Select Committee on Environmental Audit Minutes of Evidence

Examination of Witnesses (Questions 1 - 19)




  1. Good morning, gentlemen, welcome to the Committee and thank you for coming. Is there anything you would like to say, either on behalf of the Pesticides Trust or the RSPB, before we start asking questions on the written evidence you have given to us?
  (Dr Avery) From the RSPB, no, thank you. We are here to answer your questions and we are very grateful for the opportunity.
  (Mr Buffin) We submitted our written comments last week.

  2. There is nothing you want to add.

  (Mr Buffin) No.

Mr Gerrard

  3. We have seen data from the Environment Agency and to some extent from the National Farmers' Union (NFU) as well, which suggest that there has been some overall decrease in pesticide use over the last 10 years. Do you think that is right? How do you think pesticide use has changed over that period?
  (Mr Buffin) It depends in what way you mean. Presumably by weight.

  4. Yes, there seems to be a decrease in the total weight of active substances according to the Environment Agency.
  (Mr Buffin) It depends whether you include things like sulphuric acid, which is a bulky chemical. The issue when relying on the weight of active ingredients is that you are dealing with a whole range of different chemicals which have various properties. If you look at the area treated, then the figures are different. It is a very complicated area that is difficult to look at simply in terms of the weight applied but obviously you have the figures and have considered them.
  (Dr Avery) It is a complicated subject because the active ingredients are changing and therefore weight is a poor measure. We would be fairly convinced that the effects of pesticides used on biodiversity on farmland have either remained the same or increased. We do not see things getting better. If you look at the percentage of cereal crops on which herbicides, for example, have been used, over the last 20 years, the use has gone up considerably. It has gone up from an average of fewer than 1.5 applications per year to nearly 2.5. It would be misleading to take the figures at face value and to suggest that things are getting better because we are pretty convinced that things are getting worse in terms of the effects of pesticides which are being used.

  5. How far do you think it might be possible to predict what trends are likely to be over the next few years? There have been some suggestions that MAFF commissioned some research which suggested we might see some increases. A wide range of figures was quoted from just over a one per cent to just over a 19 per cent increase. How far is it possible to predict?
  (Mr Buffin) Very difficult.
  (Dr Avery) The trends though are upwards for use. If you look over the last 10 to 15 years, trends of pesticide use for insecticides, fungicides and herbicides are generally up in terms of use per hectare. So if current trends continue, there is no reason to expect any decrease and probably the changes in future will be for more powerful pesticides to be used and therefore the effects of those pesticides on biodiversity may well increase.

  6. You mention the difficulty of perhaps using weight as an indicator, given that you might now, with more modern pesticides, be using small quantities of more biologically active chemicals. How can we then measure what the environmental effects are? What would be a better way of trying to measure this than just weight?
  (Mr Buffin) That is one of the problems. We have difficulties in monitoring the actual use because we are dealing with 400 different chemicals. One way would be to look at the individual groups and see what sort of trends there were there because you would be using similar dose rates, but it is a very complicated area and difficult to know.
  (Dr Avery) To be boring on this, but certainly consistent, we should be interested in looking at the effects of the pesticide use and to look at those you have to measure a wide range of environmental measures. We would be looking at things like weeds and insects in crops to see what effect pesticides are having; we would be looking at pesticides, residues and their effects in water bodies. A whole range of measures like that would be more meaningful than simply sales or weights of pesticides used. From the RSPB's point of view, it is the environmental effects we are very concerned about, so we would point towards measuring those effects directly.

Mr Jones

  7. Would you not agree that you require a highly sophisticated taxation system based upon some fairly detailed research because the objective is not to raise money for the exchequer, the objective is to mitigate and ameliorate various environmental effects? A crude taxation system, or even a not terribly sophisticated taxation system, could have the perverse effect of reducing the amount of pesticide used but increasing the effectiveness of the pesticides which were used and environmentally having a deleterious effect.
  (Dr Avery) You raise some good points. This is a complicated issue and the issues you raised would have to be thought through carefully. However, there is evidence that there is overuse of pesticides at the moment. There is overuse simply in terms of farmers' own economic interest. There is overuse of pesticides. There are external consequences outside the agricultural industry of use of those pesticides and therefore this seems to us to be a good prospect for an environmental tax. It fits with the polluter pays principle and could reduce what is seen to be an unnecessarily large use of pesticides at the moment.
  (Mr Rayment) I agree with the point you made about the importance of ensuring that the tax is very carefully designed to avoid any potentially perverse effects. We should actually be against a tax based on the value of pesticide products because we think that would encourage a shift towards the use of cheaper products which could have perverse effects. It is very, very important to ensure that those perverse effects are avoided. Ideally we should like to see a banded tax which actually considers the different impacts of different products and taxes pesticides accordingly, therefore avoiding those perverse effects and potentially having a positive impact in encouraging a shift towards more benign pesticide products.
  (Mr Buffin) We accept the argument for a tax based on weight or perhaps dose of pesticides but then you are taking away the fact that there are heavier chemicals which may be taxed at a disadvantage. Again, there are difficulties in making sure that if you had a banded system there would not be any perverse effects and the measurements would be difficult to monitor if you were actually having beneficial effects. We think it should be a relatively simple system that is basically raising money in an hypothecated way for sustainable agriculture in a whole range of areas.

