Tree Health and Plant Biosecurity

Written evidence submitted by the NFU

The NFU represents more than 55,000 farming members in England and Wales many of whom manage small woodland areas and hedgerow trees. In addition we have 40,000 countryside members with an interest in farming and the country. The NFU welcomes the opportunity to make a submission to the Environment, Food and Rural Affairs Committee’s tree health and plant biosecurity inquiry.

Executive summary

· The NFU aims to base its policy on sound scientific evidence and supports a risk-based approach to regulation.

· Plant health biosecurity measurers should focus on minimising the risk of entry into the UK of new plant health threats as the highest priority for food security.

· Deregulation should be considered if eradication measurers prove ineffective and pest establishes itself in the UK.

· Some plant health threats can be clearly identified and good preparation is possible through horizon scanning and preparatory planning.

· Horizon scanning and preparation has been inadequate for Chalara fraxinea.

· Long term investment in research and support services may be inadequate to manage the threat to plant health biosecurity, compromising food security and protection of native tree species.

· The current EU plant health regime is under review, but possible changes under consideration to the regime to close loop holes, will not be implemented for some years leaving threats unchecked.

· UK plant health biosecurity maybe improved by government support for voluntary approaches and incentives that encourage UK production over importation in high risk situations.

Introductory comments

1. The threat of Harmful Quarantine Organisms (HQO’s) to food security and native tree species is a significant concern for the NFU. New plant health have the potential to cause significant financial loss, for instance in 2007 the financial impact of Phytophthora ramorum was estimated at £2 million (Waage et al, 2007) [1] . With many horticultural businesses suffering tens of thousands of pounds in lost sales and one specialist business being forced to close.

2. The NFU represents the interests of the agricultural production industry in plant health as a member of Fera Plant Health Forum. The NFU also represents the interest of woodland owners through participation in Forestry Commission working groups.

3. Plant health biosecurity measurers should focus on minimising the risk of entry into the UK of new plant health threats as the highest priority for food security supported by a rapid response control strategy should a HQO be identified in the UK. However this must be balanced with a pragmatic approach if a HQO becomes established in the UK. At which point regulatory controls aimed at slowing progress may represent a poor return in terms of cost of benefit analysis and deregulation would be a preferable approach for the production industry, which will then look to manage pests at economic thresholds not regulatory quarantine thresholds.

4. Whilst the Efra inquiry focuses on the threat from diseases and pathogens. The threat from insect pests such as Thaumetopoea processionea (Oak Processionary Moth) and Drosophila suzukii (Spotted Wing Drosophila) a major pest of soft fruit is comparable to the disease threat in certain plant and tree species. In many cases there is a direct association between the two threats as insect pests act as vectors for plant diseases/pathogens.

Contingency planning and preparation

5. Some plant health threat to the UK such as Chalara fraxinea can potentially be predicted based on their progression of spread. This is why concerns were raised by Horticultural Trades Association in a formal letter on the 15 September 2009. Despite this a rapid risk assessment was only undertaken in October 2012 [2] with a view to producing a detailed Pest Risk Analysis (PRA). Given the identified risk a PRA should have already been available as a matter of preparedness, a need which could have been identified as part of an annual review of contingency planning between 2009 and 2012.

6. Data available from forestry/horticultural industry experience, foreign plant health service surveys and international research on Chalara fraxinea, could have formed the basis of a case for setting up a pest free zone in the UK. This could have pre-empted the controls now undertaken for entry into the UK of ash plants and materials under emergency measures which may have afforded greater protection to the UK. It is clear this information has been available for a number of years and formed the basis of the Horticultural Trade Association formal approach to Defra and Forestry Commission in 2009.

7. The rapid risk assessment produced in October 2012 acknowledged that control methods exists to manage Chalara in other tree species, however no assessment had been made in species of Ash. The assessment of suitable control method is important in effective planning, and it is unclear why the opportunities for control had not been further investigated to assess viability to facilitate early intervention.

8. In December 2012 the horticultural industry called for a voluntary ban on the import of Chestnut because of concerns over Cryphonectria parasitica (Chestnut Blight). Industry has taken the lead on this threat, but Defra horizon scanning should have identify the threat, assessed the risk and develop a strategic approach. The industry has demonstrated in both this case and with Chalara fraxinea a greater awareness of plant health threats than Defra and a willingness to act to protect UK plant biosecurity. Greater involvement of industry in assessing plant health threats and suitable control strategies, with government support for voluntary measures could further improve plant biosecurity in the UK. Another example of industry inclusion in identifying risk, is the recent legislation that came into force on 7th December 2012 focused on the risk of bacterial disease Ring Rot from Polish produced seed and ware potatoes, following calls by the NFU and other industry bodies for reassurance from Fera the UK’s plant health status of potato’s is not jeopardised as a result of increased imports.

