Phylloxera – Who Rules?

by Dudley Brown

As The Wine Rules is a blog about the formal and informal rules of the wine industry, the rules regarding the containment of Phylloxera in South Australia should be of great interest to anyone who enjoys knowing what the natural flavors of wine grapes and wine really are. South Australia is the largest remaining un-infested wine region in the world. It is also the home of the oldest wine grape vines and the largest collection of own rooted wine grape vines on our planet because we have never permitted Phylloxera to cross our borders.

The peak body entrusted with ensuring that SA remains Phylloxera free is the Phylloxera and Grape Industry Board of South Australia (PGIBSA). The PGIBSA is currently advocating (very worrisome) relaxed standards regarding the management of this vine killer despite some very significant concerns put by grape growers, particularly in McLaren Vale.

As The Wine Rules has a long and abiding interest in the economic and political arcana of Phylloxera, this process appears to be as much about the intentions and economic motives of some parties (including my desire to see our personal vineyards remain uninfected) as it is about anything else and is worthy of understanding at some depth.

While it is an enormously complex regulatory, scientific and legal issue, this is the most important issue of our time in the wine industry in Australia.

While I have been cautioned against a “wall of words” approach to blogging by many more experienced bloggers and journalists, I can not find one attractive photograph relating to the subject of Phylloxera or the Phylloxera Board to use to break up the text.

Please bear with me on this one, it’s a long one. There is simply no short way through this.

And, if you agree with the import of this blog, please re-post, re-tweet, etc.

Most importantly, if you agree with the sentiment(s) expressed here, please email minister.gago@sa.gov.au with any sort of message suggesting that you do not want to see the risk of Phylloxera spread.

Finally, I am appending MW Drew Noon’s submission to Mr. Nankivell at the bottom of this post for those who wish to understand the intersection of science and law with regard to Phylloxera in Australia. It is compelling stuff.

Philip White at http://drinkster.blogspot.com/ has written a number of compelling articles on this subject.  Search, read and weep….but don’t do nothing.

Below is a copy of my submission regarding this process to the CEO of the Phylloxera Board:

14 October 2012

Dear Mr. Nankivell,

Thank you for the opportunity to comment on your presentation made at the Bocce Club in McLaren Vale the other night.

While I thought we were being asked to comment about the Phylloxera protection rules changes first implemented in 2011 and then reversed by Minister Gago of South Australia in 2012, you made it clear in the last-minute of your presentation that we were present to hear your presentation and to comment on your presentation and not the matter the audience thought was being discussed. What the audience thought you were in McLaren Vale to do was to conduct a public consultation session with wine growing levy payers of the PGIBSA regarding the rule changes of 2011 and the reversal of 2012.

After much deliberation and conversation with others who were present at the meeting, I think I now actually understand what was being presented and why.

In your presentation, you first asked for questions and indicated that you would answer them in your presentation. Some of these questions included “Who was consulted before the rules were changed in 2011?” and “Who benefits from the rule changes?” These questions were never addressed or answered by you in the following 2 1/2 hours. You concluded by telling us that it wasn’t a consultation.

In short, the presentation followed the following format:

You first described the history of the Phylloxera Board (“PGIBSA”) briefly and some rules about not creating trade barriers without scientific support.

You then went on to describe the process used by you and or the PGIBSA to analyze 262 different “risks” to South Australia of Phylloxera infestation. Of these 262, there were five that our community had specifically appealed to the Minister to consider worthy of reversing the rule changes of 2011. Then, at some length, you went on to describe these five as “low” risks.

You then described 10 “high” or “very high” risks that you consider to be of much greater importance than the five aforementioned risks.

You then by fielded questions again. At this point, you either evaded or did not answer numerous questions, engaged in selective amnesia in an exchange with Drew Noon (one of Australia’s first Masters of Wine), etc. Finally, when winegrower Jim Banman asked if there could be a show of hands from the 40-50 winegrowers present, you replied, “You can vote on anything you like, but what would you vote on?” I interjected and said ” Alan, Jim is asking as to whether the audience supports the measures you are consulting us on.” You replied that “this is not a consultation, this is a presentation.” That was when the penny dropped for me anyhow.