  8. Since you would have to take into account the persistence of a chemical, the activity of a chemical, its direct effect on whatever pests it was attached to and then the indirect effect on others in the food chain, who do you imagine would be responsible for calculating these effects and then advising the Government about which tax band the pesticide should come in? Do you have any idea about what level of work that would require?
  (Mr Rayment) We have already seen quite a lot of progress towards that in the work which ECOTEC, the consultants, have done for the Department of the Environment, Transport and the Regions. They have developed a banding system which could be used to determine the different levels of taxation of different pesticide products. We think that further work needs to be done on that and we are not convinced that it fully captures the impacts of pesticides on wildlife, especially through the role of herbicides in removing plants from agricultural habitats. We think more work would need to be done, but that is an example of an approach which can be taken.
  (Mr Buffin) One of the things about pesticides is that they relate to different ministries. Historically the Ministry of Agriculture, MAFF, has been the lead agency in relation to pesticides, but we actually think that the Department of the Environment, Transport and the Regions, indeed the Department of Health, should have a bigger role to play in assessing the impact of pesticides. It should be the role of the DETR to look at some of these issues but because pesticides are obviously used in agriculture and in non-agricultural situations, they can get into the environment, they can get into food, they can get into water, they are subject to various different ministerial involvement and it is always difficult to know who is in overall charge. This sometimes happens when incidents involving pesticides are investigated. You have perhaps the Health and Safety Executive investigating, maybe the Environment Agency, maybe the DETR, maybe MAFF. There is a whole range of inputs and it just underlines the complexity of the situation.
  (Dr Avery) This is complex and it would be difficult to think through exactly how a tax ought to be designed but other European countries have gone a little further down this route than we have already. France is planning to implement a banded tax, as is Denmark. Other countries are further down this route than we are and it would take some time for the UK fully to think through what a pesticides tax should be like. We would have the opportunity to learn from whatever other countries have done so far.

Mr Grieve

  9. The ECOTEC report makes quite clear the difficulties of monitoring the environmental impact of pesticides. What progress is being made on the development of indicators? You touched on this but could you amplify on that for us?
  (Mr Buffin) In our submission, we briefly outlined who is monitoring what and obviously the usage of pesticides is monitored by the pesticide usage survey group. What they do is ask a number of farmers what they are using and then extrapolate up to give an idea of what is being used nationally. We, for example, feel that there should be mandatory use reporting, as they have in California, where they actually have a good idea of what farmers are using at the moment. It is an extrapolation. There is scope there. There is quite a lot of monitoring of drinking water, but we are concerned in terms of the level of residues in water in the environment. Some work has been done by the Environment Agency but it is perhaps not very obviously in the public domain or there are difficulties in monitoring continually for residues in this area and then there are other areas of monitoring biodiversity and indicator species where an awful lot is not done. There could be areas there in which perhaps a tax might be able to increase our understanding and analysing these various yardsticks.

  10. This is perhaps a question best aimed at the RSPB. In terms of impact on biodiversity, how do you see the progress which is being made, if any, in actually monitoring impact. It is one thing to monitor what is going in, but to monitor what the consequences are.
  (Dr Avery) There has been quite a lot of work done on this and more work is being done but as always we do not know quite as much as we should like to on any of these subjects. There is no doubt that the use of pesticides has had a big impact on biodiversity in the UK over the last 20 years or so. That is recognised in Government documents, in the fact that this Government and the last Government have signed up to species action plans for species in the biodiversity action plan process, a whole range of farmland bird species which have declined very dramatically and farmland plants which have declined very dramatically. To give just a couple of examples, the skylark has declined by 75 per cent, by three out of four, in the UK in the last 25 years and part of that decline—not all of that decline—is likely to be due to pesticide use. The other example which is a very good one is the grey partridge. This indicates the difficulty of getting strong data on this subject. This species, which was once one of the commonest species of bird on farmland, has been studied by the Game Conservancy Trust for 30 years and is the one species of bird for which we can be absolutely certain that pesticide use, particularly herbicide use, has played a major part in its decline. The decline has been catastrophic for that species. It is something like 80 per cent over the last 50 years; four out of five have disappeared. For the grey partridge, the work by the Game Conservancy Trust shows without doubt that pesticides are a large part of the reason for that decline. We do not have the information for a whole range of other farmland species which are similar in many respects to grey partridge, but since many of those species have also suffered very big declines, by extrapolation we should be worried that pesticides are causing declines in those farming birds as well. There is no doubt that pesticides, particularly herbicides, have had major impacts on many plants in the countryside. It is ironic that we talk now about rare arable weeds. It is a contradiction in terms, but species like the cornflower used to be important weeds in the countryside. They are now rare plants and a large part of their disappearance is due to changes in agriculture of which herbicide use is one very important aspect.

