“Sod the wine, I want to suck on the writing. This man White is an instinctive writer, bloody rare to find one who actually pulls it off, as in still gets a meaning across with concision. Sharp arbitrage of speed and risk, closest thing I can think of to Cicero’s ‘motus continuum animi.’

Probably takes a drink or two to connect like that: he literally paints his senses on the page.”

DBC Pierre (Vernon God Little, Ludmila’s Broken English, Lights Out In Wonderland ... Winner: Booker prize; Whitbread prize; Bollinger Wodehouse Everyman prize; James Joyce Award from the Literary & Historical Society of University College Dublin)





15 October 2012


This is of vital importance to anybody who loves South Australian old vine wine, or any wine made from grapes grown on their own natural born roots:  

15 October 2012


 Alan Nankivell, CEO
46 Nelson St
Stepney SA 5069

Submission from:

Drew Noon
Noon Winery
P.O. Box 88
Rifle Range Road,
McLaren Vale SA 5171

Dear Board Members,

Re: Submission to the Phylloxera Board regarding risk assessment and the Plant Quarantine Standard

Declaration of interest:

I am a small, independent grape grower and wine maker with old vines planted on their own roots, in McLaren Vale. My livelihood depends on the quality these old vines are able to produce. I do not have the need or desire to move grapes or machinery into or out of South Australia. I have no financial interest in any vine nurseries or the sale of plant material.


South Australia has something special to protect in having phylloxera free vineyards. The Phylloxera Board’s role is to keep South Australia phylloxera free to maintain this advantage. The path that the Board is taking to align South Australia’s Plant Quarantine Standard to the National Phylloxera Management Protocol (as currently written) places South Australia at increased risk of a phylloxera outbreak resulting from the freer movement of grapes, machinery and plant material into South Australia this allows, from regions we’ve never accepted them before. This includes, alarmingly, regions alongside known phylloxera infested zones.

I call on the Phylloxera Board to take a precautionary approach to relaxing the laws which have kept South Australia phylloxera free for so long. If we allow phylloxera in through lack of precautions, it’s very likely there’ll be no going back (eradication is rarely successful). One mistake is forever.

We don’t have to relax our standards. The National Protocol sets out guidelines for the management of phylloxera but recognises that states determine their own regulations. There is no compulsion for South Australia to adopt the National Protocol as our laws.

The Phylloxera Board is promoting “Farm Gate Security” to growers and we all need to practice this but I call on the Phylloxera Board to get on the front foot, at the border and maintain our first line of defence. We expect you to protect our state from phylloxera, we can protect our farm. The Board appears to be walking away from this responsibility, advising growers to provide their own defences when the pest arrives at their door. The battle is lost by then. This approach is not acceptable. This is not what levy payers expect from the Phylloxera Board.

Where is the risk in adopting the National Protocol?

The Phylloxera Board is negligent in its duty in accepting the National Phylloxera Protocol (as currently written) as the basis for our laws. It incurs a heightened and unacceptable level of risk to South Australia in doing so.

There are two principal new risks incurred to South Australia from adopting the National Protocol.

They are:

1. The risk posed by the upgrade survey.

The survey is critical because it is used to establish area freedom.

If an area is considered free of phylloxera by the survey, then it can move risk vectors to other phylloxera free areas (such as South Australia) under the National Protocols (as currently written). The survey needs to be of a rolled gold standard. The problem is the current survey is not good enough. This has been demonstrated in practice in the Yarra Valley (see the Yarra Valley Case Study page 16 & 17 available on the Phylloxera Board website). Subsequent research by DPI Victoria Biosciences Research Division has found both a DNA probe and emergence traps more effective at early detection than the root survey. Even when repeated twice over a three year period as required by the Protocol, there is significant risk that the survey would miss a low level infestation.

The Phylloxera Board has considered the risk posed by the survey in its recent Risk Assessment September 2012 and rated it as LOW. Where is the science behind this rating? What are the confidence levels provided by the survey of detecting a low level infestation? This assessment is subjective and not based on fact. There is no information offered to support this rating.

The reality is we do not have any survey method that is good enough to establish phylloxera freedom and until such time as we have one available, we should not accept claims made by new areas on the basis of the current survey. This represents a big new risk to South Australia.

2. The risk posed by proximity to an infested area (a PIZ):

This is another risk of concern to growers which the Board has considered in its recent Risk Assessment September 2012 and rated as LOW. This defies common sense and invites doubt about the credibility of the Risk Assessment.

One only has to look at where all the outbreaks have occurred in the past 15 years to illustrate that regions closer to the infested areas are at greater risk. This is why the PIZ boundaries keep getting extended. To deny there is a significant proximity risk causes a loss of confidence in the Board and the risk assessment process. Where is the science to support the assessment that the risk relating to proximity is Low?


Other new risks flow from these two.

That is:

Because there is a significant risk the survey would miss a low level infestation, the risk posed by allowing grapes, machinery and plant material in from new regions declared phylloxera free on the basis of the survey is too high.

