Tree Health and Plant Biosecurity

Written evidence submitted by The Woodland Trust

Introduction

The Woodland Trust welcomes the Committee’s interest in this most important subject, and the opportunity to submit evidence. The Trust owns and manages 1200 woodland sites across the UK, and advises other landowners on woodland restoration and creation. The organisation is represented on the UK Biosecurity Programme Board and Chalara fraxinea Outbreak Management Team. Where referenced, views in this response draw on published evidence; otherwise they are based on our experience as a woodland owner and manager, and stakeholder in plant health matters.

Overview of evidence submitted

- The Chalara crisis indicates current systems and protocols (national and international) are inadequate to prevent the importation of new pests and diseases that pose major threats to trees and forests in the UK.

- Within the UK, capacity to deal with the issue is inadequate, particularly if we are faced with multiple outbreaks of different pests and diseases, which could result in a "firefighting" approach, drawing resources away from essential horizon scanning, research and development. Already funding has been diverted from wider biodiversity and ecosystem research due to resource constraints in forestry research.

- There are some grey areas in definition of roles and responsibilities of different agencies in terms of surveillance, horizon scanning etc. There are no clear protocols over ensuring appropriate stakeholder involvement in outbreak management teams, and a certain lack of accountability and clarity over lines of responsibility. Conservation interests are not well represented.

- Improvements could be made in UK systems, but the issue also needs addressing at EU and international level, where the presumption in favour of trade and inadequate assessment of wider social, environmental and economic costs are real barriers. It is not clear how far the EU Plant Health Regime review currently underway will be able to resolve these issues. The current system places unfair burdens on landowners and managers in terms of dealing with outbreaks.

Detailed evidence

1. Are the roles and responsibilities of public agencies for monitoring incidences of plant and tree diseases or pests sufficiently clearly defined?

1.1 FERA and Forestry Commission (FC) appear to work well together, but in some areas boundaries are not clear. FERA deals with the nursery trade, while FC has responsibility for "forest trees", but it is unclear who is responsible for tracing nursery stock to planting sites. This could have led to insufficient checks on tree nurseries in recent years.

1.2 FC inspects timber and timber product imports while FERA inspects plant imports: it is unclear where forestry plants sit and to what extent inspections of these are made at ports and borders, rather than later when they are in nurseries.

1.3 Urban and non-forestry trees are a grey area; in particular, the landscaping sector does not seem to be well covered at all by plant health monitoring structures, yet this is a high risk area.

1.4 There does not seem to be a clear remit for horizon scanning for plant health threats parallel to the group that plays this role in animal health. This function is not really fulfilled by the Biosecurity Programme Board, possibly due to lack of resources and coordination. At European level it is carried out by EPPO, but there does not appear to be a clear protocol for following through in the UK.

1.5 Devolution adds further complexity. As pest and diseases do not respect borders the Woodland Trust feels there is a need to ensure that there is the will and capacity for a UK-level approach to be taken on these matters when appropriate and it is not clear that this will be the case going forward.

1.6 The plethora of agencies involved may be confusing to the public and could discourage reporting of disease; the sector needs to work collaboratively to ensure people have a single contact point for reporting – the proposed ObservaTREE project may enable this.

2.Are Defra, FC and FERA contingency plans for managing a disease outbreak, such as Chalara fraxinea, adequate and appropriate to control its spread and mitigate the impacts of the disease?

2.1 Capacity is the issue rather than details of the contingency plans. Response to specific outbreaks is relatively efficient, but the risk is that when these occur simultaneously, the agencies involved will be unable to act effectively. More resources are needed to deal with outbreak management. A pool of trained and available contractors and surveyors, including volunteers, would enable a more flexible response. With a growing list of threats there is an increased likelihood that existing modest resources become fully committed in the short term, with no ‘reserve’ to maintain vigilance or mount additional responses in the face of additional threats.

2.2 Better horizon scanning and sharing of intelligence from abroad could enable agencies to be better prepared to produce plans and decide on action quickly.

2.3 A protocol is needed for appointment of Outbreak Management Teams to ensure they have the right specialist knowledge and stakeholder representation. For example, given the human health risks posed by a pest such as Oak Processionary Moth, it would have been appropriate for the relevant Outbreak Management Team to include a public health representative at the outset.

2.4 It is also unclear who is ultimately responsible for decisions made by Outbreak Management Teams. Currently these are largely made by FERA or Forestry Commission representatives, but given the serious economic, environmental, and social implications of many tree pests and diseases, there perhaps needs to be a clear line of authority, perhaps from a Chief Plant Health Officer as suggested in the interim report of Professor Ian Boyd’s scientific task force (Tree Health and Plant Biosecurity Taskforce, 2012).

3. How effective is coordination between agencies such as Natural England, the Forestry Commission and FERA?

3.1 The Biosecurity Programme Board, which oversees implementation of the Tree Health Strategy, aims to ensure coordination between those bodies with statutory responsibilities or stakeholder interest. Coordination between the Forestry Commission and FERA seems to be good, but statutory conservation agencies are not very evident, perhaps due to resource constraints, which means the conservation voice is not well represented. The roles and responsibilities of statutory conservation agencies need clarifying; they should be represented on the Biosecurity Programme Board and Outbreak Management Teams, and involved in horizon scanning. They need to develop the skills and staff able to support this area.

