Select Committee on Environmental Audit Minutes of Evidence

Examination of Witnesses (Questions 65 - 79)




  65. Good morning. You are on your own. Thank you for coming along and we do appreciate your flexibility and willingness to bat third but at least on your own. Is there anything you would like to add to the evidence you have already given us? May I start off by asking you—you probably heard some of the comments made about trends in pesticide use and so forth—how you see that picture?

  (Mr Killeen) Listening to the previous evidence, I would endorse the view that there appears to be a reduction in overall usage. Certainly from our monitoring programmes, this decrease does not seem to be reconciled with decreases in concentrations in the environment. That is the current position in terms of the amount of monitoring we do; we are not seeing any obvious reduction in line with decreases in trends of use.

  66. Any obvious reductions in what?
  (Mr Killeen) In general pesticide use.

  67. How do you see trends in the future? Carrying on much the same?
  (Mr Killeen) The trends have stayed very much similar over the last five years. We had hoped to see reductions through things like reductions of application rates, improved best practice, but the trend has stayed fairly stable in terms of the levels we have observed in the environment over the last five years.

  68. What view do you take of the vexed question of overuse of pesticides? One view says that there is no great overuse because it is expensive stuff and therefore why should people overuse it. On the other hand there is quite a lot of overuse.
  (Mr Killeen) Certainly in the Agency we have no evidence to suggest that there is overuse because of that very point, that it is expensive to use pesticides more than you need to.
  (Dr Leinster) So within that there is already a cost driver.

Mr Grieve

  69. Coming back to what you were saying about use, your monitoring indicates that there is no reduction in use in terms of the reduction, although there is a weight reduction, in use by farmers or reduction in the consequences which you are picking up in monitoring?
  (Mr Killeen) Certainly we have observed no decrease in the levels we observe from our monitoring programmes which are primarily surface waters, marine waters and some limited monitoring in ground water. It is very much based on a national monitoring programme we have which we try to target both to meet legislative needs and also to target areas of high use/high risk. That combined effect overall has not illustrated a decrease in observed levels in the environment over the last five years.

  70. You are currently reviewing your monitoring programme, are you not? Can you tell us something about that?
  (Mr Killeen) That is correct. The Agency spends a substantial amount of money, "substantial" probably being somewhere in excess of £50 million, monitoring the environment, within which probably about £3 million is targeted at pesticides. However, many of the pesticides we are required by UK law to monitor for, have no longer been approved for use in the UK. Over the last two years we have been gathering information to suggest that monitoring those pesticides has demonstrated that they have no real environmental significance. What we are attempting to do is re-balance our overall programme and to target our resources more effectively overall, recognising pressures generally on resources. What we are trying to do is make better use of the information we have, to place more emphasis on defining priorities from the information we generate, improving collaboration with other partners, including many of the organisations giving evidence today, getting best value from our overall monitoring programme in terms of sharing information and the biggest challenge, rather than just monitoring the environment, is using better risk based tools to predict levels in the environment. We have been spending considerable effort and research monies on developing predictive tools to support our monitoring programmes. That gives you a general flavour of what we are trying to achieve.

  71. Is it right that you do not currently have access to the test results provided by agrochemical firms to the Pesticides Safety Directorate?
  (Mr Killeen) That is correct. In terms of companies submitting the packages for registration, there is a confidentiality agreement between the producer of the chemical and, in the case of pesticides, the Pesticides Safety Directorate. However, over the past five years it was recognised that this information could be helpful in trying to assess the environmental significance of some of the pesticides which we detect. So over the past few years there has been a better understanding and sharing, not so much of the raw information which remains confidential, but, perhaps through technical discussions and general awareness, a better understanding of the significance of either pesticides subject to current use or those pesticides which might be approved for new use.

  72. If that confidentiality were to be lifted, so you had access to this, would that not help you very much?
  (Mr Killeen) I suppose having direct access to the information would assist, but we do get access in terms of our technical input to some of these Approval Committees anyway. Having to receive large volumes of confidential data would require large volumes of storage space. My colleagues from the industry would probably give a better indication of the sheer volume of information that needs to be generated for pesticide approval. I am reasonably confident that we get access to relevant environmental data to help us in our decision making.

