Consultation outcome

Summary of responses

Updated 5 April 2022

This document provides a high-level summary of key findings, as well as the results from key questions, from the analysis of the Plant Biosecurity Strategy Consultation. This consultation was launched by Defra, Forestry Commission, the governments of Scotland and Wales, and our agencies and delivery partners, to inform Great Britain’s approach to plant biosecurity over the next five years.

(April 2022)

Executive summary

This executive summary provides a brief summary of the responses to the Plant Biosecurity Strategy (PBS) Consultation. A more detailed summary is included in the main body of the report. For full details and tables of this consultation please see the Plant Biosecurity Strategy Consultation: Technical report, which was prepared by analysts at Fera Science Limited and Defra and is published alongside this summary.

The full text of the original consultation document is available on the Citizens Space consultation hub: Plant Biosecurity Strategy for Great Britain.

Outcome 1: A world class biosecurity regime

Clear, accessible, and succinct information from government, including updates and alerts when new plant pests are identified as high risk, is widely considered essential to having a world class biosecurity regime. The biggest demand for information was in relation to issues currently impacting the UK, such as emerging pests and diseases, and the measures being taken against them. GOV.UK is identified as by far the most significant information source on import requirements and restrictions, followed by the Plant Health Portal.

Several open-ended responses in the consultation, in particular members of the public and environmental non-governmental organisations (NGOs), called for an increase in mandatory measures, such as increased quarantine periods or banning certain plant imports, and harsher penalties for those in breach of these measures. However, others also referenced the burden of compliance and the impact this may have on competitiveness, both for larger domestic businesses, small to medium-sized enterprises (SMEs) and volunteer-led initiatives.

The vast majority of respondents in the trade considered themselves to have sufficient information to trade responsibly and in line with regulations, albeit with some respondents highlighting gaps in training and clear communication of requirements.

Outcome 2: A society that values healthy plants

Encouraging society to play a more active role in plant health was widely considered by nearly all respondents to be key to improving plant biosecurity standards. Most respondents highlighted the benefits of increasing public awareness and engagement, both in reducing individual incidents with plant biosecurity impacts, as well as shaping consumer purchases of plants and wider stakeholder attitudes.

Measures to increase public awareness, such as better learning resources and targeted messaging (for example at the UK border, or when buying plants), were generally favoured by most respondents.

When asked how government can further enhance positive contributions of citizen science to plant health, 47% said broader participation by the general public should be facilitated. 42% of respondents said that informal training, including webinars on biosecurity and plant pathology, would have the biggest impact on building knowledge of plant biosecurity.

Outcome 3: A biosecure plant supply chain

Only a small group of respondents from the trade sector who were eligible for an assurance scheme reported being members of a scheme. For suppliers, by far the biggest factors in choosing to engage with assurance schemes was brand reputation and the ability to demonstrate environmental commitments. The ability to charge a premium was not a big concern for respondents.

The role of domestic production in enhancing biosecurity in Great Britain was one of the most frequently raised issues in the consultation. A wide range of approaches was suggested, with some advocating for a phasing out of imports completely. Others emphasised that the globalised nature of existing systems means that a focus on domestic production may be too narrow to achieve the stated biosecurity goals. Competition from overseas suppliers was the single most significant barrier identified, followed by reliability of labour availability.

Outcome 4: An enhanced technical capability

Priorities for research funding showed a preference for strategic long-term research over reactive approaches, with the majority of respondents saying 50-70% of investment should be in strategic long-term research.

Inspections, diagnostics and surveillance are identified as the areas of research and development (R&D) investment with the greatest overall importance among respondents. This is followed by risk assessment and horizon scanning.

In terms of what can be learnt from other sectors, a few of the sectors referenced included public health and epidemiology, animal health, weather modelling and communications. When it came to new technologies that could support research and development, cost was identified as the biggest barrier.

Additional biosecurity measures for high-risk trees (Annex A)

When giving their score for both awareness of current measures for high-risk trees and satisfaction with their efficiency, respondents were fairly evenly split. Many who responded argued that the limits of the current measures were self-evident, whether due to being insufficient or due to poor adherence, although with some exceptions. The greatest concerns cited by respondents around the import of high-risk trees was the robustness of inspection activity both at the border and in exporting countries.

