Phylloxera Laws Loosened In Oz
Drew and Raegan Noon are modest quiet people. They work hard to make real wines the way their customers love them, keep their prices incredibly low, and sell out in just a few days, every year. Drew, a Master of Wine, plays a staunch quiet role assisting his beloved McLaren Vale move to a more ecologically-aware future. So while they have many reasons to crow, the cocky rock star winemaker image is something that just don’t fit the Noon template. So it’s confronting to find them both seething and cranky.
On the 16th of January 2012, the Noons wrote a letter to Gail Gago, the new Minister for Agriculture, Food and Fisheries, enquiring about changes to the laws which are designed to limit the spread of phylloxera to the infected areas of Victoria and New South Wales. Phylloxera is the dreaded root louse that demolished the vineyards of Europe, and many in eastern Australia, a century ago. Phylloxera is nearly microscopic. Phylloxera never leaves. Viable phylloxera has been found in carwash sumps in Melbourne, and has been caught in a windsock dragged behind an aircraft flying at 30,000 feet over Europe. When it ravaged Victoria, it gave South Australia the chance to dominate the viticulture business, which is has done to this day.
Miraculously, phylloxera has never been found in South Australia. But then, it’s not so much of a miracle. It’s largely the result of very rigid transport protocols which were imposed by winemakers themselves long ago. Protocols which many people want relaxed.
Three stages of phylloxera: adult, crawler, and egg.
It’s a complex story, and long, but I see more trouble than advantage in attempting to paraphrase it. This is what the Noons wrote:
“It appears to us that South Australia has recently weakened the rules protecting our grape and wine industry from phylloxera, without consulting or informing the state’s primary stakeholders in this area, the grape growers and wine producers. The changes mean that South Australia will now allow entry of grape harvesters (and other machinery and equipment) from interstate through simple proof that they have come from a Phylloxera Exclusion Zone (PEZ) without even the requirement to clean the machine.
“Prior to this, harvesters coming from an interstate Phylloxera Exclusion Zone had to be cleaned and accompanied by a permit obtained from the Chief Inspector certifying they had been operating for at least two weeks in an area free from phylloxera, before entry into South Australia.
“South Australian grape growers have been paying a levy to the Phylloxera & Grape Industry Board of South Australia since 1899 protecting SA from the pest. There have been at least 7 new phylloxera detections in Australia in the last 10 years but prior to that it had virtually not moved for almost 100 years. Therefore I ask you why does SA appear to be (without wide industry consultation or notification) breaking down the barriers to entry to South Australia and putting our state’s grape growers at so much greater risk at this time? And why are these changes required, what harm is the current system doing?
“On the face of it, perhaps one could argue that the changes are required on the basis of fair trade. If a region interstate has been surveyed and found to be free from phylloxera, there should be no risk of spreading the pest so we can’t justify imposing barriers at the border...but what are the real risks and what about the consequences of a mistake?
“The real risks relate to the quality of the phylloxera freedom surveys and their maintenance over time.
“We believe that the interstate surveys are not rigorous enough. Phylloxera is initially difficult to detect when infestations are new, affecting just a few vines in a block and typically taking years to spread to a few hundred, at which point it will typically be detected either by the farmer and/or by a survey. But the current Victorian freedom surveys are being conducted over only three years, so there is the likelihood that a new infestation would be missed. The surveys should be conducted over a minimum of five years and preferably seven to increase the probability they will pick up a new infestation. Given the implications of a mistake, we need to be very confident before declaring a region phylloxera free and opening the barriers to entry to this state. Three years is not sufficient time to be very confident.
“Secondly, there is the problem of maintenance of the phylloxera freedom status over time. The Bendigo/Heathcote region in Victoria has recently been surveyed and declared phylloxera free but it sits alongside the Nagambie Vine Disease District where phylloxera is known to be present. It is consequently at much greater risk of a phylloxera outbreak in the short term than regions further afield. But this is not recognised by the current rules, whereby Phylloxera Exclusion Zone (PEZ) status gives the region the same easy entry of equipment and grapes into South Australia as for any other Phylloxera Exclusion Zone (PEZ).
