Passport to puzzlement

JUST weeks before Brexit (31 January, 2020) and a right old ‘ding dong’ over Big Ben’s bongs, UK government fell smartly into alignment with the EU’s new Plant Health Regulation (PHR), coming into force on 14 December 2019. From that point on, plant passports have been required for the movement of Plant Heath Forestry Regulated Material (PHFRM) within the UK. So what does that entail?

A detailed and clear account was set out in an article by Ian Murgatroyd (EU Exit Plant Health Regulations Lead) and Dr John Morgan (Head of Plant Health, Forestry Commission England). Entitled ‘All you need to know about plant passporting’, the article was published in the October 2019 issue of Confor’s Forestry and Timber News. The article says that PHFRM includes:

• all conifers,
• Castanea (including sweet chestnut) with bark,
• Platanus (including London plane) with or without bark.

Christmas trees exceeding three metres in height require a plant passport for their movement.

Plant passports for movement of these species are required at each stage of the supply chain – where whole or chipped roundwood (including brash) is moved from the harvesting site and/or site of aggregation (e.g. sawlogs stacked roadside), and to the processor which may be a sawmill or a biomass or fuelwood processor.

A plant passport is also required for movement of isolated bark from a wood processor, for Christmas trees more than three metres in height, and for cut foliage from such trees.

Isolated bark is defined as bark which has been removed by debarking or other processes, or has become detached from living, felled or fallen trees.

Examples of businesses which need to at least investigate these developments, if they have not already done so, include:

• Home Counties-based arborists working in Central London, where London plane is the most frequently occurring parkland and street tree species, and transporting arborists’ ‘arisings’ away from the site;
• small forestry contractors felling Corsican pine and other conifers for delivery to, and chipping by, a commercial biomass producer
• forestry contractors specialising in sweet chestnut coppice for the production of cleft, chestnut fencing away from the harvesting site.

A Surrey Woodland being felled and cleared and the wood material destined for fuelwood and biomass back at the contractor’s yard. Predominantly broadleaf deciduous and mainly birch but also some Norway spruce, which means a plant passport is required for movement.

Other companies and individuals that clearly need to take note of and act on these developments are those in the woodfuel sector. Woodsure (the UK’s only woodfuel certification scheme) said: “This regulation and the application for a plant passport may impact on woodfuel processors with their own woodland. Fuel processors purchasing timber should be looking for a compliant passport as part of the delivery note or incorporated into the weight ticket. Otherwise, they will need to seek reassurance that the timber species don’t require a plant passport as part of their ordering process.”

Confor has said anyone responsible for movement of PHFRM needs to become a Registered Authorised Professional Operator (RAPO).

The new requirements appear all-encompassing, impacting companies and individuals across the forestry and arb sectors, all the way down the ‘wood chain’ to woodsmen and tree surgeons. It is here where Forestry Journal’s initial interest and concern lies, following contact by a reader working as a dual forestry/arb contractor. He was not so much worried about himself, having learned of the new requirements from the Royal Forestry Society (RFS), of which he is a member. His immediate concern was for the countless contractors in forestry and arb who are not paid-up members of either Confor or the RFS and as such may not be aware of the requirements, leaving them vulnerable to “overzealous inspectors”.

Having been drawn up by the FC and Confor, the requirements made him suspicious about just how much consideration had been given to the smaller operator, and especially arborists and tree surgeons. To this end, he telephoned the FC to find out. When asked whether plant passporting requirements would apply right across the board and down the line, and if the FC was aware of the implications for small operators including arborists, their spokesperson said they had not considered this aspect.

One of the many Veteran London Plane trees at Old St Pancras churchyard in north-west London. Any ‘arisings’ from this and other London plane trees now require a plant passport for movement off site.

THE VIEW ON THE GROUND

I spoke with a number of forestry contractors and arborists with whom I work as a contributor to Forestry Journal. Virtually all were completely unaware of these plant passporting requirements. A senior manager at a large arb contracting company said if he saw the words ‘plant passports for timber transport’ in the Confor magazine he would automatically assume it did not apply to arboriculture. A small forestry contractor felling and moving softwood sawlogs and over-stood chestnut coppice thinks that on past experience the FC will introduce a tonnage threshold and that he may well escape in this way. However, others acknowledge there is no point in plant passports unless everyone down to florists and funeral directors is obliged to sign up. Some said the system would stall due to insufficient in-house inspectors, though the FC is considering the use of contract inspectors to reduce the burden on the industry.

A Home Counties-based arborist working south of the River Thames thought it would be completely impossible to monitor what goes on under the name of arboriculture.

“There are countless unqualified and inexperienced people out there masquerading as arborists and tree surgeons and causing massive amounts of damage to trees,” he said.

“No-one monitors what they do to trees on site, so why should they bother about what wood materials they are taking away?”

