APAL calls report 'irrational'
APPLE and Pear Australia Limited (APAL) has wholly and absolutely rejected the findings and recommendations of the draft report for the non-regulated analysis of existing policy for apples from New Zealand in a submission delivered to Biosecurity Australia last night.
Chairman of APAL, Darral Ashton said the Biosecurity Australia position virtually reverses the stance it took in the WTO dispute, but it has not provided the scientific evidence to justify such a radical turnaround.
“It is extremely disappointing that Biosecurity Australia has now come to a position that effectively unravels the efforts that went into the Australian Government response to New Zealand’s WTO complaint in regard to the sanitary-phytosanitary measures for three pests of concern – fire blight, European canker and Apple Leaf Curling Midge,” he said.
“Over the period 2007 to 2010, the Australian Government invested considerable time, effort and resources to justify the processes employed and the science used to determine the phytosanitary measures established in the 2006 policy, and to justify that Australia had the right to establish its own Appropriate Level of Protection.
“APAL believes the recommendations contained within the Draft Report in regard to fire blight, European canker and Apple Leaf Curling Midge are arbitrary and are based on an irrational and an unreasonable set of conclusions. Indeed, it appears that Biosecurity Australia did not even have the full New Zealand standard orchard practices document on which the recommendations were based.”
Specifically, the Draft Report is seriously flawed because:
- The downgrading of the risks posed by the three pests and diseases of concern is not based on scientific evidence
- The proposed measures to manage the risks presented by the three pests and diseases cannot achieve an Appropriate Level of Protection for Australia
- The process used to derive the proposed measures and the proposed measures themselves are not supported by scientific evidence or transparent reasoning
- There is a lack of transparency in the analysis underpinning the Draft Report
- The employment of a non-regulated review rather than a proper Import Risk Assessment denies stakeholders procedural fairness
- Biosecurity Australia failed to properly consider or utilise protocols/measures that have been implemented by New Zealand and/or Australia which represent appropriate ‘equivalence’ measures
- The failure to provide stakeholders a copy of the New Zealand Integrated Fruit Production manual upon which the Draft Report relies severely compromises our ability to address claims made by Biosecurity Australia
- From a statement made by the Minister, Biosecurity Australia has not sighted the full Integrated Fruit Production manual. Making recommendations on the basis of an incomplete document is irresponsible and a disservice to the apple and pear industry and Australia.