Drew Noon MW
“All PEZ’s are not equal! Some represent a much higher level of risk than others. The fact that we have declared a region a Phylloxera Exclusion Zone doesn’t reduce its risk level. It just means we can’t find phylloxera there at the time of the survey. And how often have we committed to resurveying these regions, to ensure they are still phylloxera free? In the case of the high risk regions, every year or two years at most would be necessary. In fact they should never be considered ‘safe’ for direct importation of equipment (or fruit) as has just been implemented. This presents an unacceptable level of risk for South Australia’s growers.
“We need to recognise that there are gold standard PEZ’s (say Western Australia) and some that are bronze at best (say Bendigo/Heathcote). By failing to recognise the varying risk levels of the surveyed areas and dropping the border rules for all Phylloxera Exclusion Zones, we are expediting the passage of phylloxera into South Australia. Bendigo/Heathcote (or any region that is in close proximity to a known phylloxera area) will always represent a higher risk for importing phylloxera than regions further afield and the current rules don’t recognise that.
“If we don’t change that soon, it may be too late. If we let phylloxera into South Australia through our lack of vigilance, we will have to live with it forever. Please don’t let that happen on your watch.
“We are also very concerned the changes to the current rules for equipment (Condition 7A) and soil samples (Condition 8A) could be the tip of the iceberg in PEZ to PEZ freedom of movement... will we blink and find a dilution of the requirements for the movement of vines and grapes next?
“Please help keep South Australia phylloxera free by maintaining our border protection rules. As a minimum, we would like to see the changes to condition 7A & 8A revert back to version 8.1 of the Standard as soon as possible.
“Thank you for your attention to the concerns we have raised. We are happy to provide any further information you may require.
“Given the importance of this matter to South Australia and the urgency of it with the grape harvest already underway in the earliest regions, we kindly ask if you could provide a specific response before the end of January, giving reasons for any decisions you make.”
At the foot of the letter was the appropriate disclaimer:
“Raegan is a member of the Phylloxera and Grape Industry Board of SA (PGIBSA) but the views expressed here are her own and in no way claim to reflect those of the PGIBSA.”
Once vintage was done, Drew got back on the keyboard. They had received no response. This time, he circulated the letters to various stakeholders around McLaren Vale.
Having reminded the reader of the content of the first letter, he added the following:
“As outlined in our letter to you of 16 January, our reading of the new Plant Quarantine Standard suggests that the requirement for wine grape machinery entering South Australia to have prior written approval from the Chief Inspector has been dropped, where the machine is coming from a Phylloxera Exclusion Zone. In fact it appears in that case, under the new rules the machine is no longer even required to be cleaned before entering South Australia. This would apply even though it could be coming directly from an Interstate Phylloxera Exclusion Zone such as Bendigo/Heathcote which sits right alongside a known, longstanding Phylloxera Infested Zone.
“In your reply to us, we would like an assurance from you that any wording changes in the new Plant Quarantine Standard will not allow the movement of equipment, under any circumstances, into the heart of South Australia without prior written approval from South Australia’s Chief Inspector and the requirement that the equipment be clean as per the rules under the old Plant Quarantine Standard.
“If for any reason you cannot give us that assurance, then it would appear that the rules have indeed changed quite meaningfully and we think SA grape growers have a right to know and be consulted about the change. This has not happened to date.
“Many thanks for your attention and we look forward to circulating your correspondence regarding this matter to others who share our concern that any changes to the Plant Quarantine Standard SA may weaken our border protection, threatening South Australia’s winegrowers and especially our precious older vineyards.”
This time they got a response within a few days.
“Recent changes to the Plant Quarantine Standard were undertaken to align South Australia with the National Protocol,” Minister Gago wrote.
“South Australia recognizes that there are areas outside of the state that are free of phylloxera. The previous requirement to disinfect machinery and equipment is considered unnecessary when moving between Phylloxera Exclusion Zones. However, machinery and equipment is still required to be certified free of plant material and soil and have a proof of origin before entering South Australia. These changes were made on the basis that a phylloxera exclusion zone has a very low risk of phylloxera being present and do not place South Australia at increased risk of a phylloxera outbreak.
“I have been informed that the National Phylloxera Management Protocol establishes the criteria and requirements for conducting vineyard surveys to detect the presence of phylloxera. These requirements are science based and agreed at the National Vine health Steering Committee.
