers will be participants in regional control programs and extension activities, and includes stakeholder awareness and extension (Objective 5; Action 5.1).
Conservation‑listed species and ecological communities
Appendix A lists specific threatened species (critically endangered, endangered, vulnerable) and unlisted taxa that may be adversely affected. These named taxa are the intended beneficiaries of targeted control programs and hence guide prioritisation of resources (Appendix A).
Private business and primary producers
The TAP recognises that pest control intersects with primary production and that R&D and control programs should integrate interests of both primary production and environmental conservation (1.1). This implies private industry (e.g. pastoralists, farmers) will face costs or opportunities from coordinated control programs and any incentives offered.
Who pays and who decides
The TAP is explicit that investment will be determined by stakeholder resource commitments, with Australian Government funds potentially available for national priorities (3.1-3.2). Decision authority for on‑ground action is distributed: DEWHA coordinates and supports, but state/territory, regional NRM, landholders and communities largely decide implementation specifics in their tenures (1.1; 3.2). The Vertebrate Pests Committee is responsible for implementation of the Australian Pest Animal Strategy, into which the TAP feeds (1.1).
Who is not directly constrained by the TAP
The TAP does not itself impose statutory duties or criminal penalties on any of these actors; it is a coordination and guidance instrument under the EPBC Act framework (1.1). That means affected parties are influenced through policy, funding, standards and technical guidance rather than new statutory prohibitions within this document.
Key duties and rights
This TAP does not create novel statutory duties, licences or explicit private rights. It operates as a central policy framework under the EPBC Act to guide and coordinate actions by governments and non‑government actors. The operative duties and rights therefore follow from the instruments, programmes and administrative arrangements it interacts with, rather than from the TAP text itself.
Administrative and coordination duties
DEWHA is tasked with developing TAPs, facilitating implementation and supporting a TAP implementation team; those are administrative obligations described in the plan (1.1; 3.2). The Australian Government is required by the EPBC framework to consider TAPs when addressing key threatening processes; here, implementation on Commonwealth land is specifically identified (3.2).
Priority‑setting duties (informal)
The TAP directs that priority areas should be identified on a scientific basis (Action 2.1), that islands or isolated sites be assessed and contingency plans developed (Actions 1.1-1.3), and that monitoring protocols be developed and applied (Action 3.1). These are framed as actions for agencies and stakeholders to implement. They create administrative expectations for agencies that accept implementation funding or leadership roles.
Standards and compliance expectations
The plan requires promotion and continued adoption of model codes of practice and standard operating procedures for humane management of foxes and their recognition under the National Competency Standards for Vertebrate Pest Management (Action 4.7). While this is not itself enforceable law, competence standards and model codes typically feed into procurement, funding eligibility and operational conditions administered by governments.
Research and monitoring obligations (programme levers)
Actions 3.1, 3.5 and 4.1-4.2 set research and monitoring priorities. Funding recipients (government or grant‑funded researchers) will be expected to follow those priorities. The TAP also requires alignment with national monitoring frameworks (3.3), which can affect reporting obligations where funds or approvals are tied to DEWHA or NRMMC processes.
Rights and entitlements
The TAP does not confer property rights or compensation rights. It does specify that Australian Government funds may be available for TAP actions and regional priorities (3.1), implying potential eligibility for grants or co‑investment for those who align with TAP objectives. The TAP also envisages incentives, partnerships and negotiated agreements with private and leasehold lands for on‑ground control (Action 2.3), which are voluntary mechanisms rather than enforceable rights.
No direct penalties in the TAP
The document contains no penalty regime or criminal sanctions. Legal obligations and penalties for harming threatened species or breaching EPBC‑regulated approvals remain in the EPBC Act and subordinate instruments, but this TAP itself does not create statutory offences or penalties. Its effect on behaviour derives from funding, coordination, technical guidance, and the influence of the EPBC Act process under which it was made (1.1).
