Summary of response, by organisation / individual | |
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| Individual nursery #1 | Scottish Natural Heritage (SNH) | NFU Scotland | The Highland Council | Individual nursery #2 |
General observations | - | Interest in PRA relates mainly to dealing with non-native species that may pose a threat to biodiversity in Scotland. PRA process applies similar principles to those that have now been identified as key to above. Approach to dealing with non-natives affecting biodiversity has much to learn from plant health processes, and it is appropriate that Defra's Central Science Laboratory are now involved in developing methodologies for biodiversity risk assessments since they also take the lead on PRA for plant health. Keen to see that potential synergies with existing processes for dealing with plant and animal health risks are identified and benefits realised. Welcome inclusion of environmental impacts in the examples of PRAs referred to in consultation. Need to ensure that potential biodiversity (and other natural heritage) impact from possible risk management options are considered in the Regulatory Impact Assessments (RIAs). | Vitally important that entry of new pests should be avoided. If new pests are introduced action should be taken quickly to eradicate/control them. Rapid passage of information will assist in prevention / control / eradication. Proposed system of notification and publication will improve protection against pests. Name / address information should not normally be disclosed but map location should. Scotland has a well recognised status as being free of a number of pests which affect other parts of the European Union (EU). Believe this status should be protected but concerned at increasing geographic spread of pests despite EU control measures. Proposed measures, which will improve the speed of flow of information on pests, offers improvements in the ability to avoid, control and eradicate new pests. Knowledge of location of a pest outbreak is important but a balance must be struck to avoid unnecessary economic harm to premises affected by an outbreak. | The Council recognises the economic value of maintaining the highest levels of plant health and welcomes the Government's approach to ensuring that new risks are identified as early as possible so that adequate control measures can be put in place. | - |
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Responses to specific questions | | | | | |
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i. Do you have any comments about the proposed future consultation procedure? | Generally a good idea. | Consultation procedure seems a sensible approach. | Procedure appears to be well thought out and should give the opportunity for interested bodies to comment on PRA. | The sample PRAs and the proposed consultation procedures appear to be sensible and the level of information appears to be appropriate. | - |
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ii. If the proposed procedure is adopted, would you or your organisation like to be included in the mailing list? | Yes. | Would not wish to be included on the mailing list as a matter of routine. However, it may be appropriate for SNH to be included when there are significant natural heritage impacts identified, either by the pest upon native species or from the recommended management options. | Yes. | Yes. Information on any correlation of risk with climatic factors would be particularly welcomed so that the local relevance can be assessed. | Yes. |
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iii. Would you be willing to receive consultation documents by e-mail in future? If so, what is your e-mail address? | (No e-mail address provided) | Yes (e-mail address provided in original response). | Yes (e-mail address provided in original response). | Yes (e-mail address provided in original response). | Yes (e-mail address provided in original response). |
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iv. Is the information provided in the enclosed examples too comprehensive, too technical, too limited or about right? | About right. | About right. However, SNH would like to see more detail provided on potential environmental impacts from the pests being considered ie on native species and habitats, highlighting any of conservation importance. Would also like to see impacts on environmental interests included in the RIA, and to included impacts not just from the pest but also any impacts from proposed management options, eg the repeated use of broad spectrum herbicides on arable land can have negative impacts on arable plant species with poorly persistent seedbanks - some of these species are now considered to be under threat. | About right. To assist those requiring more detail a contact link / e-mail address could be provided. | About right. | About right. |
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v. Do you have any views on our intention to publish more details of outbreak sites in future? | No problem. | This approach seems sensible - whilst increasing openness encourages public awareness and appropriate responses, the identification of affected businesses could discourage reporting of future outbreaks. | It is important that growers should be able to protect themselves from pests. Information on map location of outbreaks should therefore be made available. Agree that names and addresses should not be disclosed unless very serious plant health concerns warrant it. | Council would welcome publication of information on outbreak sites. Whilst they accept the need for protection of individual businesses they have concerns relating to the generalisations that may be necessary in order to protect identities. In the context of a large and sparsely populated area such as Highland, where there may be few growers in any one parish, the tendency is for data to be amalgamated to the point where it becomes meaningless. At the very least, the Council would require data to be available at the "area" level, eg "Ross and Cromarty" or "Sutherland", rather than a generic "Highland" level. | Due to the isolated nature of the area in which this nursery is located the writer is concerned that it would be immediately apparent from any map reference which business was involved. As a supplier of young plants to the trade any hint of a potentially damaging pest / disease, despite any necessary isolation or eradication measures being carried out on the nursery, could have a very significant effect on the business. The scale of this impact would depend on the pathogen involved and the degree of hysteria prevalent in the industry at the time. The threat of further disclosure of name and address in the event of an outbreak on their own nursery would make the business' own customers even more alarmed about any perceived risk of spread. |
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vi. Do you believe that disclosure of details of an outbreak of a pest at your premises would cause commercial damage to your business? | Yes. | n/a | Believe that disclosure of names and addresses could cause commercial damage. | n/a | See previous answer immediately above. |
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vii. Can you provide any evidence of the likely scale of those losses? | No, but any adverse publicity can affect long-term confidence. | n/a | NFUS cannot quantify such losses. This would be highly dependent on the perceived risk of the particular pest and the mix of plants affected on the premises. | n/a | See previous answer immediately above. |
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viii. Are there any other factors that SEERAD should take into account in deciding whether this information should be disclosed? | See previous answer immediately above. | The need for and scope of public action, and the significance for environmental interests, should be taken into account. | - | - | See previous answer immediately above. |