I asked another Home Counties-based arborist, this time working north of the River Thames, if he thought the extra administration and paperwork relating to species such as sweet chestnut and London plane might cause professional arborists with a full workload to avoid jobs involving these species. He wasn’t sure, but said the client could always find casual, unqualified workers who are not bothered about regulations to carry out the work.

“And in such cases you will have to worry about where the arisings will end up,” he said.

Finished fencing products cleaved from over-stood sweet chestnut coppice. A plant passport was required to bring the coppice poles to the contractor’s yard but is apparently not required for movement of the finished product, with or without bark, off site and to the customer.

AN IMPORTANT MEASURE

UK Chief Plant Health Officer Nicola Spence has said: “I am delighted to see the introduction of timber plant passporting. It’s important that our biosecurity measures meet the highest of standards and we need to do all we can to ensure any plant material being transported to the UK is free from regulated pests. I’m really pleased that the Forestry Commission is working with Confor and the wider forestry sector to help achieve this, and I fully support the work they are doing.”

Alignment with the new EU PHR is obviously regarded as a smart move, but it could rapidly go from sublime to ridiculous if florists and funeral directors moving cut conifer foliage get caught up in the requirements. A ridiculous scenario you may say, but entirely possible given the apparently all-encompassing and unyielding scope of the new legislation.

To see if there is any flexibility with regard to the type and size of business and the nature and size of material movements, I asked the Forestry Commission (Plant Health) to consider and comment on six scenarios (no names, but real people and companies I deal with) to find out if they would be caught up in these new plant passporting requirements. 

The FC reply, which is both clear and comprehensive, is given alongside the six scenarios at the end of this article, selected to cover as many types of operators and companies as possible. Hopefully the information provided by the FC, and related specifically to these six scenarios, will go some way in answering questions and allaying fears for many people.

Sweet chestnut coppice poles in Kent destined for the coppice contractor’s yard and cleaving into chestnut fencing. Plant passport required for movement off site.

WHY TIMBER AND WOOD FROM THESE TREE SPECIES?

So what are the risk factors which made UK plant health authorities single out these species (conifers, Castanea and Platanus) for special treatment?

Castanea

The Castanea genus comprises some seven species spread across North America, Europe and Asia. Main UK interest is in sweet or Spanish chestnut (Castanea sativa), an exotic but naturalised tree with a two-millennium UK provenance and generally regarded as an honorary British native tree. Estimated area of sweet chestnut woodland in UK is 20,000 hectares.

UK sweet chestnut led a relatively charmed life until hit in succession by an alien fungal pathogen (Cryphonectria parastica or sweet chestnut blight) and an alien insect pest (Dryocosmus kuriphilus or oriental chestnut gall wasp), regarded as the world’s worst disease and insect pest, respectively, of the genus Castanea. The FC may also be concerned about Phytophthora ramorum recorded on sweet chestnut at more than 30 sites, mostly in Cornwall and Devon but as far east as Wiltshire. Sweet chestnut is also suffering from resurgence in ink disease caused by a pair of Phytophthora pathogens (Phytophthora cinnamomi and Phytophthora cambivora). The fungus-like pathogens were documented as causing this disease in UK-grown sweet chestnut as early as the 1930s but are now on the increase, in response (it is thought) to a warming climate.

However, of most concern to UK plant health authorities is chestnut blight, ever since it was found at a Warwickshire farm in 2011 on sweet chestnut trees planted in 2007 as part of a consignment of planting material imported from a nursery in France. Between 2011 and 2018, the FC issued SPHNs (Statutory Plant Health Notices) for the destruction of blight-infected sweet chestnut trees at 37 sites across England. More were issued in 2019, including at sites where the pathogen had been previously been dealt with and disease eradication was presumed.

Apart from a cluster of outbreaks in south-west England during 2016/2017, the chestnut blight situation in the UK, including the location of outbreaks and nature of affected sites and infected sweet chestnut trees, has been shrouded in secrecy, with the FC keeping details well under wraps.

Conifers

That plant passports are now required for the movement of all extant (living as opposed to fossil) conifers in the order Pinales means the plant health authorities could well be mindful of a panoply of pests and pathogens, though inclusion of Christmas trees exceeding three metres plus specific comments in the Confor article give the game away.

The FC appears most concerned about Ips typographicus (larger eight-toothed European spruce bark beetle), currently causing havoc in central Europe. The pest was identified for the first time in the UK at two sites at Ashford in Kent during December 2018.  Since then, the FC has conducted a prototype plant passporting system for spruce timber movements within a large Demarcated Area of south-east England. The Demarcated Area comprises the whole of Kent (apart from a small north-west section which includes the area around Sevenoaks) and a portion of East Sussex adjoining West Kent.

There is evidence to suggest this particular spruce bark beetle may also be present in Surrey. Photographic evidence was posted on 26 December 2018 by a forestry contractor working on a private estate in Surrey, though the location was not divulged at the time, apparently due to commercial considerations.