Your presentation was a tautology both in format and content. You started with questions and ended by saying why you were there. Your premise or “proposed actions” can only be undertaken if we accept the conclusion that the Minister is currently wrong in her policy stance. Oddly, you blamed BioSecurity SA for the first rule change (denied by Jeff Raven of BioSecurity SA at the meeting) implemented by the Minister and then took credit for the Minister reversing herself. Now you are in the position of suggesting she change her mind again. It was one of the most bizarre and incoherent meetings I have attended in my life.

Having endured two and one half hours of your fulminations and arm waving with the ISO 13000 handbook tightly clenched in your hand, I realized that you were finally speaking plainly. You were not here to consult with us at all. You were here to spend half that time explaining why our fears were unfounded and / or wrong and the other half with how smart and scientific you and the Board is. In a successful sales pitch, first telling the customer they are wrong and then telling them you are right is a sure-fire road to failure.

After the meeting, Robin Nettlebeck, the Chair of the PGIBSA was kind enough to introduce himself after not answering a number of my emails inquiring about the rule changes over the past months. After a bit of a build-up, Robin very awkwardly asked me if “there is something special we can do for McLaren Vale?” Fortunately I had two witnesses to what could only be inferred as an unseemly approach.  Later I discovered Mr. Nettlebeck had also asked one of our leading citizens and winegrowers, John Harvey, the same question. I replied “honestly, my concerns are not for McLaren Vale but for South Australia and Phylloxera Exclusion Zones in other states as we all wish for Phylloxera’s borders to be as far away from us as possible.”

In the following days, I ruminated on your presentation and Mr. Nettlebeck’s unsettling approach.

My conclusions are this:

1) Your risk analysis is fundamentally flawed. While following an ISO approach is a structured and valid approach to risk analysis, the risk of all 262 areas of inquiry is exactly the same – infestation of Phylloxera in the world’s largest germoplasm of un-grafted wine grape vines remaining in the world. A cigarette smoker can smoke three packs per day of cigarettes and never develop emphysema, cancer or have a heart attack. Others can smoke only passively and die of lung cancer. These are variegated risks. Phylloxera is not variegated – it will kill every vine it comes in contact with. Therefore, the only “risk” is infestation. Your analysis can only be properly understood as an assessment of probabilities of infestation and not a risk assessment.

2) As anyone aware of this ISO protocol can attest, the analysis you have conducted is just a starting point for further study and testing and is in no way “definitive” in the conclusions that have been arrived at. The identification of 262 “risks” is very valuable. The ISO method is a process of evaluating subjectively identified risks over time by objectively testing these subjective items with data collection, analysis and experience. Only then can the probability of each “risks” be quantified with any certainty.

However, in my subjective analysis, even then I would rate the certainty level “very low” because, in the absence of an infestation, you will always be trying to prove a negative.  In fact, the only way to really find out which of the risks is highest or lowest, is to do absolutely nothing to stop Phylloxera movement and then figure which of the “risks” actually caused infestation. Then you can be certain. Until then, you have to do the hard work of following the scientific method of data collection and analysis over very long periods of time.

What you chose to not share with us is the methods of data collection and analysis employed to test the various probabilities you graded from low to very high. When one grower requested this information, you replied that you could not share it because “it is open to misinterpretation.” Is it open to misinterpretation because it does not exist or because it might not support your argument? Or, are you the only person capable of understanding these risk factors and assessing them? Are there any other options for us to consider as to why you will not share this information?

3) The PGIBSA operates in a culture of secrecy and stand-over tactics. When I was the Chairman of the McLaren Vale Grape Wine and Tourism Association, from 2008-2010, we conducted the first Phylloxera Outbreak Planning Scenario workshop conducted in South Australia with the Phylloxera Board. This is the sort of extension work that really engages growers and is one of the reasons growers here are so engaged with this subject now.

