As a GERMAC member and a fully operational importer in a range of high value species and one of few that actually utilise Level 3 quarantine facilities regularly, the company says, in fact – all the time and ten years forward, at this point – it makes the following comments:

The first point is the big picture – if New Zealand as a country doesn’t invest in facilities for robust border control and the import of new germplasm, it simply doesn’t protect its current aghort production, let alone increase exports. Furthermore NZ, as a geographically isolated country of horticultural exporters, becomes less competitive. From a New Zealand perspective, there is a significant public good component in that (just like Australia have recognised and invested in the AU$380m Mickleham facility) and on that basis our government needs to invest in the import process.

Bloomz says that Level 3 standards for PEQ have been raised to Level 3b by default when, in fact, there may be little justification to do so in a number of the high value crops that are the most regular users of Level 3 space, and unlike other regular imports do not have an option to use L2. The re-examination of such IHS’s (eg vaccinium, fragaria, rubus, etc) is a major and urgent priority to avoid a complete collapse of the current arrangements.

Until the PEQ review that effectively raises the bar to Level 3b there were only three Level 3 greenhouse facilities in NZ – PHEL, P&F and Arborgen (in the process of being reinstated). P&F for their own reasons are selling their facility and Arborgen will operate at only at the current Level 3 (the new Level 3a). That leaves PHEL as the only option for higher Level 3b.

The company reports that some have commented that cost is the main issue when selecting a quarantine facility, and on that basis importers prefer to wait till cheaper PHEL space is available.

Cost is not so much an issue as is timeliness to large offshore breeders. The lack of Level 3 space (a or b) in a currently subpar national facility like PHEL (look at the minimal size of their TC facility) is the major issue. Notwithstanding the space issue, PHEL staff do an excellent job in cramped and outdated facilities – Bloomz commends them for that.

Given that PHEL is booked out till at least the end of 2019, and as it is the only current 3b facility going forward, there is clearly a requirement in the national interest to urgently address high-level import quarantine capacity, and therefore comments about importers choosing on a cost basis have become irrelevant.

The company notes that some importers simply don’t want to use the current alternative due to conflicts of interest; actually nothing to do with cost. When a private facility is doing its own breeding and development then other importers are less likely to place material of the same species in such facilities.  The development of a private facility will also face the same issues as would not be totally independent. Furthermore, a private facility may focus on selected species of interest to the operator, and not provide a full suite of services.

As Australia has recognised, government has a role in protecting the public good and the very industries it is promoting to increase exports – leaving it to a private operator to pick and choose what comes into the country is an undesirable outcome.

One of the biggest import quarantine cost and resource issues is MPI verification. This is a separate cost to housing and testing at the likes of PHEL. This is a different MPI department from PHEL and by being based in Auckland or Wellington, effectively disadvantages other geographically located private facilities given the huge disparity in costs of inspection services. A quarantine period of fifteen months has mandatory ten inspections by an MPI verification officer (only two or three in Australia for the same species), and with each visit to a location outside Auckland or Wellington involving extra charges of up to $1000 per visit could possibly add $10,000 per quarantine. This is a disincentive to the establishment to any private facility outside of Auckland or Wellington, and notably a separate component to the actual facility operating cost.

Bloomz says that the current single Auckland-based MPI Verification Officer, Abu Iqram, does a good job in very busy circumstances but leaves MPI Verification services in a precarious position if he leaves or is incapacitated. It understands a new officer is being trained for the Northern area, but the geographic cost issue remains.

Expecting return on capital in terms of a national facility may simply not be possible, whereas cost recovery on operational costs is probably realistic. The Public Good issue needs to be considered in this matter.

Bloomz understands MPI is considering the adoption of new, more efficient and cost effective testing protocols e.g. NGS (Next generation sequencing). The older methodologies such as woody indexing are expensive, slow and need review – this is currently adding to the bottleneck.

Furthermore, the way tests are programmed in New Zealand, i.e. PCR and virus testing, tend to be in the last stages of PEQ, whereas in Australia are in the earlier stages of the process. This potentially adds to the length of the quarantine period and the length that L3 security required, e.g. in Australia, the first two thirds of some high value crops are done in Level 3 but are then moved to Level 2 for the balance of the quarantine, thereby immediately releasing valuable space.

Although a little outside this discussion, the opportunity to collaborate with Australian Quarantine, in the case where high value species are simultaneously entering Australia and New Zealand, in most cases by the same importers, is a reality.

Bloomz says it’s pleased to see MPI follow this up, further to the company’s own discussions with Australian Quarantine operators. It has recently made available to MPI, Australian testing protocols for a full range of high value crops (vaccinium, rubus, fragaria, malus, vitis, actinidia) that clearly demonstrate a different approach to testing of in most cases the same regulated pests. In the event a standard quarantine protocol (even with a few exceptions) can be established for both countries then the economic and space benefits are obvious.

Summary

As an operational importer, Bloomz strongly supports the development of a national quarantine and testing centre that will use state of the art testing protocols and have sufficient capacity to support government’s economic aspirations to double exports. It urges GERMAC and other interested parties to lobby Government for investment in this critical area.

There is no doubt the fastest growth area is in high-value horticultural food crops, and this needs to be supported and encouraged at a national level.

Andrew Warren is the NZFGA representative at GERMAC and works positively with MPI retaining a cordial relationship to achieve good and workable outcomes for all industry users of the PEQ facilities and in other areas where importation of new Germplasm is bottlenecked.