Of the proposed measures implemented before the border, prohibiting the entry of specific plants was generally identified as the most effective response, being especially favoured by landowners and members of the trade. At the border, tightening of restrictions on larger trees with soil was ranked as the most effective measure overall, followed closely by increases in the inspection regime.

Introduction

Note: This document provides a high-level summary of key findings, as well as the results from key questions, from the analysis of the Plant Biosecurity Strategy Consultation. The full technical evidence report, compiled by analysts at Fera and Defra, is published alongside this document, and contains the graphs and analysis from all the questions contained in the consultation.

This consultation was launched by Defra, the Forestry Commission, the governments of Scotland and Wales, and our agencies and delivery partners, to inform Great Britain’s approach to plant biosecurity over the next five years. The new approach will build upon the previous Plant Biosecurity Strategy for Great Britain published in 2014. Our^{[footnote 1]} refreshed biosecurity approach will be developed in collaboration with our partners through established forums, and from the views of the public through this consultation.

The new Plant Biosecurity Strategy for Great Britain will be published later this year and will set a new vision for plant biosecurity from 2022 to 2027. Recognising that pests and pathogens do not respect national boundaries, our three nations have agreed to continue to align around our common biosecurity vision and to act together. Delivery of the strategy will be coordinated across Great Britain through the Plant Health Common Framework. This Framework sets out a commitment to continue joint working in order to establish a common approach, where devolved competence intersects with powers that have returned from the EU (European Union)^{[footnote 2]}.

The scope of this consultation is limited to biosecurity of plants and plant products (including but not limited to trees, vegetables, seeds, fruits in the botanical sense, wood packaging material and cut flowers)^{[footnote 3]}.

It is important to note that the government has outlined a new approach for arrangements in relation to Northern Ireland in the Command Paper ‘Northern Ireland Protocol: the way forward’, which was published on 21 July 2021.

This consultation was launched on 21 September 2021 and was open for ten weeks until 30 November 2021. The consultation was supported by a consultation document and technical annex. The consultation invited responses to 33 questions, with 6 further questions in a separate technical consultation on additional biosecurity measures for high-risk trees.

The consultation document proposed the following vision to strengthen Great Britain’s approach to plant biosecurity: ‘To protect Great Britain’s plants through a strong partnership of Government, industry and the public, with the aim of reducing and managing the risks posed by plant pests and pathogens and facilitating safe trade.’

The questions in the main consultation were divided up into the following four outcomes that will help deliver the vision for the Plant Biosecurity Strategy, and set out a series of actions for future focus.

Outcome 1: A world class biosecurity regime

Making the most of opportunities to tailor and strengthen our response to prevent and manage the introduction and spread of pests and pathogens that pose a threat to plant health in Great Britain.

Outcome 2: A society that values healthy plants

Raising awareness of the importance of healthy plants and trees and encouraging the adoption of responsible behaviours across society.

Outcome 3: A biosecure plant supply chain

Government and industry working in partnership to support a biosecure plant supply chain.

Outcome 4: An enhanced technical capability

Building plant health capability and making use of emerging, innovative science and technology to keep pace with changing threats and ensure preparedness for the future.

High-risk trees

In parallel to the consultation on the overarching strategy, we launched a more detailed technical consultation on additional biosecurity measures for tree species posing a particular risk of pest introduction through imports. This technical consultation (Annex A) looked at specific biosecurity risks associated with importing trees and whether further measures should be introduced in the future to strengthen our biosecurity regime.

Respondents

The consultation received 1,192 responses in total. This included 139 responses to the consultation questionnaire on Citizen Space, 6 individual email responses, and 1,047 responses from a letter writing campaign. The following sections provide further details on the breakdown of responses and respondents.

Responses to the consultation questionnaire

Stakeholders and members of the public were invited to respond to 39 questions posed in the consultation document (including the technical annex) – these included a mixture of closed (quantitative) and open-ended (qualitative) questions.

A total of 145 responses to the consultation questionnaire were received, either directly via the online portal (Citizen Space) or separately by email or in writing. In total there were 144 respondents from whom meaningful quantitative data could be extracted either from the survey portal or from documents provided in alternative formats.

