My name is Trevor Andrew Hold. I am managing director of HOLD Technologies Pty Ltd (ABN 96 109 935 891), which manages several registered business operations including Genesis Novel Pastures and Agriculture, Amber Resolve, and Australian Advocacy Group. My business, a registered biosecurity entity, has lost two calves and experienced fertility problems in cows as a direct result of repeated, excessive exposure to toxic chemicals distributed by the National Fire Ant Eradication Program (NFAEP), both directly on my property and in waterways upstream from my livestock drinking water supply supply. These adverse effects have been reported and ignored by the Australian Pesticides Veterinary Medicines Authority (APVMA). This has negatively impacted the cash flow of my commercial enterprises and created negative emotions for myself, my family and my clients who come to enjoy the livestock as part of their own family.
I reached out to NFAEP to discuss these issues only to be ghosted and ignored. I had to learn about the regulator APVMA and the process for reporting adverse experiences myself. I had to pay for the necropsy report, water testing, and investigate the situation myself because I recieved no support for the NFAEP at all. Not one single person from the NFAEP or the Department of Primary Industies (DPI), previously Department of Agriculture and Fisheries bothered to come to my property and discuss my concerns and conduct a thorough investigation into the death of my calves and the ongoing fertility issues experienced in my cattle.
The more I learned about the NFAEP’s current eradication plan, the more concern I had about their eradication strategy, to the point of realisation that the eradication of fire ants is impossible. I reached out to international experts who publicly expressed similar concerns. I have even had internal NFAEP scientists, employees and former staff reach out with similar concerns and expressed moral support, without publicly speaking out.
My clients, both of Amber Resolve and Australian Advocacy Group, have expressed that their fundamental human rights, documented in the Universal Declaration of Human Rights and the Queensland Human Right Act are essential to their overall health and wellbeing and have instructed me to do what I can to to communicate this with the decision makers and protect them from having their fundamental human rights breached in any way that I can.
https://www.legislation.qld.gov.au/view/html/inforce/current/act-2019-005
Human Rights
The NFAEP has opening expressed in government and official letters and standard operating procedures that they have deemed human rights as a secondary consideration to the current fire ant eradication 2023-2027 strategy.
As a public entity, the Department of Primary Industries (Department) is required to act and make decisions in a way that is compatible with human rights as per section 58(1)(a) of the Human Rights Act 2019 (Qld) (HRA).
Further, when making decisions, the Department must give proper consideration to a human right that is relevant to the decision (section 58(1)(b) HRA.
The following human rights (along with others) under the Qld Human Right Act (HRA) could be relevant:
- Property rights (section 24): QHRC: Property Rights
- Right to privacy and reputation (section 25): QHRC : Right to privacy and reputation
Human rights can be limited because the HRA does not give absolute rights. Instead, the HRA provides that rights may be subject to reasonable limits that can be demonstrably justifiable in a free and democratic society based on human dignity, equality and freedom: section 13(1) of the HRA.
The Department and NFAEP argue that the risks posed by not eradicating fire ants outweigh the relevant rights under the HRA, and therefore consider it reasonable to limit human rights in the endevour to eradicate fire ants.
Australian Advocacy Group completly oppose this assessment. Our members believe and we advoacte for more weight on individual human rights and more transparency on the evidence used to deny human rights. Ultimately, we believe the process and the name of the person who decides to strip Queenslanders of their basic human rights should be made public.
The argument of fire ant eradication to deny basic human rights is not valid because the eradication of fire ants is impossible, many experts agree and have made public statements about this. The time (30-40 years) and distribution (700 thousand hectares [7000 km sq]) creates a situation where it is impossible to eradicate fire ants.
This paper (below) gives confidence in discussing the actual (in)effectiveness of baits. These results are very similar to results reported elsewhere for actual control rates of fire ants using toxic baits and other pesticide application methods in combination.
In summary, they baited and used dusts to control fire ants in an orchard agroecosystem with a highly reduced ant fauna (very few species) that is almost entirely exotic (no native species present). A number of the species there do not generally pick up cornmeal-based broadcast baits (e.g. Tapinoma and Paratrechina generally only recruit to sweet baits), so it is not surprising that there was not a lot of evidence for declines of other ants. So, even in this favorable environment, where pretty much only fire ants are picking up the baits, they were only able to achieve around 70% controls. They cite a number of other studies in China that show similar outcomes including repeated baiting trials (a “four-step” treatment protocol) that gets over 90% control. What is left unsaid, however, is that these baiting protocols that use multiple baiting and pesticide application techniques (they are actually using a broader approach than the baiting only approach in Australia) can never reach 100% control. Thus, as is the case everywhere else that fire ants have invaded, without 100% control, eradication is no feasible if the populations get too large, because pesticides alone will not get to 100% control. Furthermore, there is nothing said about what happens once the pesticide application stops. That is, the fire ants come back, often in higher numbers than before.
