2454 final report.pdf - Agra CEAS Consulting

Evaluation of the Community Plant Health Regime: Final Report
DG SANCO Evaluation Framework Contract Lot 3 (Food Chain)
payments) exclusively on ‗man-assisted‘ movement inappropriate and even unsustainable in
the long term.
It is noted that ISPM 2 prescribes pest risk analysis whatever the pathway of pest introduction
or spread, and at the final stage of the PRA (Stage 3: Pest risk management) foresees that
phytosanitary measures are only justified if the pest risk is considered not acceptable and the
measures are feasible (―whether appropriate phytosanitary measures adequate to reduce the
pest risk to an acceptable level are available, cost-effective and feasible‖). This may, on a
case-by-case basis, include measures to address natural spread 51 .
3.1.1.2 Suitability of CPHR intervention logic for forestry, public green and natural habitats
The appropriateness of the current CPHR intervention logic to address the control of HOs in
public green, forests and natural habitats (sub-question of EQ2) is an issue which goes beyond
the debate on whether or not natural spread as such is - or should be explicitly - included in
the scope of the plant health regime. It also concerns, for example, the consideration of
inclusion of invasive alien species (IAS) in the scope of the plant health regime, since IAS
generally impact on the natural environment (see sections 3.1.1.2 and 5.1.2).
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The vast majority of MS CAs consider that, during the last 15 years, the CPHR has only
partly addressed the objective of safeguarding the natural environment, while the damage
caused by natural spread of regulated HOs (listed and non-listed) to forestry and public green
is considered to be high (results to EQ 1.4 of general survey and graph above). The
stakeholders‘ general position, when considering in particular the affected stakeholders in
these sectors, is equally strong.
It appears that, at its origin, the fundamental principles and objectives on which the current
CPHR intervention logic is based are designed for the sectors of agriculture and horticulture.
In practice, in its current legal form, the Directive aims primarily at protecting commercial
products and at acting at all levels to protect these products in trade. For instance, the
protection of maize crops against Diabrotica virgifera virgifera is limited to the perimeter of
the maize field; in the case of PWN, actions outside the affected areas have to be taken to
support the protection of non-affected areas.
Nonetheless, it is also clear that, although the CPHR was originally not intended for forestry
and public green, the regime has always listed pests of potential impact on forests and natural
green. In principle, the overall aim and approach of the regime applies across all sectors:
listing of non-EU HOs prevents their entry into the EU and protects not only agriculture but
also EU forests and natural green against potentially high damages. It is noted that third
countries similarly regulate HOs impacting on forests and public green.
While the overall aim of the regime is the same across all sectors, the selection of appropriate
measures and objectives to ensure this aim can vary between sectors.
51
ISPM 2, PRA Stage 3: ―Phytosanitary measures are not justified if the pest risk is considered acceptable or if
they are not feasible (e.g. as may be the case with natural spread).”
Food Chain Evaluation Consortium 47