Following on from this we asked the PGIBSA to assist us in developing a Phylloxera Outbreak Planning Manual with the community. At the time, you insisted that help would only be forthcoming if we agreed that, in advance, we would declare the entire McLaren Vale GI a Phylloxera Infested Zone (“PIZ”) in the event of any infestation in our region. I replied that I had no power to make such an agreement and that only the community could do so and further, that if we did accept your ultimatum, the conclusions of that document were fore ordained. That was my first experience of your tautological approach to things.

Subsequently, you forbade employees of the PGIBSA from assisting us in this endeavor. You also attempted to strong-arm an employee of MVGWTA and our Phylloxera Committee into making such an agreement. They also declined on the same grounds.

In our meeting, when pressed as to who had been consulted regarding the changes to the 2011 rule changes, you did not answer. Former PGIBSA Chair Dr. Richard Hamilton did indicate that you had consulted us over 10 years ago. When reminded that we disagreed at that point in time, he did not argue. When asked who would benefit from the rule changes, you again demurred.

4) After spending a number of years contemplating exactly who the beneficiaries of such changes could be, the likely ones fall into two camps. The first is (mostly) interstate vine nurserymen. After the planting boom ended in the early 2000’s, the nurseries have had a very tough run economically. They would clearly benefit from an infestation in South Australia by selling grafted vines to SA grape growers. The other camp is vineyard owners with substantial holdings in multiple states and Phylloxera zones. There are only a few of these and tend to be very large wineries who have substantial holdings of younger vines already on grafted rootstock. Of these, I am aware that the two largest wine companies in Australia are supportive of the changes made in 2011 and that they plan to write submissions in support of these changes.

The nurserymen first. The nurserymen who would benefit are primarily in New South Wales and Victoria. They are also under recently elected Liberal state governments who are justifiably eager to assist in reducing “red tape” for constituencies that have been perhaps under-served during their many years in opposition. These governments have in turn placed pressure on the South Australian state government, principally through BioSecurity SA it seems, to remove unwarranted trade barriers as governments are required to do where no scientific basis for the rules exist. This is very clever business.

Simply put, the Phylloxera Board was created to protect South Australian grape vines and wine growers from Phylloxera; if it can not mount an effective campaign to protect us on a scientific basis from the most lethal vine pest on the planet, it has no reason to exist or to continue to collect levies. This is your job – to make this case and protect us. It is not a non-partisan effort.

Now, the wine companies – why would they support rules to encourage the spread of the worst grapevine killer in the world?  The rules governing the movement of machinery – tractors, harvesters, etc from the various zones are currently quite restrictive. As these companies attempt to recover from the many billions of dollars of investors’ money they have written off over the past decade due to previous bad decision-making, they have a strong incentive to shrink their capital base to improve their shareholder returns.

As they have been largely unable to flog off the vineyards they have had up for sale the past few years, they would benefit from reducing the amount of expensive equipment they use to do the work required at far flung properties. The pre-2011 rules make this difficult.

Two different multinational companies with large wine portfolios operate the vineyard blocks across the road from our vineyard. This winter I watched in horror as one winery operator made up to five tractor passes in a completely waterlogged vineyard performing machine pruning, cutting off cordons, slashing and finally spreading mulch (!) to improve the soil / mud that they had just compacted to buggery. Then, in came the workers to do a hand-pruning pass in the mud.  These are the exactly perfect conditions required for lightning fast spread of Phylloxera.

Why didn’t this company wait until the vineyards were dry? The short answer is that they only have “x” acres, “y” work hours “z” tractors during winter to do the work and their accountants have the ultimate decision-making authority. To do it any other way would involve hiring un-budgeted contractors or paying penalty rates for overtime at additional expense.

These are the same companies where every employee wears high visibility work-wear everywhere on site, the cappuccino machines have step by step photographs of “dos and don’ts”, etc. because those rules are mandated by law. They are no natural respecters of our region’s voluntary codes of conduct for winegrowers; they spray agri-chemicals in high winds regularly every year because they can. Its legal! This is no rant. It’s my life as their neighbor.