Table 1. Responses to the consultation questionnaire by channel

Response channel	Responses received
Citizen Space consultation website	139
Email	6
Total	145

In the questionnaire respondents were asked to self-identify the category of respondent which they felt best represented them. We have used these respondent types throughout this report, including the attribution of quotations. It is important to highlight the fact that respondents self-identified as belonging to each of these categories, and that no verification was conducted.

Table 2. Responses to the questionnaire by respondent type

Respondent type	Number of respondents	Proportion of overall quantitative sample
Member of the public	48	33%
Landowner or land manager	6	4%
Forester	3	2%
Arboriculturist or other tree professional	7	5%
Farmer	0	0%
Business that grows and sells plants or plant products to trade	10	7%
Business that grows and sells plants or plant products to the public	7	5%
Business that only sells or trades plants online, with no physical premises	3	2%
Member of the landscaping sector	3	2%
Member of the education sector	4	3%
Involved in research or plant health science	19	13%
Local government	4	3%
Environmental non-government organisation	13	9%
Professional body	17	12%

In the questionnaire, respondents were also asked to identify the geographical region they were from. The vast majority of respondents listed themselves as coming from England, with a minority from each of the other home nations, including a single respondent from Northern Ireland. Of those respondents who listed themselves as ‘Other’, the majority (9 out of 10) represented organisations with a UK-wide scope.

Table 3. Responses to the questionnaire by geographical region

Geographical region	Number of respondents	Proportion of overall quantitative sample
England	111	77%
Scotland	13	9%
Wales	9	6%
Northern Ireland	1	<1%
Other	10	7%

Additional responses to the consultation

In addition to the responses submitted on Citizen Space, 6 organisations provided separate responses to the consultation by email.

Letter writing campaigns

The consultation also received 1,047 responses through a letter writing campaign arranged by the Woodland Trust. The Trust provided its members with a suggested wording to use and encouraged them to respond via a portal on their website. Further details on the Woodland Trust campaign are provided below. The responses have been analysed separately from the other consultation responses.

Summary of responses

Question 8: Which of the following issues do you think poses the greatest risk to plant health?

The overall greatest perceived risk to plant health in the UK was the movement of material in trade. Over two-thirds of respondents listed this among their two greatest concerns. Climate change was seen as the second greatest current risk. The remaining issues, including lack of incentives, personal import of material, poor awareness of risks, and low knowledge of practice, achieved relatively similar levels of recognition. Awareness of risks and low knowledge of practice were on average ranked slightly higher than lack of incentives, which in turn was ranked higher than personal imports, but the effect of these differences is very small and consequently not explored in detail here.

Outcome 1: A world class biosecurity regime

Summary of key themes

Mandatory measures

There were several calls for an increase in mandatory measures, such as increased quarantine periods or banning certain imports, as well as harsher penalties (especially from members of the public and environmentally aligned NGOs). However, other respondents also referred to the burden of compliance and the impact this may have on competitiveness, both abroad, for larger domestic businesses, and specific challenges for SMEs and volunteer-led initiatives.

Many respondents felt that their preferred biosecurity arrangements, especially in relation to inspection and enforcement, would not be possible with the current size of the Plant Health and Seeds Inspectorate.

Sources of information on plant pests and diseases

Most respondents emphasized the need for clear, accessible and succinct information from government, including updates and alerts when new pests are identified as high risk. The biggest demand for information was in relation to issues currently impacting the UK, such as emerging pests and diseases, and the measures being taken against them. This was consistent across most types of respondent, although respondents in the trade also prioritised the need for increased background information relating to the introduction of measures, as well as guidance and information relating to good practice (the last was also prioritised by landowners).

When asked where they would look for information on import requirements and restrictions on personal imports of plants, GOV.UK is identified as by far the most significant information source, followed by the Plant Health Portal.

Biosecure stock

Most respondents in trade considered themselves to have sufficient information to trade responsibly and in line with regulations, albeit with some highlighting gaps in training and communication of requirements.