Summary
The TAP creates administrative expectations for government agencies and guidance for practitioners: identify priorities, apply national protocols, integrate pest control, develop contingency plans and adopt humane practices. Compliance is primarily achieved through policy levers,funding, guidance, standards and inter‑governmental coordination,rather than through new statutory duties within the text of the TAP.
Penalties and enforcement
The TAP document does not establish novel criminal offences, civil penalties or a standalone enforcement regime. It is a strategic policy document prepared under the EPBC Act framework and structured to guide research, management and coordinated action. The TAP therefore operates through non‑coercive mechanisms: funding decisions, guidance, standards, intergovernmental coordination and stakeholder engagement (1.1; 3.2).
What enforcement mechanisms are expressly in the TAP
The TAP sets expectations for adoption of model codes of practice and National Competency Standards (Action 4.7). Adoption of those codes will influence operational practice and may be incorporated into contracts, grant conditions or licensing arrangements administered by agencies, but the TAP does not itself specify enforcement sanctions for non‑adoption.
Indirect enforcement via other instruments
Practical enforcement or sanctioning for activities that harm EPBC‑listed species or communities would continue to come from the EPBC Act and associated regulations. The TAP does not substitute for the EPBC Act; it complements it by providing priority actions and a strategic framework (1.1). Where TAP‑guided work is tied to funding, failure to meet contractual or grant conditions informed by TAP priorities could produce administrative enforcement (suspension of funds, termination of agreements), but those are contractual or administrative, not statutory penalties imposed by the TAP itself.
Monitoring and evaluation as an accountability mechanism
The TAP emphasises development of national monitoring protocols, indicators and evaluation under the NRMMC monitoring and evaluation framework (3.3). These systems create transparency and public accountability. If monitoring shows failure to meet performance indicators, that is intended to guide adaptive management and reprioritisation rather than to trigger direct penalties within the TAP (Performance indicators under each Objective).
Operational consequences for implementers
Practitioners and agencies accepting public funds or participating in coordinated programs will face practical consequences if they do not meet TAP‑linked standards: loss of funding, lower priority status in national coordination, reduced access to technical support, or reputational costs. The TAP is explicit that achievement is resource‑dependent and that DEWHA will facilitate partnerships and co‑investment (1.1; 3.1-3.2).
Summary
The TAP itself contains no penal provisions. Enforcement pressures arise from companion statutory instruments (the EPBC Act), contractual conditions on funding, national standards and codes of practice recommended by the TAP, and the monitoring and evaluation processes (3.3) designed to report progress against the TAP’s performance indicators.
How it interacts with other laws
The TAP is an instrument produced within the EPBC Act framework and is expressly designed to operate alongside and feed into a network of other policy frameworks, statutory arrangements and non‑statutory guidelines. The document refers repeatedly to those interactions.
EPBC Act
The TAP was continued in force under the EPBC Act 1999 and derives its standing from the Act’s requirement for approaches to listed key threatening processes (cover page; 1 Introduction; 1.1). The TAP provides the research and management actions necessary to abate that listed process. The EPBC Act remains the primary statute for legal protection of threatened species and ecological communities identified in Appendix A.
Australian Pest Animal Strategy and Vertebrate Pests Committee
The TAP is to be implemented in the broader context of the Australian Pest Animal Strategy (2007) and the Vertebrate Pests Committee, which comprises representatives from Australian, state and territory governments and is responsible for implementation of that strategy (1.1). This links TAP priorities into intergovernmental pest‑management fora.
Australian Biosecurity System for Primary Production and the Environment (AusBIOSEC)
The plan is to operate under the overarching framework of AusBIOSEC, integrating biosecurity and pest management for both primary production and environmental outcomes (3.2). That links the plan to biosecurity policy processes that often have statutory dimensions for import controls and movement of risk materials.
National Monitoring and Evaluation Framework (NRMMC)
Monitoring and evaluation are expected to conform with the National NRM monitoring framework established by the Natural Resource Management Ministerial Council (NRMMC 2003). This creates an interaction between TAP reporting and the broader national monitoring arrangements (3.3).