Given that this work was planned, managed and conducted by thoroughly trained and knowledgeable viticulturists in violation of every known principle of good viticulture and soil management, why should we expect their behavior to improve with relaxed standards of behavior towards Phylloxera?

The vineyards these companies have been unable to off-load in the vineyard business slump are mostly grafted on Phylloxera resistant roots. If Phylloxera were to get into SA, most growers (including me) would be wiped out or forced to replant at enormous expense. My estimate for our vineyard is $40,000 – $50,000 per acre over a ten-year period in lost income and investment capital required.

The fruit we produce is highly valued, goes into Chapel Hill’s Vicar Shiraz every year and regularly obtains 94 to 97 point scores from critics. But, despite the relatively high prices we obtain, we cannot afford to recover from infestation. However, my corporate neighbor across the road would not only continue producing, their vineyard would increase in value while we went broke!

The nurserymen and large wine companies clearly have motive. They also have time and resources to patiently push these undesirable changes to the detriment of the small growers who produce the preponderance of the great wine grapes in Australia. While we wait for the ground to dry out and do the right thing by our vines, they speed through the mud, they employ lobbyists, they ensure their employees are on the “technical committees,” that they sit on industry Boards of every type and dominate them where they can. Finally, they insist on “caps” on levies paid to regional associations, which only apply to them! The sense of entitlement of the best-capitalised and largest companies in our industry is beyond the pale.

I have no quarrel with anyone acting in his or her own interest. In fact, I applaud it to the extent that it makes society wealthier. But when someone tries to manipulate the polity to enrich themselves at the expense of their neighbor, I see it as an obligation to make their hypocrisy public. This is my declared interest.

5) Engagement – the PGIBSA is required by its governing Act to maintain Phylloxera Committees in each wine-growing region in South Australia. A number of years ago, the PGIBSA decided that this was just too hard and that the committees were dying out of “lack of interest.” Having been involved in various ways with numerous industry bodies, my observation is that the Phylloxera Committees died out of lack of engagement with PGIBSA, not lack of interest.

Instead of doing the missionary work of building these committees up through education and engagement, you chose to begin communicating with a variety of bodies, local grape and wine associations and “technical committees”, etc. without ever asking for the Act to be changed to reflect the changing circumstances. As such, you have defied the law, the will of Parliament and your sacred duty to levy payers and the Minister. This casual disregard for the primacy of the law and the Minister’s authority is not a commendable trait in a body set up to establish and enforce standards and protocols.

The Act works (worked?) because the regional committees created a small base of a dozen or less very knowledgeable and respected people in each community on the topic of Phylloxera. A half-dozen or more well-connected growers is a very large number in an agricultural community. One of the points that have been repeatedly raised by various industry figures is that “McLaren Vale seems to be the only region concerned about these rules changes.” I submit that this is because we have never stopped having a Phylloxera Committee despite being stymied in almost every effort to interact with the body required by law to maintain us and engage with us.

While I was the Chair of MVGWTA, our Board nominated winegrower Rae Noon to the PGIBSA Board. It was through Rae that we discovered that the rules were changed in 2011 without you consulting levy payers or even our Phylloxera Committee. Rae’s husband Drew (an all around boy scout), has long experience with Phylloxera from his days working for the government of Victoria building up their wine industry. Drew has assiduously and politely campaigned to maintain the rules and even strengthen them to the frequent embarrassment of the PGIBSA.

Over the past few months, Rae has reportedly become aware that the PGIBSA has held “gatherings” (not “meetings”) to which Rae was not invited to discuss these matters. Reportedly, this culminated in the PGIBSA obtaining advice from the Crown Solicitor that Rae held a conflict of interest (because of Drew’s passionate, informed and effective campaigning) to the effect that the PGIBSA could exclude Rae from certain portions of official business. It does not seem to matter to the PGIBSA or the Crown Solicitor or the Minister (she has reportedly been made aware of this) that Rae was accurately representing the views of growers other than Drew in McLaren Vale to the PGIBSA and communicating (also known as “engaging”) with them. In short, she did her job while you did not.