When asked about their concerns around selection of biosecure suppliers, many respondents highlighted the relative inaccessibility of information. They also requested transparent expansion of accreditation schemes or other official markers in support of biosecurity aims (particularly around the identification and traceability of imported stock).

Outcome 2: A society that values healthy plants

Summary of key themes

Society’s role

There was close to universal support for the intention to encourage society to play a more active role in plant health. Most respondents highlighted the benefits of increasing public awareness and engagement, both in reducing individual incidents with biosecurity impacts, but also in shaping consumer purchases and wider stakeholder attitudes.

To facilitate this, developing multi-faceted solutions was repeatedly emphasised in responses. For example, using a mixed approach of all the proposed messaging points was seen as important by many respondents, although 44% of respondents said messages on protecting plant health would have the most impact when people are buying plants.

Citizen science

When asked how we can further enhance the positive contribution of citizen science to plant health, 47% of respondents said broader participation by the general public should be facilitated, followed by 20% saying data should be used to support action on the ground. Members of the public liked the idea of citizen science as a tool for public engagement.

Targeted messaging

Overall there was appetite for general improvements to public messaging on buying or importing high-risk material. When asked what the most effective message for a promotional campaign would be, 45% of respondents said campaigns raising awareness of the threats to plant health, while 33% said campaigns about potentially risky behaviours.

Outcome 3: A biosecure supply chain

General note

The feedback on this section highlighted that the questions tended to focus on the perspective of the trade sector, resulting in a lot of inapplicable or null responses as well as a desire from some respondents to have the option to skip this section.

Summary of key themes

Assurance schemes

Only a small group of respondents from the trade sector who were eligible for an assurance scheme reported being members of a scheme. For suppliers, by far the biggest factors in choosing to engage with assurance schemes was brand reputation and the ability to demonstrate environmental commitments. By contrast the ability to charge a premium was barely a consideration for the respondents.

Domestic production

The role of domestic production in enhancing UK biosecurity was one of the most frequently raised issues in the consultation. A wide range of approaches was suggested, with some advocating for a phasing out of imports completely. Others emphasised that the globalised nature of existing systems means that a focus on domestic production may be too narrow to achieve the stated biosecurity goals.

Competition from overseas suppliers was the single most significant barrier identified, followed by reliability of labour availability. Themes such as ongoing uncertainties around future demand and the risk burden of potential changes to rules around imports were frequently cited as significant factors in restricting investment within the sector (particularly where upfront costs remain high and availability of trained staff is limited).

In terms of ways to address the main barriers to domestic production, the most popular option was promotional activities to increase demand for domestically produced products, followed by improving availability of labour and research into increasing domestic production.

Outcome 4: An enhanced technical capability

Summary of key themes

Priorities for research funding showed a preference for strategic long-term research over reactive approaches, with the majority of respondents saying 50-70% of investment should be in strategic long-term research.

Inspections, diagnostics, and surveillance are identified as the category with the greatest overall importance among respondents. This is followed by risk assessment and horizon scanning.

In terms of what can be learnt from other sectors, a few of the sectors referenced included public health and epidemiology, animal health, weather modelling and communications. When it came to new technologies that could support research and development, cost was identified as the biggest barrier. In addition, a great diversity of collaborative partners was suggested, including universities and research institutes, nurseries and industry partners, foreign countries with effective biosecurity policies, and local and voluntary groups, such as citizen science networks.

Many respondents also suggested specific research questions, which have been categorised and listed in the accompanying technical report. Some of the suggestions included:

• impact of biodiversity loss
• modelling emerging threats and predicting impact
• natural resistance and replacement strategies
• information access and support

Additional biosecurity measures for high-risk trees (Annex to the consultation)

Summary of key themes

Current measures

When giving their score for both awareness of current measures and satisfaction with their efficiency, respondents were fairly split across the scale. Many who responded argued that the limits of the current measures were self-evident, whether due to being insufficient or due to poor adherence, although with some exceptions.

The greatest concerns cited by respondents around the import of high-risk trees was the robustness of inspection activity both at the border and in exporting countries. Members of the public (and environmental NGOs), tended to be more focused on the potential outcomes of at-risk imports (such as the establishment of novel pests into the landscape), while members of the trade were often more focused on the practicalities and issues around the operation of the current system.

