Proposal | Summary of response, by
organisation (excluding
BPC
- see paragraph 5 above) |
(Numbers in brackets refer to para
numbers in consultation document) | |
| VTSC
Growers |
NFUS |
SPTA (Council) |
SCRI |
Notification of potatoes for
planting (2.1) | Welcomes the general aim of improving
the traceability of non-classified seed to
be planted in Scotland. However,
VTSC
believes that the proposals to collect
information on the origin, etc of
farm-saved seed may be difficult, and
relatively expensive to implement, in
practice. In addition, the proposals outlined in
the consultation document assume that ware
growers in Scotland will always know in
advance which ware crops they will draw
farm-saved seed from at the end of the
season: this may not be the case. There may
be occasions when growers will prefer to
leave this decision until harvest. An option which could have the same
effect as the current proposals in
2.1, 2.2 and 2.5, but which might
be simpler, would be to require all
potatoes planted in Scotland to be of
classified, or at least "field inspected",
seed. If this were to be made a requirement
in Scotland it would avoid the need for the
additional legislation proposed under
2.1, 2.2 and 2.5.
VTSC
understands that this is a requirement in
the Netherlands and that it has the effect
of limiting virus infection in Dutch ware
crops. VTSC
recommends that this alternative should be
explored. | Shares the concerns of the Executive on
the need to exclude diseases such as ring
rot and brown rot. It is also important
however to minimise bureaucracy for
growers. For that reason notification of planting
should only be extended to seed planted for
ware if this will make a significant,
positive contribution to protection against
imported disease. The contribution should also be
considered in light of the Executive's new
powers in respect of imported seed potatoes
from the Netherlands, the development of
BPC's
Safe Haven Scheme and the existing
voluntary ban on imported seed
potatoes. Information collected by the Executive
on plantings by individual businesses
should remain confidential. | Supports the proposal but at the same
time feels that this will impose another
time-consuming requirement, with associated
costs, on an industry that is already
over-burdened with regulation. To reduce this burden, Council requests
that the use of existing information from
other (
egBPC)
sources be investigated. | Strongly supported. | |
| | | | | |
Continuation of the restriction re
"once grown" (2.2) | No view. | Agrees that the general restriction to
"once-grown" should be continued but the
potential to request derogation from the
restriction in circumstances where there
are shortages of seed of particular
varieties should be retained. | Council agrees that these proposals,
which already operate and are accepted by
industry, should continue. | Strongly supported. However, crops grown on same farm as
"once grown" may still represent a disease
risk to adjacent seed crops since control
measures described in
2.3 are based on a
sample/selection of growers and 4% aphid
transmitted virus is high and time limits
are long - 72 hours plus for arranging
contractors. | |
| | | | | |
Power to order immediate burning
down of haulm of infected crops
(2.3) | No view, but see comment against
2.6. | Concerned that the proposal could
potentially cause financial harm to ware
growers who have fully complied with all
legal requirements, yet for reasons outwith
their control are found to have virus
levels above 4% in their crop. Giving
powers to require "burning down" even when
correct documentation is provided would
protect the interest of a neighbouring seed
crop grower, but at the expense of the ware
producer. As with the issue of
GM
co-existence
NFUS
believes that growers who have acted within
the law and in accordance with relevant
codes of practice should be treated
equally. Further clarification of what is meant
by "nearby" seed crop is needed. Other
factors should also be taken into account
before deciding whether to burn down, such
as wind direction or natural barriers,
which might reduce the risk of virus
spread. | Seed representatives on Council accepted
these proposals but concern and
reservations expressed by the ware sector:
in particular, latter feels that the power
which
SEERAD would seek to burn down
after 72 hours from the issue of a
statutory notice requires further
thought. There appears to be no prospect for
appeal. The application of the opinion of
the local inspector without any input from
experts causes unease. Strong feeling is
that this would require a very experienced
senior inspector or some form of
arbitration to make a decision, which could
result in a high loss to the grower
concerned. It is suggested that there could