The authors also took a strange swipe at hot water having “negative impacts on biota” and cite two papers that have no evidence of that in the introduction, so I’m assuming these authors are very pro-pesticide. Yet, their results reinforce the reality that pesticide management of fire ants cannot provide 100% control, even in a circumstance where that might be possible. So, it is not just concerns about whether or not the baits may reduce the native fauna, it is also that baiting in Australia would have to provide 100% control for the eradication effort to succeed and I doubt that they can report those results from anywhere in the management or prophylactic zones, unfortunately.
Australian Advocacy Group would also like to highlight the right to make a human rights complaint to the Queensland Human Rights Commission. You should note that even if you can establish that the Department acted in a manner which was not compatible with your human rights, human rights complaints under the HR Act are limited to the QHRC conciliation process and if not resolved, end there. This process could take over 12 months to be heard.
I have been able to prevent the NFAEP from entering and treating my private property since I learned about the harm their poisonous, toxic chemcial distribution is causing my animals in July 2024. This includes the fact that my property was not treated in Spring 2024 or Summer 2024/25 and I have a current tacit agreement with the program that I have a reasonable excuse and am on a do not treat register. If my excuse is considered reasonable than everyone could be deemed to have a reasonable excuse.
In addition, I have become aware of dozens of properties that have been excluded from the program due to the agressive (threatening) defence of private property rights. There is an occupational health and safety obligation that NFAEP are required to consider and have ignored treatment on these properties, adding stength to the eradication is impossible statement. I wrote about this in a post in October on LinkedIn and subsequently on Facebook.
https://www.facebook.com/share/p/1H5fwGvPQB
‘Wieambilla Can Happen Again’ – Cut and Paste text version of the paste.
Reckless, irresponsible distribution of poisonous, toxic chemcials by the NFAEP is wrong. It causes harm to the overall health and wellbeing of humans, environment, ecosystems, and non-target species. There is no Australian research to demonstrate the adverse effects experienced by fire ants outweigh the adverse effects experienced from prophylactic toxic chemical distribution. I have written 100’s of letters to members of parliment and different departments and have continually being ignored, resulting in more extreme campaign measures to get heard and to initiate change.
These measures and my Wieambilla Can Happen Again article of concern has been weaponised against me in an atempt to minimise my concerns and continue to ignore me by placing my on a nuisence register and officially ignored by the NFAEP and the DPI.
The NFAEP has a dely, deny and discredit anyone who has an opposing view to them and doesn’t like the broadscale distribution of toxic chemcials over the environment.
The NFAEP and by default DPI (QLD) and (federal) The Department of Agriculture, Fisheries and Forestry have not only failed to listen to me and the people I represent. They are attempting to silence my concerns by labeling me as a nuisance client and in doing so are further discriminating themselves as the bullies I am portraying them as. They continue to breach the the very Act they pretend to operate under, in particular,
Biosecurity Act 2014, Chapter 1, Part 3, Section 12, which states: ‘Community involvement in administration of Act This Act is to be administered, as far as practicable, in Consultation with and having regard to the views and interests Of, public sector entities, local governments, industry, Aborigines and Torres Strait Islanders under Aboriginal tradition and Island custom, interested groups and persons and the community generally’.
In addition, by not accepting advocacy for my clients breaching Disability Services Act 2006 – Section 31 to deny advocacy.
Raising and resolving grievances
https://classic.austlii.edu.au/…/dsa2006213/s31.html
and the Anti-Discrimination Act 1991 –
Section 46 – Discrimination in goods and services area
https://classic.austlii.edu.au/…/con…/aa1991204/s46.html
I am advocing for my clients to be put on a ‘Do Not Treat List’, based on their (individual and detailed circumstance) reasonable excuse to obstruct the designated officer, or another person or a detection animal helping a designated officer entering the private property, as is their right, as detailed in the Biosecurity Act 2014 (Queensland), Section 336 Obstructing a designated officer.
The NFAEP will do anything to stop my from assisting my clients, including discrediting me, to excercise their rights to stand up for their beliefs and to protect their fundamental human and property rights.
In complete contrast, I will do anything to protect the communities fundamental human and property rights and continue to advocate for better outcomes for my clients and the community at large.
And so the STAND OFF continues…….will the arrogence of the decision makers cease empowering a choice to meet their obligation to engage in productive, meaningful conversations with the community or will they cointinue their bullying, threatening and coresive control strategies to continue their poisonous, toxic chemical, regime?
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