2454 final report.pdf - Agra CEAS Consulting

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Table 3-37: Evaluation of CPHR performance during 1993-2008 – synthesis of findings Policy area Evaluation Question (a) Summary of findings Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) General approach of CPHR and scope: Control of EQ2: Extent to which natural spread the control of natural spread is addressed. IAS Classification of HOs in EQ3: Extent to which IAS are included in scope of the Directive. EQ5: Extent to which the classification of Inclusion of natural spread in CPHR scope: the current legislation is not explicit on ‗natural spread‘ (as opposed to manassisted spread), leading to considerable confusion and divergence in interpretation amongst MS and stakeholders. Natural spread is covered by Directive 2000/29 in Article 16 which requires measures to deal with spread; however, Article 23 explicitly excludes natural spread from eligibility for solidarity funding, and past experience has shown the shortcomings of this approach in 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 not acceptable or if phytosanitary measures are feasible. Therefore, there is need for clarification of CPHR rules on natural spread. The potential longer term effects of climate change on altering patterns of natural spread of HOs in the EU need also to be taken into account. Consequently, options for the explicit inclusion of natural spread in the CPHR are explored further in section 5.1.3. This question also covers the suitability of the CPHR intervention logic for forestry, public green and natural habitats. 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. However, 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), 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 be ultimately political (Commission action vs MS subsidiarity) and need to involve close coordination between plant health and environment protection policy makers. There is currently 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 already listed in the Directive (recent examples including Anoplophora spp., Phytophthora Ramorum, also PWN). 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 therefore extensive calls for clarification of the CPHR on this issue. The potential effects of climate change on altering patterns of alien species invasion in the EU need also to be taken into account. The options for the future regarding the inclusion of IAS in the CPHR are explored further in section 5.1.2. The current approach for listing 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 historical approach of EU MS, therefore reflects MS and EU historic priorities Food Chain Evaluation Consortium 280
Policy area Evaluation Question (a) Summary of findings Directive 2000/29/EC HOs in Directive reflects the objectives of the regime and priorities on phytosanitary risks. Extent to which appropriate information for PRA (pest risk analysis and pest risk management) is available. EQ5(i): The appropriate positioning of RNQPs. CPHR policy areas: Surveillance EQ6: Implementation (intra-EU) of surveillance provisions by MS. Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) on risks. Although the number of listed HOs as such is not an issue for effective management at MS CA level in terms of imports from third countries, there is need for revising the lists (reviewing the approach to Annexes I and II in particular), and for considering 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, sections 5.2 and 5.3 respectively). Additions to the lists of the Directive, on the basis of PRAs, are constrained by current data availability and methodologies and this delays 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 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 in sections 5.2 (prevention at import) and 5.4 (emergency action) respectively. The approach followed for the positioning of Regulated Non Quarantine Pests (RNQPs) is questioned 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). 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, an analysis of options and recommendations on this are provided in section 5.1.4. Surveillance is currently compulsory only in the case of emergency, control measures and 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 (with the notable exception of PWN), leading to varying implementation. Notification of findings is not done within the legal requirements in the great majority of cases; this has hindered the possibility for early action against HOs, and delayed communication of information to CAs and stakeholders. There is agreement on the need to introduce a quicker system for notification of findings and outbreaks (possibly to be developed within current EUROPHYT database). Other (general) surveillance is carried out by some MS for certain HOs, according to MS priorities and following different procedures and <strong>report</strong>ing standards. This affects the extent to which comprehensive information on the spread of HOs on the EU territory is available, thus leading to less effective and efficient eradication measures. The involvement of POs is generally limited, despite the importance of stakeholder involvement in early action. Food Chain Evaluation Consortium 281
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PWN Key host plant(s) Estimated pot
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