The delicious irony in this is that, if we follow the PGIBSA and Crown Solicitor’s views on conflict of interest, Minister Gago herself will be conflicted as her husband Peter Gago is the head winemaker for the Penfolds brand at Treasury Wine Estates! Unless of course, “conflict of interest” only really means “disagrees with the PGIBSA.” Theoretically (in this scenario), Treasury’s self-interested tacit and / or overt support for rule changes of 2011 would not be a conflict in this instance as they don’t disagree with the PGIBSA! Perhaps the most materially conflicted party in this bowl of spaghetti is PGIBSA Chairman Robin Nettlebeck, head of the largest vine nursery in South Australia at Yalumba. Has the PGIBSA sought “conflict of interest” advice from the Crown Solicitor about him and his interests? If not, why not?

I will leave specific discussion of the five “low” risks and ten “high” risks to Drew Noon and others to capably address in their submissions.

However, suffice it to say that at least four of the ten “high or “very high” probabilities, if applied to the culture and management of PGIBSA, combine to make the PGIBSA itself the very epicenter of risk of Phylloxera infestation in South Australia on a probabilistic basis.

This current process is a perfect example of how a series of risks can combine into a contagion if they are overly centralized in an organization with a fundamentally conflicted Chair (in my humble opinion anyhow) and an executive with poor communication skills.

What is apparent here is everything required for a sensible person to arrive at the conclusion that this entire process is being stage-managed by those who stand to benefit from Phylloxera entering South Australia.

That the Minister seems to take advice from BioSecurity SA ahead of the Phylloxera Board is an indication of the low regard held by Government for the management of PGIBSA. This is a shameful state of affairs for a body with a 100+ year history of serving all grape growers in South Australia and not just those with the time and money to push their own agenda.

My advice is that the Minister should heed the precautionary principle by not lowering, relaxing or “harmonising” the rules for many years, order that PGIBSA re-establish the Regional Phylloxera Committees and for the PGIBSA engage with them in person on a regular basis, raise quarantine standards and engage in the long hard work of getting the rest of the Australian grape industry “harmonised” around a gold-plated standard rather than lowering our standards to appease those who would profit from doing so.

The first step is to reconstitute the Board with an independent Chair and the employment of a CEO capable of the missionary work of engaging with levy payers in an effective fashion.

Failing that, I fear we will be re-naming the PGIBSA the Phylloxera Grape Infestation Board of South Australia.