3.2 There is a gap around urban trees; Forest Research provides an advisory service but statutory responsibilities lie with local authorities. Urban trees are a critical pathway for pest introductions. Given current constraints on budgets and resources, we are concerned that this is an area of responsibility that could fall between agencies.

4. Are there sufficient resources for research to provide effective evidence on the emergence of new threats to trees and plants and for management of existing threats? Is there sufficient coordination of research effort and does the UK have an adequate pool of the right skills to draw upon?

4.1 Emerging and existing pests and diseases have a real economic cost to the UK; published papers on the broad economic impacts by Pri ce (2010), for example, provide some insight. His estimate of total annual cost of economic losses due to tree diseases (not including Chalara) is nearly £172m, with over £100m represented by landscape consideration s .

4.2 A paper on the economic impacts of invasive species in forests in North America, which included consideration of chestnut blight, also suggested greatest economic impacts are due to loss of non-market values; in particular landscape aesthetics and recreation (Holmes et al, 2009).

4.3 Costs and benefits do not fall evenly. The benefits of trade that may facilitate introduction of pests and diseases fall largely to individuals and businesses, whereas the costs of pest and disease impacts fall to tax payers and society as a whole. In theory policy should shift the balance so that the costs are absorbed by those who also realised the benefits – a polluter-pays-principle.

4.4 Given an ongoing increase in new pests and diseases, and cuts in overall funding for agencies like FC, there is a danger resources are not sufficient for pre-emptive action, management or mitigation. We welcome the Secretary of State’s intention to reprioritise DEFRA resources so that Plant Health has the same emphasis as Animal Health. The scale of the threat from plant pests and diseases should not be underestimated. Compared to the potential costs above, even the addition of £8m over the next four years for the tree health and biosecurity action plan seems small.

4.5 Costs of management fall to land owners and managers who do not have control over introduction of pests and disease; there is currently no compensation available. At the same time the ability of the sector to deliver the ecosystem services and economic benefits required or promoted by government are reduced.

4.6 Resource constraints lead to a "firefighting" approach to dealing with outbreaks to the detriment of other work that in the long term would help build resilience in woodland and wider landscapes by enhancing biodiversity and enabling adaptation to climate change. The Forestry Commission is increasing the proportion of its research budget devoted to tree health, but this is at the expense of spend on other areas, including ecosystems and biodiversity (House of Commons Library, 2012).

4.7 The British Society for Plant Pathology has warned of a shortage of people with skills in this area, and in the capacity of institutions to teach in it (BSPP, 2012).

5. Are sufficient resources being put into developing effective responses to plant health threats such as improving resistance, biocontrols and chemical or management responses.

5.1 Research does not become a priority until a disease becomes a problem, by which time the time to explore options such as genetic research and plant breeding may be limited.

5.2 International cooperation between researchers is invaluable eg the EU FRAXBACK project (FRAXBACK website, 2012), but this needs to be followed through into action.

5.3 Response to pests and diseases must also include building resilience through conservation, restoration and expansion of natural habitats as set out in the Lawton review, and in the cross-sectoral State of the UK’s Forests report (Woodland Trust, 2011), which highlights the need for diversity in forests and landscapes.

6. Does the international regime for trade in plants and the EU plant health framework provide a sufficiently flexible and responsive framework to respond to newly identified pests and diseases or those that are spreading. Can these regimes impede stronger import controls. Are plant health controls sufficiently broad to cover trade in tree and plant products such as biofuels?

6.1 The arrival of Chalara on imported stock shows current systems are inadequate. A key problem is that international protocols begin with assumptions favouring free trade, rather than minimising risks to biodiversity.

6.2 Regulation is through known harmful organisms exempted from this presumption, but Brasier, (2008) sets out the flaws in this system. Diseases are often caused by previously unknown organisms, to which the regulations do not apply. Lists focus on organisms threatening commercial forestry and agricultural crops, rather than looking at social and biodiversity impacts. Countries are allowed to use different standards and methods of inspecting products. There is evidence of breaches of protocol by some exporting countries. These can only be picked up by surveillance in the importing country which relies on visual inspections, usually of a sample, and unable to pick up micro-organisms in soil.

6.3 Within the EU there is free movement of plant material between countries except for the most serious "quarantine" pests, for which plant passports are required for the host material. Border checks are not carried out. Where material is imported into the UK from outside the EU, but via another EU country, we are reliant on the EU ‘transit’ country carrying out adequate checks, yet there is currently no standardisation of surveillance within the EU. The issue of material being moved between countries within the EU to be grown on, or being "rebadged" as of EU origin, is of concern. We welcome the fact that the Secretary of State’s has raised questions over the issue of free trade of plants within Europe.