“I understand that the Plant Quarantine Standards have been agreed to by Biosecurity SA and the Phylloxera and Grape Industry Board of South Australia with input from the Mclaren Vale Grape Wine and Tourism Association who are currently reviewing the wording to ensure the section is consistent with the national protocol and is clearly expressed. This has involved consultation with representatives from industry and other stakeholder groups.
Gail Gago, South Australian Minister for Agriculture, Food and Fisheries
“I want to assure you that while there have been some changes made to South Australian practices, these have been simply a measure to ensure consistency with the National Management Protocol, and are not a reduction in scrutiny or commitment to protecting this state.”
The Noons are not happy.
“It hasn’t addressed our concern that SA is now accepting fruit and machinery from regions in Victoria that sit alongside phylloxera-infested areas,” Drew responded. “The Minister simply says that the changes are consistent with the National Phylloxera Management Protocol, which was drafted a long time ago and treats all Phylloxera Exclusion Zones as the same. That’s what needs to be very carefully re-written.
“We think this is wrong and that we need to recognise high risk PEZs like Bendigo/Heathcote, and low, like the whole of Western Australia. This was never taken into account when the Protocol was drafted. It’s crazy to accept such a risk and growers don’t know about it. They think the Phylloxera Board of SA is watching out for their interests...but we don’t hear them explaining the changes and justifying them to growers!
“The National Protocols were drafted long before the Yarra got phylloxera in 2006. The game changed then and those National (Science Based) Protocols need review in light of the heightened and evident risks.”
“Given that it only takes 1 phylloxera insect to start an infestation, who is asking if there are any assurances that the phylloxera surveys are good enough to detect a low level infestation? Are there any phylloxera detection probability statistics on the current survey method? Are they 98% sure that the survey would find phylloxera if it were there at all? How sure are they?
“What level of risk is acceptable to SA growers who have everything to lose here?”
It seems that this conversation is far from over.
The Noons want to know who would benefit from the changes which have been quietly made.
Phylloxera gutsing on vine root.
“Who benefits?” Drew asks. “Primary Industries and Resources SA, for convenience, cost & paperwork. Large winegrowing companies moving grapes and machinery around the country, for convenience, cost & paperwork. Victorian companies moving machinery into SA for convenience, cost & paperwork. The Victorian Department of Primary Industries, to justify the millions spent on phylloxera surveys. The Australian Vine Improvement Association, to assist nursery interests in PEZ to PEZ freedom. They benefit.
“But who doesn’t? South Australian Growers (especially those with old vines on their own roots) who are rarely or never involved with moving grapes or machinery from interstate and have everything to lose from a phylloxera outbreak? What level of risk is acceptable to these SA growers who have everything to lose here?”
This discussion has been bubbling away for years. I wrote about it at length in 2009. As did McLaren Vale vine scientist James Hook. It is a long intriguing yarn about deeply vested interests, secretive backroom boyos, arcane political maneuverings and lots and lots of money. The whole pile exudes not only the carrion reek of suspicion, but an infuriating wall of silence. Rae Noon was so frustrated with the lack of detail and information that she joined the Phylloxera Board, to get directly involved.
It does seem strange that a board member has to write to the Minister to find out precisely what is going on. If a board member must make such an enquiry of the Minister, one can only wonder what the board would be advising the Minister.
Minister Gago is the wife of Penfolds Chief Winemaker, Peter Gago, a man highly dependent upon precious old vineyards on their own roots. As much as far-flung viti outposts all over Victoria and New South Wales.
I’m involved, too: I have visited north-eastern Victoria on several recent occasions. It’s very confronting, coming home, to drive past the unmanned quarantine bins at the border, and suddenly realize that you’ve just been in the heart of phylloxera country visiting wineries, and saw very little there that advised you of the dangers of what might be on your boots or the muddy bottom of your car.
As for trucks and machinery? Surely a bloke who’d risk illegally removing the speed limiter from his truck would be happy to wait somewhere for an hour or two while some brains trust in a white coat steamed its guts with disinfectant? Oh? The crooks are only the minority?
DRINKSTER often wonders what phylloxera protocols were observed by South Australian country firetrucks whilst fighting the Victorian bushfires in 2009 ...
As these letters have done the e-mail rounds, some alarming comments have been made.