Because proximity to an infested area brings higher risk of an outbreak, we should not allow risk vectors into South Australia from areas alongside infested zones, which you have already sanctioned and is currently allowed.

What we want:

I call on the Phylloxera Board and the regulators to stop making changes to South Australia’s Plant Quarantine Standard to align with the National Phylloxera Protocol (as it is currently written). I support the Board’s proposal as stated in the “Risk Assessment September 2012” document that the Plant Quarantine Standards “remain as they are now proclaimed as at July 2012.”, provided that South Australia adopts a precautionary principle in relation to new PEZs declared since 2000, treating them as Phylloxera Risk Zones in light of the significant risks they pose as discussed above. I want the Phylloxera Board to promote this change to PIRSA and the regulators so that this upgrade to SA’s Plant Quarantine Standards will be made without delay.

I want the Board to get on the front line in protecting South Australian vineyards from phylloxera rather than bowing to pressure from other states interests including nurseries who want access to our market and some big wine companies who want to be able to move grapes into South Australia to centralised processing wineries for financial gain. The Board’s mission is to protect South Australian vineyards from phylloxera and I want you out there doing just that. Not promoting “farm gate security”. That is principally my responsibility. Yours is to make policies to prevent phylloxera getting into South Australia by protecting our borders. Leaving our Plant Quarantine Standards as they are and classifying new PEZs as PRZs would provide strong evidence you are doing that.

Growers I talk to are not silly. They have absolutely no appetite for increased risk from phylloxera and they expect the Phylloxera Board to ensure adequate protections are in place. In particular to protect them from the risk posed by Victoria and the movement of grapes and other risk vectors. If they knew that you were sanctioning a relaxation of the protections that have been in place, they would be furious.

At our McLaren Vale Phylloxera Board stakeholder meeting, one senior grower who sat in front of me during the presentation and didn’t say much, turned around at the end and asked incredulously “who’s paying these guys?”, another during the presentation called out “it sounds like you’re asking us to practice unsafe sex”. Growers (your stakeholders) are not happy with relaxing the standards. They see no benefit to them, only to the other states and big wine companies.

These changes are being made at a time when phylloxera is on the move in Victoria more than at any time since introduction of the pest in the late 1800s.

I suggest that 50 years from the last outbreak would be a good time to begin discussing relaxing the quarantine standards with South Australia’s grape growers and I’m not sure you’d get any sympathy then!

This is certainly NOT the time to be dropping our border protections. Rather, growers would like you to be strengthening them.

Comments on the Phylloxera Boards 10 risks and proposed actions:

I endorse the McLaren Vale Grape Wine and Tourism Associations comments in their submission in relation to these risks and proposed actions.

In terms of priority, these risks and actions should be dealt with after dealing with the treatment of all new PEZs as PRZs. This change in the definition of a PEZ in our Plant Quarantine Standard should be made urgently and completed before January 2013 and the next grape harvest.

Changes required to the National Phylloxera Management Protocol:


The Protocol needs changing to protect all members of the industry nationally.

The survey as defined in the Protocol can only establish a low risk area rather than a pest free area. We have no survey methodology at present rigorous or robust enough to establish pest freedom. The difficulty of early detection of phylloxera and the need for better methods is well recognised by research scientists. Hoffman and Herbert (2006) in their paper titled “Finalising and validating a diagnostic tool for the early detection of phylloxera” state that “There is an urgent need to develop a phylloxera-specific detection system…” so that phylloxera detection would not rely on “problems with visual detection…” Until we have such a proven system for early detection, we should not be relying on the root survey as outlined in the National Protocol. It isn’t proven or supported by science and the risks and costs of a mistake are too high.

Therefore, I call on the Phylloxera Board of South Australia to argue this case at the national level, through the National Vine Biosecurity Committee, for a change to the National Protocol to require treatments and precautions to apply to the movement of risk vectors from PEZs declared since 2000 to other PEZs, the same as are applied from PRZ to PEZ, until such time as we have a survey proven by science to be robust enough to establish pest freedom and an on-going survey programme in place to ensure this status is maintained.

History shows that phylloxera has avoided containment all around the world. Australia is in a unique position to maintain its old vine heritage and advantage over other wine producing countries. Our strict quarantine standards have defied the odds so far. Giving up this advantage by taking unnecessary and unquantified new risks would be a tragedy.

The Phylloxera Board and the State Government have a duty of care to apply a precautionary principle in relation to phylloxera risk. Please take this precautionary approach to the national forum to protect South Australia and all regions from a potentially tragic mistake and in the meantime please increase rather than decreasing our own level of protection in South Australia’s Plant Quarantine Standard.

With many thanks,

Drew Noon.



1 comment:

Daniel - Wine Club Guide said...

Wow. What an informed and passionate response, replete with both strong practical and theoretical knowledge. Obviously this is someone who, knowing that wine making is a fundamentally agricultural act, knows that the government must protect the agricultural aspect of the industry through strict regulation and control. To be honest I did not know the that Board was going lax, but it certainly would devastate farmers like Noon if phylloxera ravaged the old world vines in Australia. Thank you for posting this and bringing it to my attention.