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)
The key issue here is the appropriateness of measures to address the introduction and spread
of HOs in each case and for each sector. While full-scale eradication may be the most
appropriate course of action (depending also on the phase of the outbreak) to effectively
address the introduction and spread of pests in agriculture and horticulture, applying similar
measures in forests and public green may or may not - on balance - have positive effects. For
example, if measures require the large scale felling of trees, this can cause substantial damage
which undermines and is incoherent not only with environmental sustainability objectives but
also with phytosanitary objectives longer term (e.g. weakened habitats accentuate the
potential impacts of new or re-emerging phytosanitary risks). However, this measure may be
deemed necessary for effectively addressing a pest, especially at the early stages of an
outbreak, in which case it serves both phytosanitary and environmental objectives.
The decision on whether or not to proceed to, and in later stages to continue with, any course
of action will depend on consideration of potential costs and benefits (including economic,
environmental and social impacts) of the action against alternatives; this will ultimately
determine the feasibility, but also the acceptability of the action. For example, in the case of
forests and public green, the eradication objective may need to be pursued immediately and at
a sufficient scale to be effective at the start, but may need to be timely replaced by
containment when eradication is no longer feasible but the rest of the EU still requires
protection (e.g. PWN). Failure to implement in a complete and timely manner eradication or
containment measures will threaten the effectiveness of these measures and put at risk the
health of EU forests, with potentially substantial damages for the EU as a whole. On the other
hand, continuation of drastic eradication measures (in particular large scale clear cuts) where
these may no longer be effective can also cause very serious and unnecessary damage to the
environment and biodiversity, particularly in Natura 2000 areas, and their timely replacement
by containment measures is necessary is such cases. Where natural spread is a major factor
and this renders even containment not feasible, deregulation may be inevitable; in such a case,
standard pest management practices including damage threshold levels will apply.
From the very start therefore, deciding on the regulation of such pests requires consideration
of whether the potential impact of the pest warrants quarantine regulation (i.e. requiring
drastic measures for outbreaks), or could be managed with a systemic approach with damage
thresholds (= outside the CPHR). Such decisions need to involve close coordination between
plant health and environment protection policy makers.
In practice, past experience has shown that MS have consistently demanded rapid and strict
action at EU level against certain forest pests (e.g. PWN and Anoplophora), which indicates
the need to be able to address non-EU HOs affecting forests and public green through the
CPHR.
While technically the feasibility of one or another course of action may be unequivocal, the
final decision will depend on political considerations of the need to take action at Commission
level versus MS subsidiarity. Indeed, listing non-EU forestry pests in Annex I.A.I of Directive
2000/29/EC is relatively straightforward if technically justified, but developing binding
contingency plans or emergency measures for outbreaks of such HOs (even more so, control
Food Chain Evaluation Consortium 48