  11. I have heard it suggested—I do not know whether you would care to comment on it—that the loss of crowns on trees, which seems to be particularly prevalent in parts of England where there is a great deal of arable land, is in part attributable to high levels of residual pesticides in the soil.
  (Dr Avery) We could not comment on whether that is true or not, but that indicates the type of effect which is entirely plausible and it would take an awful lot of research to pin down whether it were true or not. There are many such effects and it is the totality of those effects which we ought to be trying to understand and that is very difficult. I think unfortunately not enough Government money has gone into research on this subject. Most of the work which has been done on these declining farmland birds and plants has been funded by NGOs like ourselves but not entirely by us.

Joan Walley

  12. May we just go back to the issue of biodiversity? It seems to me that in a way there is almost a lining up on the one hand of the industry and on the other of perhaps some government departments. I do not know. Looking at what has been presented to this Committee in terms of evidence which has been given to us, there are those who reach conclusions that the entire proposal has been based on philosophical dogmas and a basic misunderstanding of UK farming practices. Would you agree with that statement? Given what you were saying just now about the difficulties of getting the Department of the Environment, Transport and the Regions and possibly the Department of Health to look at ways of coming together with some finely tuned proposals, how would you propose getting on board every single department, not least the Treasury, and making sure you had a set of highly tuned proposals which would actually achieve the environmental objectives and health objectives of a proposed pesticide tax?
  (Dr Avery) Certainly speaking for the RSPB, we are not a very dogmatic organisation. We are rather dull and reasonable most of the time. We usually find ourselves sitting somewhere near the middle of most arguments. This is a subject for joined-up thinking. We have already heard that the effects of pesticides are complicated and they are not simply experienced on farmland but there is a much bigger range of potential impacts, some of which are not well understood. That is an argument for several government departments having to come together to look at these things. Another thing to say that is not simply dogma is that Government has taken a view that the declines in biodiversity are very serious and that pesticides are playing a part. The dogmatic conclusion would be to say we should try to ban all of them. That would be ridiculous. Pesticide tax can play a part in bringing in some measure, particularly when there is good evidence that pesticides are being overused, even from the point of view of farmers, to encourage lower use which fits in with Government policy. There are many other things as well which would include more money for agri-environment schemes which would be environmentally favourable, more money for organic farming, more advisory material, educational material and potentially the revenue from a pesticide tax could go into those measures so that to some extent the money raised from farmers from a pesticide tax is recycled into other farmers' pockets.

  13. Given the point you were making just now about lack of some degree of expertise on these issues, is that something the RSPB could advise Government on in respect perhaps of finely tuning some of those aspects of hypothecation to get the shift to organic farming or the extra training, etcetera?
  (Dr Avery) We would not claim to be the experts in this field.

  14. Who would be the experts?
  (Dr Avery) That is a good question actually. I am not sure it is clear that there is an expert in this. This type of committee inquiry is the right way of bringing together all the types of information.
  (Mr Rayment) Clearly the RSPB could offer a considerable amount of expertise in the design of agri-environment schemes for example which would help to reduce pesticide impacts and benefit biodiversity, but there are other aspects of the use of pesticides and their impacts which we would want to bring other groups in to advise on.