Proposed measures

Of the proposed measures implemented before the border, prohibiting the entry of specific plants was generally identified as the most effective response, being especially favoured by landowners and members of the trade. At the border, tightening of restrictions on larger trees with soil was ranked overall the most effective measure, followed closely by increases in the inspection regime.

Inland measures generally received the lowest ratings for effectiveness when considered across the sample. Absolute quarantine was scored as the most effective measure (especially by landowners and the research sector), but also the one with the lowest feasibility for implementation.

Letter writing campaigns

During the Plant Biosecurity Strategy (PBS) consultation period, we received responses linked to a letter writing campaign from the environmental NGO, the Woodland Trust. The Woodland Trust encouraged their members and supporters to submit responses via a Woodland Trust portal which then transferred these emails to the PBS consultation mailbox.

Defra received 1,047 emails linked to the campaign. Members who submitted emails were provided with a template and suggested wording. The emails received by the PBS consultation mailbox linked to the Woodland Trust campaign were all identically worded. The responses were centred on a number of key concerns in relation to the protection of trees from threats posed by new pests and diseases.

1. Imports of new trees and plants

Respondents argued that the UK is too reliant on imports of trees and outdoor plants, and this reliance must be decreased. They argued that trade imports pose the greatest risk to tree health, compared with other issues. To reduce the risk of new pests or diseases arriving in the UK, and reduce the reliance on tree imports, the respondents argued that the biosecurity strategy must support UK tree nurseries and UK domestic production.

The letters also urged the government to implement a process where new high-risk host species are identified as quickly as possible and are then either quarantined or banned entirely. Where the species is considered a risky import, and put under enforced quarantine measures, the responses said this quarantine period must allow sufficient time for the disease symptoms to develop and be identified.

2. Investment in the UK nursery sector

Respondents argued that increased investment in the UK’s nursery sector is essential to address the reduction of the imports of trees. Respondents argued that the main barriers to growing more trees in the UK is competition from overseas, as well as a lack of funding provided in the UK, and that the government must provide direct support from grants to UK nurseries. To boost the availability of UK sourced and grown trees they suggested that funding for these grants could be raised from tariffs on high-risk imports. They argued that the government should also provide an increase of grant support for tree-planting schemes which use trees sourced and grown in the UK.

3. Public awareness and information

Respondents supported the need for society to play a more active role in protecting plant health. The respondents argued that, in order to do this, more must be done by government to improve demand for UK-grown, biosecure plants and promote awareness through wide-reaching campaigns to create meaningful change in public understanding and attitudes. They said the impact of this work should be publicly reported.

Respondents also argued that, in order to increase domestic production, the public should be able to make better informed decisions when buying plants. For example, they said that the UK plant passport scheme needs to be strengthened so that ‘UK grown’ plants don’t include plants which have just been re-potted in the UK. Whilst respondents agreed that public awareness is important for creating meaningful change, they insist that the government must work to raise this awareness and must take new measures such as the sufficient quarantining of imports.

Next steps

We will use the responses from the consultation, alongside feedback from stakeholders, to inform the development of a new Plant Biosecurity Strategy for Great Britain. This strategy is to be published in 2022 and will set out a vision for plant biosecurity over the next five years in England, Scotland and Wales.

The development of the strategy will be coordinated through the Plant Health Common Framework (a commitment to continue joint working in order to establish a common approach where devolved competence intersects with powers that have returned from the EU). The scope of the strategy, like the consultation, is limited to the biosecurity of plants and plant products (including but not limited to trees, vegetables, fruits in the botanical sense, wood packaging material and cut flowers).

1. The terms ‘we’ and ‘our’ are used throughout this consultation. In almost all instances, they refer to Defra, the Forestry Commission, the Scottish Government and/or the Welsh Government. ↩

2. This framework, along with the regulations in place across administrations in Great Britain, will seek to maintain the adoption of common plant health rules across Great Britain and the UK, whilst respecting the potential for divergence and managing the ability for one administration to take a different approach where technically justified. ↩

3. See the definitions of plant and plant products in EU Regulation 2016/2031. ↩