  73. May I go back to ECOTEC a moment? ECOTEC took the view that monitoring of water was too much main river courses and not enough ground water, ditches along fields. Do you agree with that? Is that something you are trying to address?
  (Mr Killeen) That is very much part of our rebalancing of monitoring. Yes, I would tend to agree that traditionally where surface fresh waters have been used, specially for drinking water, our resources have been targeted probably too much in that particular area. We have a lot of good information to suggest that we could perhaps downsize our effort in surface waters and perhaps scale up our monitoring regimes in relation to ground water. Yes, it does suggest the need for the rebalancing exercise which we are currently undertaking.

  74. I think you pointed out in your consultation response that 129 sites failed at least one environmental quality standard. How do current trends match up with meeting EC standards?
  (Mr Killeen) In the case of environmental quality standards, what we are referring to are both standards which emerge from Europe, European-wide standards, for which there are quite a few for pesticides, but also importantly a range of UK standards, either legislative standards or standards for compounds where the Environment Agency determines that a quality standard is necessary. Many of the European standards for certain pesticides fall within the category of redundant monitoring. That certainly has been picked up by reviews of things like the proposed Water Framework Directive where clearly ten years on we can actually identify properly those chemicals of concern in the environment which do include some pesticides. I have much more confidence in the monitoring programme targeted from UK regulations in terms of the environment and also those compounds within the Agency where we do have some concern and hence put a monitoring programme in place.

Mr Blizzard

  75. You said you had seen no evidence of overuse of pesticides because they are expensive. What scope is there then for farmers to reduce their actual use of pesticides?
  (Mr Killeen) One of the challenges for us as an Agency is that we are having to protect the whole environment. If you look at a catchment level, individual farmers may be acting effectively, if you look at the combined effect of several farmers within an overall catchment, their combined effect can be quite significant. I would advocate, certainly at least at the environmental protection level, taking a catchment protection view. That would require not just individual farmers but farmers within a particular catchment working cooperatively and collectively to reduce overall levels. It may be that within that, some people are already applying pesticides at a much lower level than they are required to in terms of the quantity suggested for use, whereas others, because of the nature of the product, are using the quantity recommended. If we could get to a stage where we could demonstrate that the overall impact of pesticide use within a catchment and the combined impacts of several farming practices could be reduced in some way, that would be a very positive step forward.

  76. Do you think a tax would have any part to play in that process?
  (Mr Killeen) If you recognise that we have no other instrument and we are required to assess the state of the environment, we have statutory regulations in relation to pesticides in the environment where we can demonstrate that sources are diffuse, arising from normal use in most cases, then I think that a tax would assist.

  77. A tax would assist.
  (Mr Killeen) A tax would assist.

  78. We had discussions earlier about the difficulties and the technicalities of actually applying such a tax. I do not know whether you were here for that?
  (Mr Killeen) Yes; we were.

  79. Do you have any thoughts on that?
  (Dr Leinster) Yes, we do. For example, we should like to see a differential tax, some form of banding which was based on toxicity. We believe that would send signals to the users to consider which type of material to use for a particular application. We also think that in terms of the tax, the polluter-pays principle should be a fundamental part. So the issue with pesticide pollution is that it is diffuse pollution and yet we do not have any way of recovering costs for the monitoring programmes, for carrying out education work, for carrying out further R&D work that we believe we need to do, for carrying out farm visits to advise on control measures which can be taken. There is no form of funding for this work so we believe that a tax could go to fund that type of activity. Within that we believe that hypothecation is important, so the tax should be hypothecated to the Agency to fund that type of work, maybe also to government departments to assist in the funding of that sort of work. There is another area also in which a tax could be used and that is for regulatory activities such as the control of sheep dipping associated with the ground water regulations. If you actually used a pesticide tax, we believe that it would be a more efficient and less bureaucratic system for raising the funding than using the current charges that we raise and charging individual farmers, maybe 30,000-35,000 individual farmers, fees of less than £100 a time. We think that is an inefficient way of raising that sort of money, but a tax would be more efficient.

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