State and territory laws and plans
The TAP anticipates that state and territory pest management rules, subsidies, licensing and animal welfare statutes will remain operative. It invites coordination with existing state TAPs and regional NRM plans (1.1; 1.2.4). For example, NSW NPWS’ Threat abatement plan for predation by the red fox is cited as a complementary instrument (1.2.4).
Model codes, competency standards and SOPs
The TAP promotes adoption and adaptation of model codes of practice and standard operating procedures for humane management of foxes, including their recognition under the National Competency Standards for Vertebrate Pest Management (Action 4.7). Where these codes become references in funding or procurement, they will interact functionally with administrative law and contractual regimes.
Pesticide registration and agricultural chemical law
The TAP’s research and operational recommendations (Action 4.1-4.2) discuss toxins such as 1080, canid‑specific toxins and other delivery systems. The TAP does not alter pesticide registration or approvals, so any operational use of toxins remains subject to registration, label instructions, and state/territory chemical control laws and animal welfare rules.
Property and tenure law
The TAP’s measures for islands, fencing and landholder incentives (Objective 1 and Action 2.3) interact with land tenure arrangements, leasehold regulations and private property decision‑making. The plan recognises that partnerships and negotiated agreements on private or leasehold land are needed rather than top‑down statutory compulsion (Action 2.3).
Summary
The TAP is a coordinating policy instrument that complements and interacts with the EPBC Act, biosecurity and pest animal strategies, state/territory pest laws, pesticide regulation, national monitoring frameworks and competency standards. It does not amend or supersede statutory laws; rather, it informs funding priorities, best practice standards and intergovernmental coordination.
Amendment history
The compilation header and endnotes provide the amendment and registration history relevant to this document. Key points drawn from the endnotes and front matter are:
The plan published here is the 2008 TAP prepared by the Department of the Environment, Water, Heritage and the Arts (DEWHA) and is a replacement for the original 1999 TAP (1 Introduction; 1.2.4). The document states it replaces the TAP for foxes published in 1999 (EA 1999a).
Compilation details at the front indicate Compilation No. 1, compilation date 1 October 2008, and that the compilation includes amendments up to F2009L00064 (cover page and “About this compilation”).
Endnote 3 provides two registration/commencement entries. It lists:
• Threat Abatement Plan for Predation by the European Red Fox, registration 15 Oct 2008 (F2008B00667), commencement 2 July 1999; and
• Threat Abatement Plan for Predation by the European Red Fox 2008, registration 12 Jan 2008 (F2009L00064), commencement 1 October 2008.
These entries reflect the compilation metadata and the replacement role of the 2008 TAP (Endnote 3).
Endnote 4 indicates the Threat Abatement Plan for Predation by the European Red Fox was revised and shows the entry “rs F2009L00064”, signalling a repeal and substitution or replacement associated with that instrument (Endnote 4).
The plan also records the 2004-05 Bureau of Rural Sciences review (Hart 2005) as the basis for changes to the original 1999 TAP and for retaining largely the same objectives while updating actions and implementation advice (1.2.4).
Practical implication
For legal and administrative purposes, the TAP is the 2008 version; it supersedes the 1999 TAP and contains updated actions and priorities. The compilation notes that uncommenced amendments and modifications may exist and that readers should consult the legislation register for details (front matter, “This compilation” notes).
Caveat
The TAP’s endnotes show compilation and registration metadata rather than legislative amendments of a statute. The plan is a statutory instrument in the sense it was made under earlier statutory authority and continued under the EPBC Act, but the amendment history here documents the TAP versions themselves rather than amendments to the EPBC Act.
Litigation history
The TAP contains no case law citations and does not record any judicial decisions concerning the plan itself. The document’s references are to scientific reports, reviews and policy materials (e.g. Hart 2005, Saunders & McLeod 2007, BRS reports), not to litigation (References).