Mr Gerrard

  15. May I clarify a point about the structure of the tax which you mention? Both RSPB and the Pesticides Trust are saying we need to do more work, we need to have more research, we need to develop better indicators. However, in your submissions, the RSPB have come to the conclusion that there should be a banded tax and you obviously think we know enough to be able to go for a banded tax. On the other hand the Pesticides Trust are in the end arguing for a flat rate tax. Could you comment on that difference between your views?
  (Mr Rayment) May I start with the RSPB's position? Yes, ideally we should like to see a banded tax and we think that with some further research a workable structure for the tax could be arrived at. However, if it did not prove feasible to do that, we should be supportive of a flat rate tax provided that was carefully designed to avoid any potential perverse effects. Our favoured approach would be a tax based on dose, flat rate per dose.
  (Mr Buffin) From our perspective, it is a question of feeling that there is going to have to be an awful lot done in order to make sure that there is sufficient fine tuning on a banded tax and we do feel it is an enormously difficult task. A lot of thought and research is going to have to be put into it. It is the practicality of it that we find difficult. There may be things like indirect effect of pesticides which are very difficult to incorporate. How do you compare the effects on aquatic invertebrates? It may have an impact, for example, on fish or birds as opposed to the effects of the chemical on the person applying it. We know that synthetic pyrethroids may have an impact on invertebrates and feed for higher animals but are often of a lower acute toxicity compared to perhaps a carbamate which may be more appropriate in those sorts of terms. These effects are always going to be difficult to compare, so it comes back to our original point that we need a tax because of the facility that would give to improve sustainable agriculture and reduce our reliance overall on chemical inputs. There are always going to be very difficult decisions in terms of the impact of these chemicals on the environment. It is always very difficult to assess the subtle effect. We just do not have the technology.
  (Dr Avery) It would be easy to get bogged down in the difficulties of the detail of a tax and clearly the details would have to be thought through before any tax were introduced. We have said that we do not believe that would necessarily be easy, but given that there are large economic external costs of pesticide use and there is evidence for overuse at the moment and there is strong evidence for non-economic external costs of the tax, losses in biodiversity is one example, then our view would be that it is more sensible to move forward with a tax that tries to address this problem rather than be put off by the details of figuring out what that tax would look like. We would rather urge Government to get to grips with those difficulties and try to solve them, than be put off, because that will not help.
  (Mr Buffin) We had discussed the question before you asked and we have no major disagreements. We generally agree.
  (Dr Avery) We are not dogmatic.

Mr Blizzard

  16. Let us come back to the main thrust of the tax, presumably, which would be to reduce the overall use of pesticides. What scope do you think there is for farmers to reduce their actual use of pesticides?
  (Mr Buffin) Projects like the less intensive farming for the environment projects which are a range of integrated farming systems which have shown that gross margins can be maintained whilst reducing use and a range of measures to develop organic farming.
  (Mr Rayment) At least two studies have tried to quantify some of the potential cost savings to farmers through reduced pesticide use. There was a study for the DETR by RPA and Entec consultants which put potential cost savings at up to £274 million per year. Then a critique for the British Agrochemical Association by Morley Consultants estimated those cost savings at £100 million per year. The sums involved are very substantial and they involve applying a wide range of techniques designed to reduce pesticide use.

  17. Farmers are on their knees at the moment, why do you think they are not going for this? If millions of pounds are to be had by reducing pesticides, why are they not going for it?
  (Mr Rayment) The conclusions of those reports were that if farmers had better access to the right sort of advice and technical know-how, then they could realise those savings.

  18. What sort of percentage reduction of pesticides do you think might come about through these other methods overall? Have you made any estimate?
  (Mr Rayment) In the types of cost savings I am talking about you can compare £100-£274 million with the total value of pesticide sales of about £500 million a year in the UK. A very substantial proportion.

  19. If one could save money by using fewer pesticides, why do we need a tax? Surely you are saying the incentive is already there: change the methods and make savings? Why do we need to have all these people coming up trying to work out complicated systems which might cost the Treasury a lot of money to collect and all the rest of it?
  (Mr Rayment) But it is not happening at the moment and we think that a package of measures designed to reduce pesticide use and its impacts, including a tax to provide the right signals but used to fund a range of other measures including advisory, training and agri-environment schemes, could provide a significant stimulus for pesticide use to be reduced.
  (Mr Buffin) The MAFF project I mentioned showed that pesticide costs could be reduced from 20 per cent to 80 per cent so they could be substantial and I agree with Mr Rayment that a lot of the advice is from chemical companies in terms of advice to farmers and it is not going to change. On the other hand, for example, ADAS is privatised and there are issues there in that if you wanted some public sector input into farming policy then you do not have that avenue.
  (Dr Avery) May I pick you up? You said that farmers are on their knees. I am sure the eyes of the NFU are looking at me as I say this, and farmers are in trouble at the moment, but you have to recognise that three or four years ago farm incomes were at their highest level for about 20 years. That is not to diminish the fact that farming is in trouble now, but there have been good times as well as bad. A pesticide tax would fall mostly on arable farmers who are on one knee, rather than flat on the ground, which is where many farmers are. I think one would feel more sympathy for small upland farmers than some of the arable farmers. The revenue from a pesticide tax could be recycled back into the farming industry in other ways, therefore that money can come back to farmers and the use of pesticides has high external costs for all the rest of us. One of the examples which is always quoted is the cost of cleaning up water from nitrates and pesticides which leak into water, which is a cost which falls on all the rest of us.

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