With Regards,

Dudley Brown

Inkwell

PGIBSA Vineyard # 02452

cc: Minister Gail Gago via email

To; The Phylloxera and Grape Industry Board of South Australia

15 October 2012
Attention: Alan Nankivell, CEO
46 Nelson St
Stepney SA 5069
admin@phylloxera.com.au

Submission from;
Drew Noon
Noon Winery
P.O. Box 88
Rifle Range Road,
McLaren Vale SA 5171
Ph/fax; 08 8323 8290
Dear Board Members,
Re: Submission to the Phylloxera Board regarding risk assessment and the Plant Quarantine Standard
Declaration of interest:
I am a small, independent grape grower and wine maker with old vines planted on their own roots, in McLaren Vale. My livelihood depends on the quality these old vines are able to produce. I do not have the need or desire to move grapes or machinery into or out of South Australia. I have no financial interest in any vine nurseries or the sale of plant material.
Introduction:
South Australia has something special to protect in having phylloxera free vineyards. The Phylloxera Board’s role is to keep South Australia phylloxera free to maintain this advantage. The path that the Board is taking to align South Australia’s Plant Quarantine Standard to the National Phylloxera Management Protocol (as currently written) places South Australia at increased risk of a phylloxera outbreak resulting from the freer movement of grapes, machinery and plant material into South Australia this allows, from regions we’ve never accepted them before. This includes, alarmingly, regions alongside known phylloxera infested zones.
I call on the Phylloxera Board to take a precautionary approach to relaxing the laws which have kept South Australia phylloxera free for so long. If we allow phylloxera in through lack of precautions, it’s very likely there’ll be no going back (eradication is rarely successful). One mistake is forever.
We don’t have to relax our standards. The National Protocol sets out guidelines for the management of phylloxera but recognises that states determine their own regulations. There is no compulsion for South Australia to adopt the National Protocol as our laws.
The Phylloxera Board is promoting “Farm Gate Security” to growers and we all need to practice this but I call on the Phylloxera Board to get on the front foot, at the border and maintain our first line of defence. We expect you to protect our state from phylloxera, we can protect our farm. The Board appears to be walking away from this responsibility, advising growers to provide their own defences when the pest arrives at their door. The battle is lost by then. This approach is not acceptable. This is not what levy payers expect from the Phylloxera Board.

Where is the risk in adopting the National Protocol?
The Phylloxera Board is negligent in its duty in accepting the National Phylloxera Protocol (as currently written) as the basis for our laws. It incurs a heightened and unacceptable level of risk to South Australia in doing so.
There are two principal new risks incurred to South Australia from adopting the National Protocol.

They are:
1. The risk posed by the upgrade survey.
The survey is critical because it is used to establish area freedom. If an area is considered free of phylloxera by the survey, then it can move risk vectors to other phylloxera free areas (such as South Australia) under the National Protocols (as currently written). The survey needs to be of a rolled gold standard. The problem is the current survey is not good enough. This has been demonstrated in practice in the Yarra Valley (see the Yarra Valley Case Study page 16 & 17 available on the Phylloxera Board website). Subsequent research by DPI Victoria Biosciences Research Division has found both a DNA probe and emergence traps more effective at early detection than the root survey. Even when repeated twice over a three year period as required by the Protocol, there is significant risk that the survey would miss a low level infestation.
The Phylloxera Board has considered the risk posed by the survey in its recent Risk Assessment September 2012 and rated it as LOW. Where is the science behind this rating? What are the confidence levels provided by the survey of detecting a low level infestation? This assessment is subjective and not based on fact. There is no information offered to support this rating.
The reality is we do not have any survey method that is good enough to establish phylloxera freedom and until such time as we have one available, we should not accept claims made by new areas on the basis of the current survey. This represents a big new risk to South Australia.
2. The risk posed by proximity to an infested area (a PIZ):
This is another risk of concern to growers which the Board has considered in its recent Risk Assessment September 2012 and rated as LOW. This defies common sense and invites doubt about the credibility of the Risk Assessment.
One only has to look at where all the outbreaks have occurred in the past 15 years to illustrate that regions closer to the infested areas are at greater risk. This is why the PIZ boundaries keep getting extended. To deny there is a significant proximity risk causes a loss of confidence in the Board and the risk assessment process. Where is the science to support the assessment that the risk relating to proximity is Low?
Other new risks flow from these two.

That is:

Because there is a significant risk the survey would miss a low level infestation, the risk posed by allowing grapes, machinery and plant material in from new regions declared phylloxera free on the basis of the survey is too high.
Because proximity to an infested area brings higher risk of an outbreak, we should not allow risk vectors into South Australia from areas alongside infested zones, which you have already sanctioned and is currently allowed.