What the TAP records
The document records reviews and scientific evaluations (e.g. Hart 2005 review of 1999 TAPs) and cites scientific literature on fox impacts and control methods. It does not identify any court decisions, tribunal determinations or legal challenges to the TAP or to specific actions listed (References; 1.2.4).
What this means in practice
Because the TAP is a policy instrument that sets national priorities and guidance, legal disputes about obligations or enforcement would most likely be routed through the EPBC Act, administrative law (judicial review of agency decisions), pesticide regulatory law, or state/territory animal welfare and pest legislation. The TAP itself creates no enforcement mechanism that could be directly litigated; litigation would typically concern whether particular government decisions that rely on the TAP complied with statutory duties, procedural fairness, or evidenced reasonable administrative exercise of power. None of that litigation history is discussed in the TAP.
Recommendation for due diligence
Practitioners seeking case law or judicial reactions to TAP‑driven decisions should search EPBC Act judicial review decisions, administrative determinations and case law concerning threatened species approvals, pesticide approvals, or funding decisions. The TAP does not provide that record.
Gotchas
Practical pitfalls, implementation risks and common misunderstandings that arise from reading and applying this TAP are listed below, grounded in the document’s own statements.
It is guidance, not a binding statute
The TAP is a national policy framework under the EPBC Act but does not itself impose statutory criminal or civil penalties. Expectation creation (priority setting, monitoring) is the mechanism, not compulsion. Practitioners sometimes misinterpret TAP‑actions as legally mandatory; they are policy directions intended to be implemented by governments and partners (1.1; Key duties and rights).
Eradication vs suppression: feasibility caveat
The TAP explicitly states continental eradication is currently infeasible and that objectives therefore focus on suppression and targeted eradication of islands/Tasmania where feasible and cost‑effective (1.2.3; Objective 1 Actions). Planning for eradication without considering this feasibility statement can misallocate resources.
Resource dependence and uncertain funding
The TAP repeatedly notes implementation is resource dependent (3.1). The document provides concrete cost examples (aerial baiting ≈ $1.3 million per 35,000 km2/year; fencing up to $10,000/km) to signal ongoing high costs. Expectation mismatch between the TAP’s ambitions and available funding is a material implementation risk.
Monitoring difficulty and attribution problem
The BRS review found it is difficult to link TAP outputs to reduced impacts because of paucity of national data and monitoring inconsistencies (1.2.4). The TAP therefore emphasises development of national monitoring protocols (Action 3.1) but implementing robust, comparable monitoring over large jurisdictions is technically and politically hard. This complicates claims about TAP effectiveness.
Reinvasion and spatial scale problem
Fox populations recover rapidly, often through reinvasion, and successful control at a site often requires coordinated control in adjacent areas (Objective 2; Action 2.2). Site‑level efforts that fail to manage surrounding reinvasion sources are liable to fail.
Unintended ecological effects
The TAP warns control in isolation can produce unintended outcomes (e.g. mesopredator release) and calls for integrated multi‑species programs and research into interactions between foxes, cats, wild dogs and rabbits (Actions 3.2-3.4). Single‑species campaigns without ecological assessment risk shifting predation pressure rather than reducing net threat.
Humaneness, regulatory approvals and public acceptance
The TAP promotes research into new toxins and delivery methods (Action 4.1-4.2) including canid‑specific approaches and fertility control. However, any operational use of new toxins or methods will require pesticide registration, animal welfare assessment and public consultation. The TAP does not override those processes; developers must navigate them.
Dependence on stakeholder cooperation
The TAP’s success rests on coordination among landholders, local government, state/territory agencies and the Australian Government (1.2.5). Where cooperation is limited, the plan’s measures (incentives, negotiated agreements) may not be sufficient and on‑ground outcomes will lag.
Islands and contingency planning complexity
Action 1.2 directs contingency planning for islands and isolated mainland ‘islands’. That requires detailed biosecurity, social licence, and logistics planning. The TAP acknowledges DEWHA is establishing a national database for offshore islands, but data gaps can delay or misdirect priority selection (Objective 1; Action 1.1).