Norway spruce is the primary plant host for Ips typographus. It only attacks trees taller than three metres, hence the stipulation on Christmas trees. Other conifer bark beetles of concern in the context of timber and wood movement mentioned by FC include Ips amitinus (eight-toothed spruce bark beetle) and Ips duplicatus (double-spined spruce bark beetle).

Platanus

Platanus genus consists of a dozen species native to the northern hemisphere, with UK interest focussed on Planatus x acerifolia or London plane. Ironically, it is not a true species, but thought to be a natural hybrid between Planatus orientalis (oriental plane) and Planatus occidentalis (American sycamore) originating some time in the 17th century when the two species were grown together for the first time in Europe. Many believe it occurred in Spain, hence the alternative name Planatus x hispanica, but the more likely location is Vauxhall Gardens (London) where famous botanist John Tradescant the Younger discovered the tree, making it deserving of the name London plane. Today the tree is widely planted in Britain’s towns and cities, and it is by far the most frequently occurring street and parkland tree in its namesake city.

The only pest or disease of London plane currently present in the UK and of some concern is Massaria disease, caused by the fungus Splanchnonema platani. Massaria is by no means lethal (to plane trees) but is responsible for weakening large branches and triggering sudden branch drop, which occurs naturally in English elm and red river gum in Australia. Massaria may well have the potential to wipe out a group of tourists admiring a huge London plane but is unlikely to be the reason behind these new plant passporting requirements.

That is more likely to be a pre-emptive strike against plane wilt (Ceratocystis platani) causing carnage in plane trees in France and Italy and with a capacity to completely alter the London landscape. Taxonomists are constantly revising the classifications and scientific names of fungal pathogens, and in this context the fungus Ceratocystis platani was linked with Chalara. According to CABI (Centre for Agriculture and Bioscience International): “Ceratocystis was linked to the anamorphic state Chalara on the basis of phialidic conidiogenesis in the anamorph.”

That may be gobbledegook to most people (including me, without my dictionary of mycological terms), but it is enough to strike fear into the hearts of arborists at least. Foresters should also take note, because London plane, with its good canopy structure, fast growth rate and high yield of quality timber, has been singled out as an alternative hardwood species. This may be of little consequence, however, if plane wilt gets into the UK causing London plane to suffer a similar fate to common ash. 

A Hertfordshire-based arborist chipping Leyland cypress and Eucalyptus arisings on site in north-west London from several trees felled at a private residence. Plant passport apparently not required to take the chippings back to the yard even though the chippings will contain conifer.

PRIORITIES AND FOCI

The FC says the adoption of timber plant passporting will demonstrate that the forest industry is committed to the highest standards of biosecurity and will improve awareness of biosecurity threats posed by quarantine pests.  Maybe so, but perhaps the priority should be excluding quarantine pests in the first place. Exclusion of quarantine pests from so-called third (non-EU) countries continues to be largely successful, but entry from EU countries on the back of ‘floppy’ EU plant passports is an obvious weak link in our defences.

The United Kingdom is a densely populated small land area with high industrial activity. Waiting until quarantine pests and pathogens arrive – Phytophthora ramorum, oak processionary moth, Phytophthora lateralis, Phytophthora austrocedri, Chalara ash dieback, sweet chestnut blight and oriental chestnut gall wasp – has already proved to be too late.

These new plant passporting requirements for timber movement in the UK are far-reaching and comprehensive. If the same level of forethought and rigour could be invested in biosecurity and quarantine against entry of pests and pathogens we would be in better place right now. Our strength is being an island nation, which better equips us to exclude alien pests and pathogens. Our weakness is being a small land area with high population density and industrial activity, thus making it more difficult to deal with an alien pest or pathogen once it has arrived.

The article by Ian Murgatroyd and John Morgan can be accessed online (see References section). It contains a sample plant passport showing the detailed layout of the document and a contact email address for enquires about how to register to become a RAPO.

Subsequent updates from the FC and Confor imply a still evolving situation with regard to:

• exactly who and what will eventually be covered by the new plant passporting process,
• the layout and content of plant passports
• the nature and mechanics of future inspections of Registered Authorised Professional Operators (RAPOs).

Contact for the latest information, including registration for RAPO status: plant.health@forestrycommission.gov.uk

References:
Confor (2019), ‘New plant passporting arrangement’. http://www.confor.org.uk/news/latest-news/new-plant-passporting-arrangement/
Forestry Commission (2019), ‘Movement authorisation and timber plant passporting in Kent’. https://www.gov.uk/government/news/movement-authorisation-and-timber-plant-passporting-in-kent
Murgatroyd, Ian and Morgan, John (2019), ‘All you need to know about plant passporting’, Forestry & Timber News October 2019, pages 14–16. http://www.confor.org.uk/media/247539/plant-passporting.pdf

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