This is from veteran Barossa vine nurseryman and owner of 145 year old Grenache and 118 year old Riesling vineyards, Wayne Farquhar:
"Here we go again, when are we going to get bureaucrats who make these changes to realise they are potentially putting an end to the Wine Industry in South Australia as we know it.
"I have attached a letter that I sent to industry back in 2009 for your reading, pointing out exactly the problems that were facing us in SA and this new Plant Health Act change is no surprise.
"PIRSA are unable to enforce the Plant Health act, and simply make changes to make it easier for them to administer. A good example of this is when the act started in 2009 PIRSA was to monitor imports of grapes products into SA by transport manifests, this was dropped as it took too much time as there were too many manifests. SO WHO IS CHECKING WHAT COMES INTO STH AUST?????
"I have given up the fight as the politics of all this is overbearing and it seems impossible to get anyone to listen to reason.
"Good luck - copy of letter follows:
"Re: Recent Changes in Planting & Processing by large Wine Companies is putting Australia at risk of Grape Phylloxera spread, and loss of Old Heritage Vines.
"Within the last six years Australia has suffered an increase in export pressures from other counties like Chile, Argentina, Spain, Italy and even America and France. Also in this same period Australia has faced an oversupply of wine grapes resulting in surpluses being held by large wine companies. To combat this increased competition in the market place, most large wineries have restructured their businesses in an attempt to maintain profitability.
"Part of that restructuring has been to ensure long term viability of new vineyards planted, with most large companies using rootstocks on new plantings in order to ensure long term production without the fear of Phylloxera infestations destroying vineyards. It has also resulted in a centralising of process facilities to ensure maximum use of fully automated technology, and the sale of surplus facilities assisting bottom line profits by consolidation.
"Whilst the centralisation of crushing will certainly have an impact on the profitability of large wineries in Australia it can also be said that this is putting Australia at an increased risk of the spread of Phylloxera. A paper titled “Pest Risk Analysis for the establishment of a new infestation of Phylloxera in Australia as a result of harvest processes” which can be found at http://www.gwrdc.com.au/nvhscphylloxera.htm along with other Phylloxera related protocols begins to explain why.
"This paper lists whole grape harvesting & transport as the greatest risk of spreading Phylloxera, greater than machinery, must, vehicles & tourists. It seems that Phylloxera crawlers migrate to the canopy between December – March during harvest time and if mechanical harvesting is carried out a large number of these crawlers end up in the grape bins. The risk analysis puts the crawlers at an extremely high likely hood of travelling into other regions and being able to escape and multiply into new vineyards.
"Now to put this in some form of perspective it is important to do a quick review of current protocols to assess how strict they are, and do they reduce the risk of harvest transmission of Phylloxera. Are the existing legal protocols adequate for whole grape movement? Are any current changes planned within the planting and processing of wine grapes by large companies? If the answer is yes, then this is a pretty scary thought for all Heritage Old Vines and own roots vineyards around Australia.
"The Tasmanian and Queensland whole grape protocols allow for the importation of whole grapes if grown on a property outside a 40 kilometre radius of a known Phylloxera infestation (in other words the property must be over 40 kms away from an infestation).
"The South Australian, New South Wales and Victorian protocols allow whole grapes to move freely between declared PEZ’s. A PEZ is a declared phylloxera free area. A PEZ may border a PRZ or a PIZ. A PRZ is a zone that might have Phylloxera and a PIZ is a zone that has Phylloxera. South Australia, New South Wales and Victoria also allow the movement of whole grapes from PRZ’s (a zone that might have Phylloxera) to PEZ’s if that property is found to be free from Phylloxera after an annual inspection under protocols developed by the National Phylloxera Technical Reference Group and authorised by the appropriated state Government authority.
"The protocols giving status to these PEZ’s and PRZ’s are where current planting and processing practises, allied with the centralisation of crushing by large wine companies are putting all the Heritage Old Vines in Australia and own roots vineyards at risk.
"At recent Phylloxera meetings held in South Australia by the PGIBSA, Dr. Kevin Powell Australia’s top researcher into Phylloxera said that the Phylloxera outbreak in the Fosters Vineyard in the Yarra Valley probably occurred in 2001 and was only visible in 2006 a total of 5 years from infestation to detection. Under current protocols a PRZ can gain full PEZ status only after 3 years of surveys to detect Phylloxera, and new emerging regions after only one year, yet Dr Kevin Powell is indicating minimum of 5 years or longer which would also depend upon the soil type, moisture and temperature.