Scope creep and multi‑threat context
The TAP focuses on fox predation but repeatedly notes foxes interact with habitat loss, other pests, disease and fire regimes. Effective investment may need to address these other threats; funding constrained to fox control alone may deliver limited biodiversity gains.
Data reliance and species list limits
Appendix A is explicitly “indicative and not comprehensive.” Practitioners must not treat it as exhaustive; local species at risk may be absent from the list but still require protection (Appendix A statement).
Summary
The TAP is clear about its own limitations: funding constraints, monitoring challenges, reinvasion risks, and the need for integrated multi‑species management. Practical implementation requires careful prioritisation, robust monitoring design, inter‑jurisdictional cooperation, and alignment with pesticide, biosecurity and animal welfare regulatory requirements.
How to comply
The TAP sets expectations and practical actions rather than prescriptive legal requirements. For practitioners (state agencies, regional NRM bodies, landholders, contractors, researchers) who want to align with the TAP and be eligible for associated funding and partnership support, the following concrete steps are grounded in the TAP text.
Use the plan’s prioritisation framework (Action 2.1)
Identify priority areas for fox control using the TAP criteria: significance of affected populations/ecological communities, degree of fox threat relative to other threats, cost‑effectiveness of maintaining fox populations below a damage threshold, and feasibility of remedial action (Action 2.1). Document the evidence base used for prioritisation (species distributions, habitat risk maps, fox distribution).
Align monitoring to national protocols (Actions 3.1 and 2.2)
Adopt or participate in development of national, simple and cost‑effective monitoring methods for fox abundance and affected species (Action 3.1). Where available, apply the NRMMC monitoring and evaluation framework for reporting outcomes (3.3). Keep pre‑ and post‑control monitoring records, follow genotyping approaches where appropriate, and report results to regional and national databases.
Integrate multi‑species control (Actions 3.2-3.4)
Coordinate fox control with programs for feral cats, wild dogs and rabbits. Consider likely ecological interactions and the potential for mesopredator release. Plan concurrent or phased interventions to minimise unintended consequences (Actions 3.2-3.4).
Prepare island contingency and eradication plans (Objective 1 Actions)
For islands and isolated mainland refugia, collate data on conservation values and invasion risk (Action 1.1), develop contingency plans for prevention, monitoring and rapid response (Action 1.2), and implement containment/eradication actions where feasible (Actions 1.3-1.4). Ensure plans account for biosecurity, logistics, community engagement and post‑eradication monitoring.
Follow model codes and competency standards (Action 4.7)
Ensure personnel delivering control are trained to National Competency Standards for Vertebrate Pest Management and that operations follow recognised model codes of practice and SOPs for humane management (Action 4.7). Maintain training records and accreditation evidence.
Document cost‑benefit and feasibility analyses (Actions 1.4; 4.3)
For proposed eradication (e.g. island projects) or costly infrastructure (exclusion fencing), prepare explicit feasibility and cost‑effectiveness analyses, referencing the TAP’s cost examples (3.1) and the TAP’s call for testing fence designs and disseminating cost data (Action 4.3).
Use incentives and negotiated agreements on private lands (Action 2.3)
Where programs rely on private or leasehold land, put in place negotiated agreements and incentive structures (other than bounties) to encourage sustained control in adjacent areas to prevent reinvasion (Action 2.3). Keep records of agreements and incentive payments for audit and evaluation.
Participate in research priorities and data sharing (Actions 3.1, 4.1-4.2)
Contribute to or adopt R&D outcomes on improved baiting media, target specificity and non‑lethal approaches. Share genetic or monitoring data with national databases (the TAP mentions the Invasive Animals CRC genetic database development) to improve population genetics understanding and invasion‑route identification (1.2.3; Action 3.1).
Budget for ongoing costs and plan for sustainability (3.1)
Factor in ongoing high costs and operational requirements. Use the TAP’s example figures for planning (aerial baiting costs and fencing costs) as a conservative budget guide, and seek co‑investment and multi‑year commitments.
Communicate and provide extension (Action 5.1)
Develop extension material on TAP objectives, best practice control techniques, humane methods and the rationale for priority areas, and distribute to landholders, community groups and local government (Action 5.1). Document outreach activities and uptake metrics for reporting.
Recordkeeping checklist for auditors and funders
Priority area maps and selection rationale (Action 2.1).
Pre/post‑control monitoring data and methods (Action 3.1).
Training and competency certificates for operational staff (Action 4.7).
Contractual records for incentive agreements and partnerships on private land (Action 2.3).
Feasibility and cost‑benefit analyses for eradication or infrastructure projects (Action 4.3; 1.4).
Data sharing agreements and genetic monitoring outputs when used (Action 3.1).
Legal compliance overlays
Ensure all pesticide use, toxins and delivery systems comply with registration and label instructions and relevant state/territory rules. Secure any necessary approvals before deploying new toxins or devices (Actions 4.1-4.2).
Align animal welfare obligations to applicable state/territory law and to the TAP’s humane standards (Action 4.7).
Summary
To be “compliant” with the TAP in practice means to implement TAP actions where relevant and feasible, to follow the plan’s priority and monitoring guidance, to adopt the recommended standards and training, and to document outcomes. Because the TAP influences funding and coordination, proactive alignment will aid access to joint programs and grants and reduces risk of disjointed local efforts that fail due to reinvasion or unintended ecological effects (Objective 2, Objective 3).
Assistant Secretary
Biodiversity Conservation Branch
Department of the Environment, Water, Heritage
and the Arts
GPO Box 787
Canberra ACT 2601
They are also available by emailing the Department of the Environment, Water, Heritage and the Arts, Community Information Unit, at ciu@environment.gov.au
or freecall 1800 803 772.
This plan should be cited as: Department of the Environment, Water, Heritage and the Arts (DEWHA) (2008). Threat abatement plan for predation by the European red fox, DEWHA, Canberra.
Front cover photo: Graeme Purdy
Technical editing and production management: Biotext Pty Ltd
Design and artwork: Design Direction
Contents
1 Introduction 1
1.1 Threat abatement plans 1
1.2 Threat abatement plan for the European red fox 2
1.2.1 The threat 2
1.2.2 The impacts 2
1.2.3 Managing the threat 2
1.2.4 The review of the 1999 TAP 3
1.2.5 Involvement of stakeholders 3
2 Objectives and actions 4
Objective 1 5
Objective 2 6
Objective 3 7
Objective 4 8
Objective 5 9
3 Duration, cost, implementation and evaluation of the plan 10
3.1 Duration and cost of the plan 10
3.2 Implementing the plan 10
3.3 Evaluating implementation of the plan 10
Appendix A: Species affected by the European red fox 11
Glossary 17
Acronyms and abbreviations 18
References 19
1 Introduction
This threat abatement plan (TAP) establishes a national framework to guide and coordinate Australia’s response to the impacts of European red foxes on biodiversity. It identifies the research, management and other actions needed to ensure the long-term survival of native species and ecological communities affected by predation by European red foxes. It replaces the TAP for predation by European red foxes published in 1999 (EA 1999a).
This plan should be read in conjunction with the publication Background document for the threat abatement plan for predation by the European red fox (DEWHA 2008). The background document provides information on fox characteristics, biology and distribution; impacts on environmental, economic, social and cultural values; and current management practices and measures.
1.1 Threat abatement plans
Under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), the Australian Government develops TAPs and facilitates their implementation. To progress the main strategic development actions, the Department of the Environment, Water, Heritage and the Arts (DEWHA) assesses the potential for partnerships and co-investment with other government agencies, industry and other stakeholders. An important part of implementation of the TAP is ensuring that knowledge of improved abatement methods is disseminated to potential users.
