2454 final report.pdf - Agra CEAS Consulting

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Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) these new challenges and new risks arising from them as evidenced by increases in solidarity budget spending in recent years, will require the adjustment of the regime for the future. S.3. Key findings of the evaluation per thematic area The results and main findings of the evaluation per thematic area can be <strong>report</strong>ed as follows: 1. Scope of the CPHR Natural spread The extent to which the current CPHR scope includes natural spread was examined with regard to the following two aspects: Inclusion of natural spread in CPHR scope: the current legislation is not explicit on ‗natural spread‘ (as opposed to man-assisted spread), leading to considerable confusion and divergence in interpretation amongst MS and stakeholders. From the review of the CPHR legislation, natural spread is covered by Directive 2000/29 Article 16 which requires measures to deal with spread. Article 23 however explicitly excludes natural spread from eligibility for solidarity funding, and past experience has shown the shortcomings of this approach in terms of effectively targeting pests at the start of an outbreak (e.g. Diabrotica virgifera). Technically, the strong interaction between the natural spread and movement of plants, and the fact that natural spread is an inherent characteristic of any pest, make the distinction of causal effects on plant health questionable; ISPM 2 includes consideration of natural spread where the pest risk is considered unacceptable and the phytosanitary measures are feasible. Therefore, there is need for clarification of the CPHR rules on natural spread. The potential longer term effects of climate change in terms of altering patterns of natural spread of HOs in the EU also need to be taken into account. In view of these conclusions, options for the explicit inclusion of natural spread in the CPHR were developed and explored. Suitability of CPHR intervention logic for forestry, public green and natural habitats: the appropriateness of the CPHR to address the control of HOs in these sectors is an issue which goes beyond the clarification of the provisions on natural spread as such. Principally, the CPHR should continue to provide protection against non-EU HOs in these sectors as is currently already the case, and as is the practice in the plant health legislation of third countries. Deciding on the best course of action in case of outbreaks of regulated non-EU HOs in EU forests, public green or natural habitats (e.g. PWN and Anoplophora), however, requires consideration on a case by case basis of whether the potential impact (economic, environmental and social) of the pest in these sectors continues to warrant drastic measures under quarantine regulation (= CPHR) when initial eradication fails. Such decisions may ultimately be political (Commission action vs MS subsidiarity) and need to involve close coordination between plant health and environment protection policy makers. Invasive Alien Species (IAS) There is currently a lack of common understanding, leading to considerable confusion, on both the definition of Invasive Alien Species (IAS) and the extent to which IAS are covered by the scope of the Directive. The defining characteristic of IAS, according to the CBD definition, is their wider environmental impact on ecosystems. Historically, this has been considered as an indirect impact for the purposes of Directive 2000/29, but in recent years there has been a de facto shift in implementation, due to major pest incursions with significant indirect, non-commercial or purely environmental impacts. In practice, many regulated pests are IAS which are already listed in the Directive (recent examples include Anoplophora spp., Phytophthora Ramorum). There have also been international developments in considering IAS at the level of IPPC and EPPO, and a more general EU strategy on Invasive Species (IS), following the CBD definition, has been developed. There are Food Chain Evaluation Consortium V
Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) therefore extensive calls for clarification of the CPHR on this issue. The potential effects of climate change in terms of altering patterns of alien species invasion in the EU also need to be taken into account. Consequently, options for the future regarding the inclusion of IAS in the CPHR were explored. 2. Approach followed for the classification of HOs The current classification of HOs in Directive 2000/29/EC (several Annexes with lists for which a range of measures are foreseen, 250 HOs in total) is based on the historical approach taken by EU MS and therefore reflects MS and EU historic priorities on risks. Although the number of HOs listed as such is not an issue for effective management at MS CA level in terms of imports from third countries, there is need for revision of the lists (reviewing the approach to Annexes I and II in particular). There is also a need to consider prioritisation of HOs that are of EU-wide concern (e.g. in the context of pathway analysis for import inspections, or for intra-EU surveillance measures); especially as concerns HOs occurring on EU territory. If greater prioritisation is needed, then this could be based on criteria to be developed, and the general survey has already pointed in the direction these could take. The scope for prioritisation is explored further in relation to options for the future to ensure better prevention and to maximise the cost-effectiveness of current measures and resources (in particular for import inspections and for intra-EU surveillance). Additions to the lists of the Directive, on the basis of PRAs, are constrained by current data availability and methodologies and this delays the process for listing new HOs. Longer term, the EU FP7 funded project PRATIQUE is expected to support the development of generic methodologies with a view to improving PRA availability on a systematic basis and more proactively (before risks emerge). In the meantime, the use of expanded fast-track risk analysis to speed up the adoption of measures (particularly in emergency situations), as well as improving cooperation between all bodies currently involved in PRAs (EFSA, EPPO, MS CAs, stakeholders where possible) should be considered. More generally, major limitations of the current approach are found to be the lack of horizon scanning and the lack of efficiency in dealing with emerging risks. Approaches to overcome these issues are explored further under the options for the future (prevention at import and emergency action, respectively). The approach followed for the positioning of Regulated Non Quarantine Pests (RNQPs) was also examined. The question is raised because in the EU, two sets of legislation currently cover the range of regulated pests: the Plant Health Directive 2000/29/EC and the Marketing Directives for Seeds and Plant Propagating Material (S&PM). In conclusion, the results of the evaluation indicate that the major issue of concern is the current overlap between the two sets of legislation rather than inconsistencies, and that a mechanism should be in place to allow careful consideration for transfer of eligible RNQPs between the two sets of Directives. Consequently, options for the appropriate positioning of RNQPs were explored. 3. Implementation of surveillance provisions Surveillance is currently compulsory only in the case of emergency, control measures and Protected Zones (PZs); the degree of application is variable by HOs (systematically undertaken only for potato diseases). Procedures for surveys (including protocols and <strong>report</strong>ing formats) are generally not harmonised at EU level (with the notable exception of PWN), leading to varying implementation. In the great majority of cases notification of findings is not done in conformity with legal requirements. This has hindered the possibility for early action against HOs, and delayed communication of information to CAs and stakeholders. There is therefore agreement on the need to introduce a quicker Food Chain Evaluation Consortium VI
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