licensing non-native biological control agents: the english way biological control in ireland &...
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Licensing non-native biological control agents: the English way
Biological Control in Ireland & Northern IrelandSarah Hugo
12th May 2011
Outline
• Legislative background• Role of Fera• Process and key players• Assessment of applications• Case studies• Issues
Wildlife and Countryside Act 1981 (WCA)
• Section 14 of the WCA 1981 prohibits the release into the wild or allowing to escape to the wild of all animal species which are not native to Great Britain, whatever their proposed use
• Includes holding non-native animals in semi-confined situations such as gardens, glasshouses, aquatic cages
• Non-native is “of a kind not ordinarily resident in and is not a regular visitor to Great Britain in a wild state”
WCA: Section 16
• Section 16 gives the Secretary of State powers to grant licences for releases so that Section 14 does not apply
• Releases of non-native animals may therefore be licensed under the Act for specific purposes such as:
• research, education, species (re-) establishment, control of pests on commercial crops, control of invasive organisms
WCA: section 16 licenses
• In England, the licensing authority for the release of a non-native animal or listed plant species is the Secretary of State for Defra:
• Fera is the appointed licensing body for non-native biological control agents
• Natural England is the licensing body for all other purposes
• Licence holders have a legal responsibility to comply with the statutory conditions in licences
• Inspection and enforcement mechanism via Defra’s ‘Wildlife Inspectorate’ and the police
Application for a licence
• Two types of licence:
• Releaser’s licence, for experimental or species (re-)establishment purposes
• Supplier’s and grower’s licences for commercial release (sale and distribution)
• Applications must include information on the organism to be released, purpose of release, and sufficient biological data to enable assessment of the risks and benefits
• Standard application form provided
Assessment of applications
• Fera receives and assesses all applications
• WCA guidance states “Secretary of State may wish to take advice before granting a licence”:
• Advice may be obtained from persons who are members of the Advisory Committee on Releases to the Environment
• Advice may be sought on nature conservation and wildlife aspects from Natural England, JNCC, SNH and CCW, and from Defra, SG and WAG
Assessment of new applications
Can the organism overwinter & establish in GB?
Yes NoApplicant’s experimental evidence‘Climex’ data
Is the organism host-specific?Potential risks and benefits of
the specific release
Special conditions attached to licence?
Licence plus monitoring requirements
Potential for dispersal?
Applicant’s experimental evidence
OK to licence?
Yes
Reject No
Yes
LimitedApplicant’s experimental evidence
Direct &/or indirect non-target effects?
Applicant’s experimental evidence &/ or published data
Wider consultation needed?
Consultation process
Licensing body: Food and Environment Research Agency
Application to release a non-native biological control agent
Natural England
JNCC Jeff Bale, University of Birmingham
Scotland Wales
Academic expert Devolved administrations
Government advisor(s)
Plant health restrictions
(Fera)
Consultation: advice on whether licence should be issued for release
No substantial objections
Fera drafts and issues licence to applicant: • Specified period of time • Specified restrictions for
use • Requirements for
monitoring and reporting
Objections / concerns &/or Lack of agreement, &/or High risk release, &/or New type of release
Conservation agencies
Fera seeks advice from ACRE
ACRE advice
supports licensing
ACRE advises further
information needed before licensing could be supported
ACRE advice not supportive
of licensing under any conditions
Licensing body (Fera)
Licensing body requests
further info from applicant
Information provided
Application rejected
Additional expert advice may be sought if necessary
Valid application? Completeness
check
Additional expert advice provided
if necessary
Substantial objections: REJECT
Reject: not for Fera; licence not needed;
other reason
Release of Aphalara itadori
• Classical biological control of Japanese knotweed
• Complicated by requirement to lift plant health licence restrictions
• Lengthy process requiring Ministerial approval• Licence issued with phased release and strict
monitoring requirements
Licensing body: Food and Environment Research Agency
Application to release a non-native biological control agent
Natural England
JNCC Jeff Bale, University of Birmingham
Scotland Wales
Academic expert Devolved administrations
Government advisor(s)
Plant health restrictions
(Fera)
Consultation: advice on whether licence should be issued for release
No substantial objections
Fera drafts and issues licence to applicant: • Specified period of time • Specified restrictions for
use • Requirements for
monitoring and reporting
Objections / concerns &/or Lack of agreement, &/or High risk release, &/or New type of release
Conservation agencies
Fera seeks advice from ACRE
ACRE advice
supports licensing
ACRE advises further
information needed before licensing could be supported
ACRE advice not supportive
of licensing under any conditions
Licensing body (Fera)
Licensing body requests
further info from applicant
Information provided
Application rejected
Additional expert advice may be sought if necessary
Valid application? Completeness
check
Additional expert advice provided
if necessary
Substantial objections: REJECT
Reject: not for Fera; licence not needed;
other reason
Peer review
Pre-requisite forissuing licenceunder WCA = REMOVAL of plant health ‘quarantine’
status
Interesting conundrums
• Amblyseius (Neoseiulus) californicus- Predatory mite particularly effective against red spider mite
- Licensed for many years in glasshouses only
- Reported in strawberry fields across country
- Growers want it de-regulated
• “Supernemos”- Company selling already-licensed EPNs, but in different
formulations
- Enhanced virulence against target pests: need to licence?
Issues to address
• Must balance regulatory burden on applicant with scope and potential impact of release
– including requirements for post release monitoring
• Separate licenses needed for release in England, Scotland and Wales
• Aware that process is not as visible as it could be – improve website and links from Defra, NNSS etc
• Classical biological control – need to clarify route for fungal agents
• Very different practices across the EU Member States – EPPO trying to ‘harmonise’ to some degree