Mitigating the threat of invasive species is not simply a matter of providing better technical solutions, such as improved baits for pest animal control. It also involves understanding and addressing social and economic factors; for example, through supporting the efforts of private landholders and leaseholders to manage invasive species on their lands for biodiversity conservation and primary production. In addition, research and development programs for controlling vertebrate pest species need to integrate the interests of both primary production and environmental conservation.
Regional natural resource management plans and site-based plans provide the best scale and context for developing operational plans for controlling invasive species. They allow primary production and environmental considerations to be jointly addressed, and control to be integrated across the local priority vertebrate pests within the scope of other natural resource management priorities.
The national coordination of pest animal control activities occurs under the Australian Pest Animal Strategy, released in 2007 by the Natural Resource Management and Primary Industries Ministerial councils. The Vertebrate Pests Committee, comprising representatives from all Australian, state and territory governments, has responsibility for implementation of the strategy. This TAP provides guidance for management of foxes within that broader context.
1.2 Threat abatement plan for the European red fox
1.2.1 The threat
The European red fox (Vulpes vulpes) was first brought to Australia by English settlers in the 19th century (Rolls 1984), and by the 1870s fox populations had become established in the wild. Today, foxes are widely distributed across the Australian mainland and are confirmed to be present in Tasmania (Saunders et al. 2006). However, the fox has not yet colonised the tropical far north and is not established on Kangaroo Island or on many other offshore islands. Factors driving abundance and distribution of foxes are not clear; for example, it is not known whether they have reached their northern limit (Saunders et al. 1995).
The fox is a serious vertebrate pest and is in the World Conservation Union’s list of the 100 worst invasive species (Lowe et al. 2000). Predation by the European red fox is listed as a key threatening process under the EPBC Act. Foxes are a confirmed or perceived threat to a large number of threatened species (see Appendix A), although impacts from fox predation are not restricted to these species.
This TAP has been put into place as a feasible, effective and efficient way to abate the threat of predation by foxes.
1.2.2 The impacts
Foxes have a wide dietary range, and are threatened by few natural enemies or few serious diseases in Australia. They also have high reproductive rates and high rates of cub survival, which allows them to rapidly colonise areas although they only breed once a year over a short period. These attributes are important in making the fox a significant threat to biodiversity.
Foxes have direct impacts on a range of native animal species. They prey particularly on small to medium-sized, ground-dwelling and semi-arboreal mammals, ground-nesting birds and chelid tortoises.
1.2.3 Managing the threat
As foxes are so widely established in Australia, the focus of management is on abating impacts by established populations, except for offshore islands that are currently fox free and Tasmania where eradication is being attempted. Control of foxes is difficult; control methods include baiting, shooting, trapping, den fumigation or destruction, and exclusion fencing. However, apart from broadscale baiting, the methods are expensive, labour intensive, long term and of limited effectiveness (Saunders and McLeod 2007).
Interactions between pest species mean that control of other pest animals can have effects on foxes. For example, a study in inland Australia found that fox numbers fell after a major reduction in rabbit numbers through rabbit haemorrhagic disease (Bowen and Read 1998). An understanding of these interactions is important when designing and recommending pest animal control programs. In many situations, concurrent multi-species programs will be required. Integrating control techniques will maximise the success of control programs.
Continental eradication may be the ideal goal of a fox TAP, but is not feasible with current resources and techniques. Fox populations must therefore be suppressed and managed to mitigate impacts on affected native species. Progress in control programs must be monitored to ensure that objectives are met and to allow management options to be adapted to changing circumstances. Individual identification of foxes by scat genotyping has potential for monitoring abundance before and after control programs (Piggott and Taylor 2003). In addition, population genetic analysis may offer insights into invasion routes and population dynamics. The necessary background genetic database enabling data interpretation is being developed by the Invasive Animals Cooperative Research Centre.
