3.5 Ctenopseustis herana, C. obliquana, Planotortrix excessana and P. octo
AFFA considers that the probability of entry of these species is moderate. New Zealand believes that this is a considerable over-estimate of risk.
3.5.1 Probability of entry
AFFA has not assessed the likelihood of these leafroller larvae being present on or in apple fruit at harvest. As these pests have the capacity to reduce the marketability of apple fruit (quality) the export industry takes measures to minimise pest levels. MAF has provided to AFFA information on these industry operated programmes (Integrated Fruit Production) and these have been considered in some sections of the draft IRA. New Zealand asks that AFFA take into account that the level of fruit infestation at harvest will be very low.
AFFA suggests that larvae in the calyx or feeding internally on the fruit may not be detected during pre-export or on-arrival inspection of the fruit. It is our experience that there are signs such as webbing, frass or an entry wound to suggest that internal feeders could be present. If these signs were seen by an inspector, they are required to investigate further to determine if larvae are present in the fruit. Normal AQIS inspection techniques will therefore be useful in detecting these pests.
AFFA have stated in the draft IRA that they have intercepted these pests on apricots, avocados, cherries, nectarines and peaches from New Zealand at the standard on-arrival inspection. AFFA presumably considers that MAF pre-export inspection and AQIS inspection is sufficient to detect pests on these crops, so a similar policy should apply for apple fruit. New Zealand asks that AFFA employs a consistent approach to the application of phytosanitary measures between pests on similar commodities.
AFFA have also referred to the importation of these pests on other crops from New Zealand when discussing the effect of storage and transport on the probability of entry. Stone fruit, avocado and cherry fruit are cool stored between harvest and sale, however, these fruit are generally air-freighted to Australia within hours of picking. The period of time spent in coolstorage is minimal. In contrast, apple fruit generally spend a considerable period of time in coolstorage before and after export. In addition, it is expected that apples will be sea-freighted to Australia in coolstorage which will likely take 3-4 days. New Zealand asks that AFFA takes into account these different importation pathways when assessing the probability of entry. New Zealand believes that the probability of entry is very low.
| New Zealand requests that AFFA takes into account the following when assessing the risk of entry: that the level of fruit infestation at harvest will be low, that visual inspection techniques will detect the pest, and that storage and transport will reduce the likelihood of survival of the pest. |
3.5.2 Overall assessment of risk
AFFA should maintain consistency between measures required for these pests on other crops and the measures required for apples. New Zealand does not consider that these pests would be any more difficult to detect on apples. The storage and transportation conditions for apples involve longer periods of cool conditions and this is likely to adversely affect pest survival.
| New Zealand believes the overall estimation of risk is very low. |
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