"The other anomaly is that if a zone is being re-classified from a PRZ to PEZ, the movement of grape plant material into the PRZ is unrestricted up until the time the PEZ is declared, then and only then do the PEZ protocols take effect and restrictions apply to the movement of grape material and grape plants into the PEZ. This is at odds with what Dr Kevin Powell is saying about 5 years or longer before the likely hood of phylloxera presence being detectable. If you take this simple statement at face value it would mean that a newly declared PEZ zone should not be given full freedom of movement until a further moratorium of 5 years or longer has elapsed. Put simply the newly declared PEZ of Heathcote/Bendigo that took place in 2009 should continue to be inspected and not allowed full freedom of whole grape movement until 2014 or longer, in case phylloxera was introduced leading up to the day the zone was declared a PEZ.
"Remember Phylloxera crawlers are present many years before the visible evidence of vine decline takes place, and the risk of moving these crawlers with whole grapes due to the freedom status of a newly declared PEZ is quite real. Compounding this is the fact that grape bin loads from PEZ’s do not have to be covered, allowing the crawlers to blow out along the way to the centralised crushing facility.
"When you apply this thinking to the newly declared PEZ of Heathcote/Bendigo which has had rapid development in the state of Victoria where all the recent Australian Phylloxera incursions have taken place, it makes one realise that the declaration of the PEZ without a further moratorium of 5 years or longer for whole grape movement and grape plant material is extremely high risk. Further complicating this is that in recent years large wine companies have increased the use of Phylloxera tolerant rootstocks in new vineyard plantings. The use of rootstocks in a vineyard puts a mockery to the annual inspection protocol as Phylloxera presence will most likely never be detected as the vines on rootstock will not show any signs of decline. The increased use of rootstock could mean that Phylloxera crawlers are spread everywhere long before detection, and that detection will most likely be the newly infected vineyards not the source vineyard.
"Also putting Phylloxera free zones at risk is the Vine Industry Nursery Association’s (VINA) representation to the NSW Department of Primary Industries “Directors Approval” where VINA accredited nurseries can take cuttings from vineyards in PEZ zones like Heathcote/Bendigo and send them into New South Wales to VINA accredited nurseries without Hot Water Treatment, so long as they are ultimately treated prior to propagation in NSW. This is an extremely high risk scenario as it is too late treating the cuttings after the Phylloxera has been allowed to travel and escape into the new region.
"As can be seen from the discussion points above, Australia is at an increased risk of Phylloxera spread, due jointly between the protocols that currently exist and the changes of the way large wine company’s plant new vineyards and more importantly the centralization of processing to maximise their profitability through advanced technology. The risk associated with new protocols for the movement of grapevine planting material are also increasing the risk of further infestations of Phylloxera throughout Australia.
"Don’t be complacent your future is at stake, whilst there has been numerous recent changes to Plant Health Act’s etc, that give stronger penalties to individuals who deliberately break rules, here we are talking about the existing current protocols.
"BE ACTIVE, HAVE A SAY, AND SEEK ANSWERS!
"Yours Sincerely, Wayne B Farquhar, Frill Hill Vineyards, Barossa."
... and another, from a bloke who knows what he's talking about:
"Hi Noon family
"I just wanted to congratulate you both on a very well written letter and for raising the questions about the relaxed attitude that now exists in regards to PEZ. If the South Australian Wine Industry is serious about preventing a Phylloxera outbreak then shouldn’t ALL interstate transfer of grapes or vineyard machinery be banned? We should be increasing the measures of protection not decreasing them. I am very concerned about the relaxed attitude that seems to be descending on this matter. I am unsure what I can do as an individual but I offer my support to you wholeheartedly.
"Regards, Justin Lane, Alpha Box & Dice."
ALL THE ABOVE HAS BEEN CIRCULATED TO MINISTER GAIL GAGO AND LOCAL MEMBER LEON BIGNELL. THIS TOPIC DESERVES URGENT DISCUSSION. PLEASE ADD YOUR OPINIONS BY CLICKING COMMENTS BELOW: