Environment, Food and Rural Affairs CommitteeWritten evidence submitted by the National Trust
1. The National Trust welcomes the Committee’s inquiry into this issue, and the opportunity to contribute evidence. As custodians of 200 gardens and parks, national retailers and purchasers of plants, and manager of over 25,500 ha of woodland, plant and tree health is vitally important to us. It is likely that we have more ash trees on our land than any other organisation in Europe, and we are therefore deeply concerned by ash dieback. As well severely damaging our gardens, parks and woods it will irreversibly change many of the beautiful landscapes we protect. We have also estimated that if this disease is now allowed to spread across the country it will result in additional costs to the National Trust of around £15 million over the next decade.
2. Our evidence is in three parts, focused on the questions raised in the Terms of Reference:
A review of the way in which the Government has handled ash dieback, as a way of assessing the adequacy of tree health measures.
Recommendations on the improvements needed to the plant health regime based on our experience with ash dieback and longer experience with other tree and plant health issues.
An annex giving some more detail on the implications of ash dieback for the Trust.
Our Key Recommendations
Our overall view is that the Government’s handling of ash dieback has revealed many deficiencies in the plant health regime, and furthermore that the Governments response has been “too little, too late”.
Our key recommendations for improving this are to:
(1)
(2)
(3)
(4)
(5)
(6)
Reflections on the Handling of Ash Dieback
Identifying new threats
3. The first and most fundamental failing was that none of the Government agencies took sufficient notice of the spread of ash dieback across Europe. The report from FRAXBACK an EU COST action1 meeting revealed that almost every other country in Europe had been observing, managing and researching this disease, for up to 10 years.
As a result we missed a very good chance to prevent this disease entering Britain, and instead sanctioned the ongoing trade of infected plants into Britain.
Roles of public agencies
4. We appreciate there was a huge rush to address to disease in the autumn, and the speed with which the survey was organised was impressive. But having so many agencies involved has added significantly to the complexity:
It has not been at all clear which aspects Defra, the FC and FERA were leading on (eg the silvicultural advice on managing ash dieback was being drafted rather independently of the emerging Action Plan).
The recent move to transfer part of the FERA team to Defra may have made sense to Government, but has added to the confusion.
Even within the FC the roles of FC-GB, the devolved Forest Services in each country and Forest Research have not been clear.
NE, JNCC and CCW seem to have joined in rather late, and this appears to be a reason for the ecological aspects being under played and “bolted on”.
5. We were very troubled that the drafts of the guidance on managing the disease from the FC-GB played down the economic importance of ash timber. This felt like a Scottish perspective, as ash is one of our valuable and saleable hardwoods and important to woodland owners right across England and Wales.
The international plant health regime
6. There is significant bureaucracy associated with the European Plant Health regime and plant passports in particular, and yet this totally failed to restrict the movement of infected trees across Europe. As evidence on this, the Polish Forest Service admitted that it stopped buying ash transplants from Polish nurseries it knew were infected over 8 years ago, but still these nurseries were growing on trees and sending them back (infected) to Britain.
7. It appears that academic debate about the identification and nomenclature of the disease held up concerted action to prevent its spread, whereas it was clear that a new disease syndrome with a pattern of symptoms was spreading. Similarly the need for a consultation period before any controls could be imposed led to an absurd delay in stopping imports of infected ash trees.
Responses to an outbreak
8. Once the disease was confirmed in Britain, some impressive and rapid action was taken by the FC and FERA, such as the ban on moving ash plants, the “tracing” of infected young stock and the rapid survey of ash trees. But we are dismayed that there appears to be no follow-up survey planned around infected sites, to learn more about the pattern of infection. At these sites we still do not know if the infection is limited to a small group of trees or spread across the wider countryside. A good understanding of this is fundamental to understanding its epidemiology and in turn identifying possible control measures.
We are equally dismayed to see the “trace forward” of infected trees seems to be losing momentum, and the agencies’ commitment to reducing the rate of spread of the disease seems to be weakening.
9. We understand that concern over resources is one reason. It feels very wrong to be limiting the response to this disease in order to save a relatively small amount of public funding. Given that the reason this disease is established is due to a failure of these public bodies we believe there is a moral imperative on the Government to do all it can to limit the cost to other landowners, the damage to our environment and loss of our heritage.
Research
10. We are troubled that the FC and FERA have not initiated and funded a wide ranging research programme to investigate the various possibilities for combating this disease. Many different “leads” have been identified across Europe, (such as leaf collection/treatment, competitor fungi, mycoviruses and fungicides) and we need these to be followed up urgently through collaboration across Europe.
11. There has been a lot of focus on breeding resistant trees, which is important but in danger of being a distraction from the much more urgent task of researching ways of reducing the rate of spread and increasing the resilience of existing trees.
Working with stakeholders
12. The Core Group and Outbreak Management Group have provided good opportunities for FC, FERA and Defra to tell us what is going on. Events such as the Ministerial Summit in November and teleconferences held by the FC were welcome initiatives. But these didn’t really offer good opportunities for dialogue and felt rather “one way” communication. In general the governance and stakeholder groups do seem to have been over-complicated but under-effective.
Recommendations on Wider Plant Health Regime
International controls and emerging threats
13. The current plant health regime is flawed in that import inspections only look for a limited number of known organisms, and are not structured to identify any new threats. We recognise that large consignments of plants or plant material are often only inspected at UK points of destination and then only 2% of the whole consignment is inspected. Given the enormous risk from international trade in biomass and hard landscape materials it is vital that this is brought within the inspection regime.
14. We believe that more rigorous inspection at origin/source may prove a better and more cost effective option than trying to detect at point of entry. This will require establishing clear inspection procedures (3rd party) that must be enforced and require more a robust evidence provided before entry into EC. Introducing quarantine at source may also be a more effective and practical solution. Increasing quarantine times at destination may also be a solution especially when combined with a more robust series of biosecurity measures at these destination points.
15. Much better cooperation is needed between inspectorates dealing with related issues in member countries within the EC. We also call for much better horizon scanning and more open and rapid sharing of concerns internationally, and particularly within Europe.
Preventing Entry of Pests and Diseases
16. The EU plant health regime needs to improve its risk targeting. Plants imported for planting are the biggest risk to our natural environment, and a shift of inspection effort from plant produce to plants and propagating material is needed. The UK authorities are also required to spend too much time inspecting trade for organisms that are highly unlikely to impact on our own natural environment, leaving not enough time for inspecting for organisms that do constitute a real threat.
17. What is defined as a pest in one place may not be a pest elsewhere. We believe that more national flexibility is needed so that a member state can make decisions based on what they consider a threat to their particular environment/trade. A Member State should be able to apply for a temporary Protected Zone status as soon as threat is identified. This would give a more responsive approach as new threats/impacts emerge—instead of the delay incurred with ash dieback.
18. Agreeing the identification and scientific naming of new harmful organisms can be an impediment to co-ordinated action. This obstruction must be addressed so that controls can be based on symptoms and syndromes rather than causative agents. We would fully support the introduction of post- entry quarantine for known high risk harmful organisms which cannot be detected visibly or within the timeframe of normal import procedures.
Plant passports
19. It is clear from ash dieback that we need a robust and efficient system for tracing wholesale plant sales and this must be rigorously enforced, to enable the movement of infected plants to be traced after any outbreak. This should be achieved via the plant passporting scheme.
20. We believe that the Plant Passport system should be enforced through stronger regulation, with the power and willingness to penalise breaches (eg lack of labelling to protect trade or re-labelling stock to mask country of origin). The Plant Passport system should enable full traceability of infestations/outbreaks so investigation of breaches can be conducted to prevent similar situations occurring. Biosecurity breaches in other countries or states will put others at enhanced risk and we believe an open reporting of any breaches must be part of the scheme.
21. To ensure that the full range of vectors for plant disease are covered it is our view that the Plant Passport system should extend to include all plants. We also strongly support the introduction of a single fully harmonised labelling system that is applicable to all plants and plant products.
Preventing Spread
22. It is very important that the scope of any new regime includes sufficient measures to prevent natural spread occurring once a harmful organism is found. With Phytophthora ramorum it appears that a small window of opportunity was missed that may have offered options to prevent the large scale spread we are now dealing with.
It now appears that the Phytophthora programme had very limited success and failed to prevent widespread spread via a tree host even though £25 million was allocated towards preventing spread.
23. We need greater clarity and decisiveness about which harmful organisms we have to accept as naturally spreading and which we are going to attempt to prevent entering. That is, be very clear on whether we are trying to prevent entry, eradicate, reduce rate of spread or accept natural spread?
24. A more flexible approach is needed to extending and creating new management zones restricting plant movement in areas where there have been new outbreaks of pests or diseases.
