Supplementary memorandum submitted by
the National Farmers' Union
I refer to your letter of 21 December to our
Deputy President, Tony Pexton, asking for a supplementary note
on three issues.
1. HOW CAN
THE BAA AND
NFU RECONCILE THE
CONCLUSIONS OF
THE MORLEY
REPORT IN
RELATION TO
COST-EFFECTIVE
SAVINGS WITH
THE VIEWPOINT
PUT FORWARD
DURING THE
HEARING?
In giving their oral evidence, the RSPB and
Pesticides Trust indicated they felt there is evidence of the
over use of pesticides (though we are not certain on what evidence
they based this assertion). BAA and the NFU do not accept this
thesis, believing that the tightening pressure on production costs
has led the minimum amount of pesticide being used consistent
with a reasonable expectation that the desired end market quality
requirements for the primary produce will be achieved.
Your letter refers to a report by RPA/Entec
which estimates that savings of £274 million per annum (equivalent
to 50 per cent of current use) are achievable. The subsequent
critique by Morley Agriculture Consultants concludes that RPA/Entec
grossly over-estimated the savings, maintaining that a reduction
of 20 per cent would be possible over the next 10 years provided
that integrated crop management and application techniques continue
to be refined and universally adopted by farmers and growers.
The NFU believes that the confusion may have
occurred because the questions posed were taken to relate to the
potential for immediate reductions, hence the response of our
witnesses that they could see little scope for reduction. Given
the same assumptions, over time the NFU is confident the Morley
figures represent a more realistic forecast of the likely reduction
in pesticide use—especially if the current market criteria
for high quality primary produce continues.
2. WOULD THE
NFU AND BAA ACCEPT
THAT SUCH
(ENVIRONMENTAL) INDICATORS
AS DO
EXIST ALL
APPEAR TO
BE MOVING
IN THE
"WRONG" DIRECTION?
The NFU has argued that a simple measure of
the weight of pesticide applied to agricultural land would provide
only a partial insight into the effectiveness, efficiency, and
the actual effect of pesticide use in farming. We suggest that
a broader range of indicators, including those covering biodiversity,
would provide a fuller picture of usage. In your letter you highlight
the wildbirds indicator included in the "headline" set
of 15 indicators published by DETR late last year (ref. Quality
of Life Counts).
We strongly support the Government's use of
indicators to illustrate the range of action necessary for sustainable
development. However we are less convinced by the selection of
a relatively few indicators as "shorthand" methods of
assessing progress. When combined with the media tendency to focus
on simple stories the use of headline indicators carries a very
real risk of providing both a misleading impression of progress
and a consequent bias in action.
A prime example of the potential weakness of
this approach would be a simplistic association between the wildbird
indicator and levels of pesticide use. It is our understanding
that pesticide use has been proven to have a direct impact in
only two of the 20 species included in the wildbird index. It
is likely that a variety of other factors are influential in the
case of other bird species—many of these may be related
to farming practice (eg switch from spring-sown to autumn-sown
cereals) but other factors may also be influential. Climatic factors
may, for example, be influential in respect of the three migrants
included in the index just as conditions in their wintering grounds
may be of importance.
We are aware that it is population declines
in these species which is causing alarm. While reductions in numbers
of the magnitude highlighted by the RSPB are of concern to the
NFU, we would question whether the initial population level used
for comparison was itself sustainable. It is interesting to note
recent correspondence in the British Trust for Ornithology's magazine
"British Birds" which shows that the tree sparrow (which
has suffered an 86 per cent decline in the last 20 years) had
population levels at an all time high in the 1950s. Population
levels are now equivalent to those common in the 1920s and 1930s,
well before pesticides became widely adopted in agriculture.
Our message from these comments is not to deny
that wildbird populations have declined substantially but to recommend
caution in ascribing such change simply to the use of pesticides.
We would suggest to the Committee that reliance on a small number
of indicators carries a very real risk of providing misleading
messages.
3. DO THE
BAA AND NFU CONSIDER
THAT THE
INDIRECT EFFECTS
OF PESTICIDE
USE ARE
SUFFICIENTLY UNDERSTOOD
AT PRESENT,
PARTICULARLY IN
THE LIGHT
OF THE
EVIDENCE FROM
SUCH BIODIVERSITY
INDICATORS AS
DO EXIST,
TO REJECT
THE "PRECAUTIONARY
PRINCIPLE" AND
CONCLUDE THAT
PESTICIDE USE
CARRIES NO
ENVIRONMENTAL RISK?
IF THIS
IS THE
CASE, WHY
ARE THEY
IN FAVOUR
OF FURTHER
REDUCTIONS BY
FARMERS IN
THE USE
OF PESTICIDES?
From the phrasing of your question we think
that some misunderstanding may have arisen. In the NFU overview
from which you quote we argue that regulatory process (administered
by PSD) already makes the judgement as to whether a product presents
an unacceptable risk to the environment. Hence pesticides correctly
used should not cause pollution or environmental damage.
We understand that there are those who argue
that the current regulatory regime is insufficiently thorough
to evaluate all the possible environmental risks—and perhaps
the Committee will reflect on this in a future inquiry. However
given the current evaluative checks we do not believe the polluter
pays principle should be applied to pesticide use as use is undertaken
to rigorous statutory standards using products licensed for such
use.
Having said this we recognise that pesticide
use will inevitably disrupt plant and fauna populations. Continuing
research and development on these unintended impacts is vital.
Farmers contribute to the research both financially
via levies to HGCA and PSD and practically via implementation
of integrated crop management techniques. More research is required
especially to ensure that pesticide products become increasingly
specific (ie targeted to pests and diseases) and that application
techniques minimise losses to the wider environment.
The NFU believes that there is the potential
to achieve circumstances where farmers can not only reduce their
pesticide use and so save money on a costly input, but also minimise
unintended disruption of the ecosystem. It is with this objective
in mind that we would commend an approach focused on integrated
crop mangement, technology transfer and further research on pesticide
impacts. In this context we maintain our fundamental objection
to a pesticide tax which would do little to promote best practice,
reduce use, or minimise environmental impact.
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