1.2.4 The review of the 1999 TAP
In accordance with the requirements of the EPBC Act, the original TAP for foxes (EA 1999a) was reviewed in 2004–05 by the Bureau of Rural Sciences (BRS) (Hart 2005) as part of a broader review encompassing the original TAPs for cats (EA 1999b), goats (EA 1999c) and rabbits (EA 1999d). Anecdotal, circumstantial and experimental evidence shows that fox predation continues to be a major threat to the survival of native Australian fauna. The review identified a number of the actions that have been implemented by state agencies; for example, New South Wales with its own TAP has undertaken local regional fox control to benefit threatened species.
The BRS review found that it was difficult to accurately determine the extent to which the TAP had reduced the impacts of foxes on biodiversity. This reflects the current paucity of nationally consistent data on the ranges and densities of foxes and their impacts, and the difficulties of linking outcomes in population changes to the outputs of the fox TAP. The invasive species indicator data to be produced under the National Monitoring and Evaluation Framework (NRMMC 2003) should improve the availability of continental overview data over the next year or so.
The BRS surveyed a broad range of stakeholders and assessed a range of projects commissioned by the Department of Environment and Heritage (now the Department of the Environment, Water, Heritage and the Arts) that were developed under the auspices of the existing TAPs. This has helped to identify actions that will need to be initiated or continued into the future. The review concluded, however, that the fox-related projects that were assessed had positively contributed to reducing the impacts of foxes. Furthermore, projects have addressed specific pest control needs in high-priority locations, toxin development and biocontrol agents, and have provided considerable support for developing control techniques. Of the 27 actions in the 1999 TAP for foxes, many were targeted by at least one project, and almost a third of the fox actions had been fully completed.
The BRS review proposed a number of changes to the actions found in the original TAP, but recommended that the objectives remain substantially unchanged. The review suggested that the implementation of the revised fox TAP should give priority to improved national engagement, integrated pest animal control, flexibility in implementation, setting priorities for research, follow-through with research and development, and establishment of a new advisory panel for vertebrate TAPs. The review also recommended that the revised plan include measures to enhance existing processes through, for example, regional processes, control and monitoring techniques that support on-ground management, and monitoring of key projects according to national protocols.
This document replaces the 1999 TAP. It incorporates the knowledge gained in the intervening years and has been modified in line with recommendations from the review. The TAP aims to guide the responsible use of public resources and the best outcome for native species and ecological communities threatened by predation by foxes. The plan seeks to achieve these outcomes by recognising the opportunities and limitations that exist, and ensuring that field experience and research are used to further improve management of foxes. The activities and priorities under the TAP will need to adapt to changes as they occur.
1.2.5 Involvement of stakeholders
The successful implementation of this TAP will depend on a high level of cooperation between landholders, community groups, local government, state and territory conservation and pest management agencies, and the Australian Government and its agencies. Success will depend on all participants allocating adequate resources to achieve effective on-ground control of foxes at critical sites, improve the effectiveness of control programs, and measure and assess outcomes. Various programs in natural resource management, at national, state and regional levels, can make significant contributions to implementing the plan.
2 Objectives and actions
The goal of this TAP is to minimise the impact of foxes on biodiversity in Australia and its territories by:
• protecting affected native species and ecological communities, and
• preventing further species and ecological communities from becoming threatened.
To achieve this goal, the plan has five main objectives, developed through the review of the previous TAP (Hart 2005) and consultation with experts. These objectives are to:
prevent foxes occupying new areas in Australia and eradicate foxes from high-conservation-value ‘islands’
promote the maintenance and recovery of native species and ecological communities that are affected by fox predation
improve knowledge and understanding of fox impacts and interactions with other species and other ecological processes
improve the effectiveness, target specificity, integration and humaneness of control options for foxes, and
increase awareness of all stakeholders of the objectives and actions of the TAP, and of the need to control and manage foxes.
Each objective is accompanied by a set of actions, which, when implemented, will help to achieve the goal of the plan. Performance indicators have been established for each objective. Progress will be as
This is an opening excerpt, not the complete document.