Research

9. There has long been a concern that funding into applied sciences within the food industry has declined since the 1980’s with a higher proportion of funding now allocated to research into fundamental biology [3] . Resultantly the availability of expertise and research into plant health threats has been depleted. It was clear during the Chalara fraxinea outbreak that limited expertise was available to provide necessary guidance on control options. This is in contrast with the work at the Institute for Animal Health (IAH) on the bluetongue virus (BTV). In 2007, the direct cost of bluetongue in northern Europe was over £95 million. When it hit the UK, world-leading expertise was in place in this country to diagnose the disease and advise Government and industry on ways to manage it through vaccination. This highlighting the value of long term investment into on-going applied research to maintain a research base to support food security and environmental protection.

10. Investment in preparation and monitoring services are critical to effective biosecurity. Whilst plant health import inspections services are well established it is unclear to what degree plant health services utilise monitoring and modelling techniques to assess and predict transmission routes. One such route for disease transmission monitoring is through air borne spores as demonstrated by Chalara fraxinea, using the example of BTV for comparison, IAH scientist’s monitored populations of the midge species that transmit bluetongue as they spread north. Modelling and satellite imagery predicted the distribution of the midge and thereby the disease itself, demonstrating that warming of Europe’s climate was shown to drive BTV transmission through the range of insects able to transmit BTV, and in collaboration with the meteorological office, IAH identified the winds that the midges travel on to predict when and where disease would hit the UK, as it did in August 2007.

11. Pesticide control options for plant health threats have been depleted by over 70% since the early 1990’s as a result of the plant protection products directives 91/414 and 1107/2009. With few replacement products available, this has limited control options for endemic pests and diseases but also limited options for control of new threats. Furthermore the limited range of control options also increases the pressure for resistance development across all European Member States, so that pests that spread from mainland Europe may already have developed some resistance within their populations before reaching the UK.

12. In addition to reduced availability of plant protection products the UK Research and development funding into alternatives to pesticides to manage plant health threats has halved since 2005 [4] this includes development of resistance, biological controls and alternative management practices. The depletion of plant protection products and lack of investment in applied research into alternatives compromises the resilience of UK food production to plant health threats and overall compromises food security and the ability to protect native species.

The EU Plant Health Regime (PHR)

13. The EU PHR was reviewed in 2010 and is currently undergoing revision with a new draft text expected in March 2013. The review of the PHR highlighted a range of concerns about the effectiveness of the current regime some of which will hopefully be addressed in the revised draft. However implementation of any changes to the PHR are unlikely to occur until 2016 at the earliest, so a number of the current threats to biosecurity and food safety will remain unchecked in the foreseeable future.

14. Control of plant health threats within the EU is heavily dependent upon the efforts of other Member States (MS) within the Union. It is notable that responses to threats by MS are not comparable, for example Phytophthora ramorum has been strongly managed in the UK, whilst in other MS limited control options have been implemented. Within the PHR the weakest link principle applies and if other MS fail to control the spread of harmful organisms or operate effective import controls this limits the UK ability to protect its borders. The only regulatory recourse then available is to implement Protected Zones (PZ), which must be agreed by other MS, this can be time consuming dependent upon the level of proof required, whilst over implementation of PZ could be seen as restrictive to trade. Voluntary approaches may be an alternative in some cases but these may require government support to be effective.

15. With regards to clear regulatory loop holes the major threats come from 1) New developing trades from outside the EU 2) Packaging materials (associated pests Asian Longhorn Beetle and Pine Wood Nematode). 3) Lack of control on baggage entering the EU containing plant materials. Currently the PHR does not provide adequate flexibility to limit the risk of these threats before they enter the UK. The experience with Asian Longhorned Beetle (Anoplophora glabripennis and Anoplophora chinensis) in wood packaging illustrates the risk of possible contamination before entry in the EU and also the risk when moved with the EU. The pest is a threat to trees and shrubs including maple, poplar, willow and elm. Larvae may be imported on wood packaging and can remain undetected in the wood for up to 3 years making it particularly difficult to control without thorough inspection and opening of packaging, as a result wood packaging must now be treated to eliminate risk of infestation.

16. The PHR inflexibility can impede the potential for speedy import controls, so alternative instruments could be considered such as incentive that move production practices away from imports in high risk situations. For instance the woodland grant scheme has been heavily criticised as the main reason for increasing European trade in ash. The scheme was set up on an annual basis so dis-incentivised the setup of UK nurseries because there were no guarantees of a market for planting that would be ready in 2 or 3 years.

January 2013