What we want:
I call on the Phylloxera Board and the regulators to stop making changes to South Australia’s Plant Quarantine Standard to align with the National Phylloxera Protocol (as it is currently written). I support the Board’s proposal as stated in the “Risk Assessment September 2012” document that the Plant Quarantine Standards “remain as they are now proclaimed as at July 2012.”, provided that South Australia adopts a precautionary principle in relation to new PEZs declared since 2000, treating them as Phylloxera Risk Zones in light of the significant risks they pose as discussed above. I want the Phylloxera Board to promote this change to PIRSA and the regulators so that this upgrade to SA’s Plant Quarantine Standards will be made without delay.
I want the Board to get on the front line in protecting South Australian vineyards from phylloxera rather than bowing to pressure from other states interests including nurseries who want access to our market and some big wine companies who want to be able to move grapes into South Australia to centralised processing wineries for financial gain. The Board’s mission is to protect South Australian vineyards from phylloxera and I want you out there doing just that. Not promoting “farm gate security”. That is principally my responsibility. Yours is to make policies to prevent phylloxera getting into South Australia by protecting our borders. Leaving our Plant Quarantine Standards as they are and classifying new PEZs as PRZs would provide strong evidence you are doing that.
Growers I talk to are not silly. They have absolutely no appetite for increased risk from phylloxera and they expect the Phylloxera Board to ensure adequate protections are in place. In particular to protect them from the risk posed by Victoria and the movement of grapes and other risk vectors. If they knew that you were sanctioning a relaxation of the protections that have been in place, they would be furious.
At our McLaren Vale Phylloxera Board stakeholder meeting, one senior grower who sat in front of me during the presentation and didn’t say much, turned around at the end and asked incredulously “who’s paying these guys?”, another during the presentation called out “it sounds like you’re asking us to practice unsafe sex”. Growers (your stakeholders) are not happy with relaxing the standards. They see no benefit to them, only to the other states and big wine companies.
These changes are being made at a time when phylloxera is on the move in Victoria more than at any time since introduction of the pest in the late 1800s.
I suggest that 50 years from the last outbreak would be a good time to begin discussing relaxing the quarantine standards with South Australia’s grape growers and I’m not sure you’d get any sympathy then!
This is certainly NOT the time to be dropping our border protections. Rather, growers would like you to be strengthening them.
Comments on the Phylloxera Boards 10 risks and proposed actions:
I endorse the McLaren Vale Grape Wine and Tourism Associations comments in their submission in relation to these risks and proposed actions.
In terms of priority, these risks and actions should be dealt with after dealing with the treatment of all new PEZs as PRZs. This change in the definition of a PEZ in our Plant Quarantine Standard should be made urgently and completed before January 2013 and the next grape harvest.
Changes required to the National Phylloxera Management Protocol:
The Protocol needs changing to protect all members of the industry nationally.
The survey as defined in the Protocol can only establish a low risk area rather than a pest free area. We have no survey methodology at present rigorous or robust enough to establish pest freedom. The difficulty of early detection of phylloxera and the need for better methods is well recognised by research scientists. Hoffman and Herbert (2006) in their paper titled “Finalising and validating a diagnostic tool for the early detection of phylloxera” state that “There is an urgent need to develop a phylloxera-specific detection system…” so that phylloxera detection would not rely on “problems with visual detection…” Until we have such a proven system for early detection, we should not be relying on the root survey as outlined in the National Protocol. It isn’t proven or supported by science and the risks and costs of a mistake are too high.
Therefore, I call on the Phylloxera Board of South Australia to argue this case at the national level, through the National Vine Biosecurity Committee, for a change to the National Protocol to require treatments and precautions to apply to the movement of risk vectors from PEZs declared since 2000 to other PEZs, the same as are applied from PRZ to PEZ, until such time as we have a survey proven by science to be robust enough to establish pest freedom and an on-going survey programme in place to ensure this status is maintained.
History shows that phylloxera has avoided containment all around the world. Australia is in a unique position to maintain its old vine heritage and advantage over other wine producing countries. Our strict quarantine standards have defied the odds so far. Giving up this advantage by taking unnecessary and unquantified new risks would be a tragedy.
The Phylloxera Board and the State Government have a duty of care to apply a precautionary principle in relation to phylloxera risk. Please take this precautionary approach to the national forum to protect South Australia and all regions from a potentially tragic mistake and in the meantime please increase rather than decreasing our own level of protection in South Australia’s Plant Quarantine Standard.
With many thanks,
Drew Noon.

About these ads