25. We need more recognition of the risk posed to wildlife, heritage, gardens or the environment rather than just crops.
Research
26. We believe that a total costing of impacts of plant disease outbreaks would reveal that funding R&D in this area is an economic imperative. Research must be adequately funded to improve our understanding, improve the effectiveness of our actions and preventing wider costs to both the plant trade and the wider environment.
27. We believe that the competent bodies should strive for stronger coordination of research projects across the EU, and more effective sharing of proposals, progress and early results.
Stakeholder Liaison and Biosecurity
28. We believe that the structure of stakeholder liaison groups needs to be simpler and clearer. These should be stakeholder led and facilitated and supported by Plant Health agencies.
Wider Economic Impacts
29. Currently, the direct and indirect costs of an outbreak are typically borne by innocent parties, with those responsible often not bearing any cost. We would like to see a much fairer system. It seems sensible to use existing schemes such as the “Mutual Fund” to enable compensation payments to be made to those suffering economic losses from a plant disease. At present only agriculture attracts such a mechanism.
30. One small way of sharing costs with those enhancing the risk is for inspections at origin could be co-financed by importers of high risk items—such as species of plants known to be liable to infection or new trade.
31. Any new plant health regime should recognise and include tourism and heritage as a key element in any risk protection and mitigation measures.
Public Awareness of Plant Health
32. A campaign is needed to raise public awareness of and the risk to gardens, crops and the wider environment and the role they play as customers. There are many lessons we can learn from New Zealand in the way public messages are communicated. We feel that changing perceptions will provide one of the biggest gains when dealing with new plant health threats.
33. As part of this we would like to see a review and clarification of the current regulations and controls surrounding the plant and plant material allowance in personal baggage at ports within the EU.
Annex A
THE IMPLICATIONS OF ASH DIEBACK FOR THE NATIONAL TRUST
(A) The National Trust is a leading conservation charity, with a core purpose of protecting special places, for everyone, forever. The land we own extends to over 270,000 ha of countryside and includes 25,500 ha of woodland. Our open spaces are highly valued and attract more than 100 million visits per year. We are also responsible for many hundreds of gardens and parks of historic or cultural significance, as well a diversity of landscapes rich in their diversity of wildlife.
(B) This scale of ownership means that the National Trust is major enterprise, with a turnover close to £500 million, some 5,500 employees, over 60,000 volunteers and a membership of c. 4 million. We typically harvest and market 15,000–20,000 cubic metres of timber and woodfuel each year from our woodland, with an increasing amount used as woodfuel in the many boilers we have installed in our properties.
(C) The National Trust also retails plants through plant stalls at National Trust properties, and we also propagate some plants for use in our own gardens, woodlands and landscapes as well as for retail sale. In response to the threat from Phytophthora to our garden plant collections we recently established our own plant conservation centre to safeguard plant collections and our genetic assets.
(D) The health of plants and trees is thus fundamentally important to our charitable purposes, our commercial enterprises and our conservation work. We therefore have a very strong interest in plant health policy, controls and practices, and considerable experience of working within the plant health regime. As a reflection of the importance of the issue to us several years ago we appointed our own in-house plant health specialist.
(E) The most recent tree health issues we have faced are Phytophthora, acute oak decline and ash dieback. We estimate that dealing with Phytophthora alone has cost the Trust around £1 million pounds over the last five years. If ash dieback is allowed to spread across the country we anticipate the following main impacts:
Loss of an important component of our native woodland, and we estimate constitutes around a quarter of the canopy of the 25,000 ha of woodland we own
Threat to the thousands of ancient ash trees in our parkland, woodland and wider estate, which are historic features, natural sculptures, rich wildlife habitats and refuges for many rare species.
Loss of the hundreds of thousands of hedgerow and field trees, giving irreversible change in many landscapes where ash is a characteristic feature.
Reduction in the growth of ash timber of around 20,000 cubic metres per annum from our woodland.
A huge increase in tree surgery needed to ensure public safety.
Major investment in replanting to replace lost ash trees in gardens, parkland, hedgerows and in woodland.
(F) We cannot put a figure on the environmental and heritage cost of losing our ash trees. But we have made an initial estimate of the economic costs of managing this disease. These calculations indicate a figure of £1.5 million per annum, recurring for at least the next 10 years. This would total £15 million, and finding this funding will mean reducing other conservation work and acquisitions by the Trust. We are very aware that if the plant health regime had been more robust this devastating cost would have been avoided.
January 2013
1 See: www.fraxback.eu