be a specially selected arbitration panel
ready to be called on to decide on these
cases. | Strongly supported. However, with regard to
2.3.1 and 2.3.2, defining
"nearby" may be difficult. Unless solid
evidence already exists, independent
validation may be necessary to determine
the distances over which aphids from one
crop pose a "clear and present danger" to a
nearby crop. | |
| | | | | |
Separation of farm-saved seed from
ware (2.4) | No view. | The consultation does not spell out
exactly what is intended in terms of
separation but
NFUS
presumes that it would preclude the use of
the same machinery, equipment, containers,
stores or vehicles for farm-saved seed
potatoes and ware potatoes. As the
suggestion is that the major concern is
separation of farm-saved seed and
"dangerous" ware
NFUS
agrees that machinery etc. that comes into
contact with imported ware should not also
be used for farm-saved seed. The provision for annual derogations for
handling of farmers' own produced ware and
farm-saved seed potatoes, using the same
facilities, is essential. | Terms of this proposal already being
met, and it is agreed that this should
continue and be policed to prevent contact
of potatoes for planting with potatoes for
risk countries. | Strongly supported. | |
| | | | | |
Introduction of compulsory testing
for Potato Cyst Nematode (PCN) of land for
ware production where farm-saved seed
potatoes are to be produced
(2.5) | A possible alternative to testing land
for
PCN
prior to planting crops to produce
farm-saved seed might be to test a
representative sample of tubers prior to
planting. This would probably give a more
accurate assessment of the existence of
PCN
than would soil sampling and testing. | NFUS
reading of
EU
Directive 69/465/EC (Article 2) and the
Plant Heath Order 1993 is that testing is a
requirement only for seed potatoes that are
to be marketed (or classified for marketing
purposes) rather than for all seed potatoes
"for planting". The extension of compulsory
PCN
testing to land producing farm-saved seed
would therefore be a gold-plating of the
Directive, adding cost to ware
production. | Council supports the proposal in the
interest of controlling the spread of
PCN
and given the problems associated with the
long-distance movement of farm-saved seed.
Ware sector concerned however at additional
paperwork and expense involved. | Recognises that farm-saved seed is one
of the most important causes of spread of
PCN.
Presently, growers can get tests done and
if cysts are found may not use the field
for seed but can use it for ware - the
information is not transferred to the
authorities. Statutory testing of such ware
fields is an important step forward. | |
| | | | | |
Potato blight - compulsory powers
to treat dumps, etc (2.6) | No specific comment on the proposals for
burning down other than to say that a
reasonable period should be allowed between
the spraying of potato dumps and any
further action when there is no evidence of
potato blight. | As stated in the consultation document,
the
BPC
has highlighted the issue of potato dumps.
It has an ongoing campaign to improve
grower knowledge of the risks of disease
spread associated with dumps. Before changing legislation to extend
the powers of inspectors we would prefer to
see what improvements result from the
BPC
campaign. | Agrees that it would be sensible to put
these proposals on a statutory footing.
However, concern expressed in relation to
para
2.6.4 of the consultative
document and the question is therefore
asked: "where [the action] refers to
paragraph
2.3 (burning), does this include
a whole potato crop as the source of blight
infection and if so would [the entire crop]
be burned down?" Council feels that if this
is the case their suggestions for treatment
of virus in the same circumstances should
apply. Council concerned that if an organic
crop was treated as [the disease] source it
had to be recognised that the burning down
of that crop with a chemical such as
sulphuric acid would lose that field its
organic status for a period of 2 years,
affecting all crops. Council agrees this
aspect needs serious consideration and
clarification. | Strongly supports plans to reduce
sources of primary inoculum - with the
powers to enforce the destruction of dumps,
volunteers, etc. This system, with
penalties for failure to comply, appears to
have been successfully adopted in the
Netherlands. Unclear from text of consultative
document whether inspectors will
specifically request an inspection of dumps
or rely on casual observations during farm
visits - the former would be
preferable. The Executive should encourage growers
to follow the advice from the
BPC
"Fight Against Blight" campaign and site
dumps in areas where they can be readily
observed. | |