Memorandum from the Environment Agency
SUMMARY
The Environment Agency is a member of the Steering
Group overseeing implementation of the Voluntary Initiative and
is playing an active role in a number of the projects. The Voluntary
Initiative provides an important opportunity for the agriculture
industry to demonstrate that it can control and manage its environmental
impacts. The Agency has the following comments on the progress
and likely success of the Initiative.
— If the Voluntary Initiative delivers
the promised improvements in farmer practice, it will provide
environmental benefits. However, this relies on the degree to
which farmers adopt the measures. We believe that unless there
is a commitment by the user community to specific objectives and
targets it is unlikely that the Initiative will be successful.
— Overall progress of the planned elements
of the Initiative is on schedule. However, there have been delays
to some individual projects, most notably the development of Crop
Protection Management Plans.
— The "Incentivisation" sub-group
tasked with identifying how good levels of adoption of the measures
will be achieved has made slow, uninspiring progress and has yet
to finalise its report. The Agency has serious concerns that without
a clear implementation strategy levels of uptake are likely to
be low with limited or no resultant environmental benefits.
— Indicators of success of the Initiative
have yet to be put in place. Without these it will not be possible
to determine the extent to which the Voluntary Initiative has
provided improvements in the environment. The Agency has been
assisting in developing suitable indicators and has suggested
a framework for reporting these. We are concerned that there are
no proposals to measure changes in pesticide usage or risk.
— Success targets linked to the indicators
have still to be agreed. The Agency is concerned that the signatories
are seeking to back track on targets agreed in the original package
of measures.
1. INTRODUCTION
1.1 The Environment Agency welcomes this
opportunity to submit evidence to the Environmental Audit Committee
inquiry into pesticides: the Voluntary Initiative.
1.2 The Agency plays an active role in the
Initiative as a member of the steering group overseeing progress;
in assisting with a number of the individual projects; and in
developing indicators of success.
1.3 The Agency believes the Voluntary Initiative
provides an important opportunity for the crop protection and
agriculture industries to demonstrate that they can control and
manage their environmental impacts. Progress of the Initiative
will inform policy-makers working on the implementation of new
European legislation affecting farming.
2. PROGRESS TO
DATE
2.1 Most projects in the Initiative are
making satisfactory progress. A notable exception is the development
of Crop Protection Management Plans, which is a long way behind
schedule. The National Farmer's Union is leading this project
The NFU has had difficulties in producing a suitable plan that
most farmers will be willing to undertake and yet will at the
same time deliver significant environmental benefits.
3. ENSURING UPTAKE
OF MEASURES
BY FARMERS
3.1 Most significantly, the signatories
to the package have been slow in recognising the need to not only
deliver project outputs such as improved training programmes but
also to ensure that these measures are adopted by farmers. An
Incentivisation sub-group has been set up to consider how a high
level of uptake by farmers can be achieved. The work of this group
has been poorly focussed and only recently, at the suggestion
of the Agency, has it drawn on academics with experience of motivating
farmers to adopt improved environmental practice.
3.2 An initial report of the group suggested
using financial (grants) and regulatory incentives to improve
uptake, both of which would no longer make the Initiative voluntary
as required by Ministers. There has been inadequate consideration
of the more difficult issue of motivating farmers to change practice
without the use of such incentives.
3.3 A final report is still awaited from
the Incentivisation group. The Agency has advised through the
steering group that an implementation plan is needed for each
project to identify the most effective ways of ensuring uptake.
4. MEASURING
SUCCESS
4.1 Measuring the extent to which the Initiative
has improved practice and delivered environmental benefits is
vital if we are to be able to judge whether a voluntary approach
is a viable alternative to a pesticides tax or further regulation.
4.2 Measures of success have still to be
agreed. A draft set of indicators of farmer awareness, changes
in practice, changes in levels of pesticides in the environment
and reduced environmental impact has been put together. Some of
these were proposed in the original package put forward by the
signatories, others have been drawn from the work of the Pesticides
Forum.
4.3 The Environment Agency has played a
key role in this work and has proposed a format in which indicators
may be reported. In drawing up the format it has become evident
that no measures of pesticide use or risk to the environment are
included in the proposed suite of indicators. Without such indicators
it will be very difficult to make a link between changes in practice
and any environmental improvements that might be seen. The Agency
believes that it is vital that indicators of pesticide usage and
risk are included.
5. TARGETS
5.1 The original package of measures included
a number of targets for farmer uptake of the various elements.
Some of these targets, eg all spray operators to be members of
a professional register by 2003, were ambitious and promised a
large scale improvement in practice with resultant environmental
benefits. They were one of the main reasons why the Agency supported
the introduction of the programme as an alternative to a pesticides
tax.
5.2 It has become evident in the process
of drawing up success indicators that the signatories are now
looking to back track on some of these targets since they now
realise that they will not be met. The Agency recognises that
the timescales for some targets may need to be extended because
of slow progress of individual projects. However, we do not consider
it acceptable to lower overall targets for the uptake of measures.
5.3 Targets should also be set for indicators
of environmental improvement such as pesticide levels in water.
At the moment the signatories are proposing that the target for
all but one of the environmental indicators should simply be improvement,
no matter how small. The Agency considers that more robust targets
should be set that would deliver significant improvements in the
environment.
6. CONCLUSIONS
6.1 The Agency supported the package of
measures at the outset because it believed that environmental
improvements were likely to result if all measures were adopted
to the extent that the signatories predicted. However, the lack
of clarity of how farmers will be encouraged to adopt the measures
and the apparent back tracking on targets for uptake reduce the
likelihood that the Initiative will deliver these improvements.
We believe that unless there is a commitment by the user community
to specific objectives and associated targets it is unlikely that
the Initiative will be successful. It is vital that these areas
are resolved quickly. In addition, the Agency believes that measures
of pesticide use or risk should be included as indicators of success.
October 2002
| 