6.4 While there is a system for recording and notifying buyers of trees as to the provenance of the seed there is no statutory system to allow buyers to see where those trees have been grown and how many nurseries have handled them. Some landowners, the Woodland Trust included, may thus have unwittingly contributed to the import of Chalara to the UK. A "traceability" system should be put in place across the nursery/horticultural sector to tackle this.

6.5 While some of these issues may be addressed through the EU Plant Health Review early in 2013, the EU is still limited by higher level international trade agreements.

6.6 A key problem is unbalanced evaluation of costs. While the international systems around plant health aim not to restrict trade and therefore economic activity, there is no comparable evaluation of the costs – social, economic and environmental – of harmful organisms becoming established in the UK, and as a result no true holding to account of those responsible for breaches of biosecurity.

6.7 Plant health controls can technically cover trade in tree and plant products such as biomass. The European Plant Protection Organisation (EPPO) has produced a Pest Risk Analysis for the bronze birch borer beetle, Agrilus anxius, a species found across North America and known to cause considerable damage to UK’s native birch species. A key risk pathway is through import of wood chip for bioenergy. The PRA sets out phytosanitary measures needed but the issue is ensuring effective compliance with these.

7. What lessons are being learnt in the UK from the management of Chalara dieback of ash in other EU member states?

7.1 In relation to Chalara, there is considerable evidence from 20 years of experience in Europe. The collaborative science research project FRAXBACK ensures information sharing: the UK is a collaborator.

7.2 Even so, early action to reduce the rate of spread or implement mitigation measures was not taken. Lessons should be learnt about cross-European early warning and action to reduce the impact of further emergent infectious diseases and pests.

7.3 Evidence suggests a percentage of trees will be resistant to Chalara. Studies conducted between 2007 and 2009 in Denmark, show a strong genetic variation in susceptibility (McKinney et al, 2012). The UK may be able to learn from this. In most other European countries, ash is a smaller component of the total forest and tree mix so it is more  difficult to extrapolate potential large scale impacts from experience in Europe.

7.4 Analysis suggest most British ash belongs to a single meta-population covering mainland western and central Europe (Sutherland et al, 2010). It might therefore be expected to respond in a similar way to other European ash populations. However three northern and western sites (the Forth and Tay watersheds in eastern Scotland and the Lleyn peninsula in northwest Wales) differ from the dominant population, and may represent remnants of two late potential Ice Age refugia. It is unknown whether the genetic makeup or phenology of these populations will confer any different susceptibility to the disease. There will be a need for UK-specific research into mitigation and adaptation.

References

Brasier, C. (2008)The biosecurity threat to the UK and global environment from international trade in plants. Letters to the editor. Plant Pathology 57, 792-808.

British Society of Plant Pathologists(2012) Audit of plant pathology training and education in the UK . Available at http://www.bspp.org.uk/society/bspp_plant_pathology_audit_2012.php. (Accessed 19 December 2012)

Holmes, T.P., Aukema, J.E., Von Holle, B., Liebold, A., and Sills, E. (2009) Economic Impacts of Invasive Specieis in Forests: past, present and future. The Year in Ecology and Conservation Biology, 2009: Ann. N.Y. Acad. Sci. 1162: pp18-38

House of Commons Library (2012) Ash Dieback Disease: Chalara fraxinea. Standard note SNSC6498. Available at: http://www.parliament.uk/briefing-papers/SN06498. (Accessed 7 January 2013).

Price, C. (2010) Appraising the economic impact of tree diseases in Britain: several shots in the dark, and possibly also in the wrong ball-park? In: Helles, F. And Nielsen, P.S. (eds) (2010) Proceedings of the Biennial Meeting of the Scandinavian Society of Forest Economics. Scandinavian Forest Economics No.43. pp 45-61

FERA 2012 Fera website, Plant health http://www.fera.defra.gov.uk/plants/plantHealth/

Forestry Commission (2011) Protecting Britain’s Forest and Woodland Trees against Pests and Diseases – the Forestry Commission’s Strategy. Annex 2.

FRAXBACK (2012) www.fraxback.eu (accessed 19 December 2012)

Lawton , J.(2010) Making space for nature: a review of England’s wildlife sites and ecological network. Available at http://archive.defra.gov.uk/environment/biodiversity/index.htm. (Accessed 19 December 2012)

McKinney, L.V., Thomsen, I.M., Kjær, E.D. and Nielsen, L.R., (2012) Genetic resistance to Hymenoscyphus pseudoalbidus limits fungal growth and symptom occurrence in Fraxinus excelsior.Forest Pathology 42 pp69–74

Sutherland, B.G., Bejaj,A., Nier, S., Cottrell, J.E., Vaughan, S.P. Hubert, J. And Russell, K. (2010) Molecular biodiversity and population structure in common ash (Fraxinus excelsior L.) in Britain: implications for conservation. Molecular Ecology19, 2196–2211

Tree Health and Plant Biosecurity Expert Taskforce (2012) Interim report. 30 November 2012. Available at http://www.defra.gov.uk/publications/2012/12/06/pb13842-tree-taskforce-interim/. (Accessed 19 December 2012)

Woodland Trust (2011) The State of the UK’s Forests: perspectives from the sector. Woodland Trust.

January 2013