Memorandum from English Nature
BACKGROUND TO
WITNESS
English Nature is the statutory body that champions
the conservation and enhancement of the wildlife and natural features
of England. We do this by:
— advising—Government,
other agencies, local authorities, interest groups, business,
communities, individuals;
— regulating—activities
affecting the special nature conservation sites in England;
— enabling—helping others
to manage land for nature conservation, through grants, projects
and information;
— enthusing—advocating
nature conservation for all and biodiversity as a key test of
sustainable development.
In fulfilling our statutory duties, we:
— establish and manage National Nature
Reserves;
— notify and safeguard Sites of Special
Scientific Interest (SSSIs);
— advocate to government departments
and others effective policies for nature conservation;
— disseminate guidance and advice about
nature conservation; and
— promote research relevant to nature
conservation.
Through the Joint Nature Conservation Committee,
English Nature works with sister organisations in Scotland, Wales
and Northern Ireland to advise Government on UK and international
nature conservation issues.
INTRODUCTION
1. English Nature considers that a reduction
in the burden on the environment from pesticides is essential
in order to reduce the impacts and risks of pesticides to biodiversity
and to the environment more. This should be achieved through a
range of mechanisms, including regulatory, advisory, economic
and voluntary measures. The Voluntary Initiative (VI) forms only
one of a raft of necessary measures; to be effective it must be
fully implemented and underpinned by a clearly stated Government
strategy and action plan for pesticide risk reduction.
2. Restoration of farmland biodiversity
requires action to counter the effects of agricultural intensification.
Appropriately targetted reductions and selectivity in the use
of pesticides should be part of that action, and should be part
of the environmental benefits explicitly sought from the Voluntary
Initiative. The study by the Environment Audit Committee is a
timely review of the progress made by the Voluntary Initiative.
It should make an important contribution to the broader debate
about how policy instruments can be designed and used to help
change farming practice, including achievement of these goals.
In particular, firm links need to be made between the objectives
and mechanisms for achievement in the Voluntary Initiative, and
environmental outcomes sought from entry level "broad and
shallow" agrienvironment schemes.
THE CONTRIBUTION
OF THE
VOLUNTARY INITIATIVE
3. The Voluntary Initiative must address
the effects of pesticides on biodiversity both within the crop
and in the non-crop environment. Within the cropped area, the
objectives should be to reduce the risk of adverse direct effects
of pesticides on important wildlife (such as rare arable weeds)
and to reduce the indirect adverse effects of pesticides (which
act by reducing the availability of wildlife food resources such
as weed seeds and invertebrates). To achieve these objectives,
the VI needs to contribute towards:
(a) A reduction in unnecessary pesticide
use.
(b) Promotion of alternative methods for
crop protection.
(c) Selection of less environmentally damaging
products.
(d) Mitigation of the adverse effects of
pesticides where their use is essential.
The key elements of the VI package which help
deliver these objectives are:
— training programmes to improve understanding
of risks and alternative methods of crop protection;
— improved information availability
on the risks associated with pesticides;
— the development of individual Crop
Protection Management Plans (CPMPs), including measures to mitigate
for indirect effects of pesticide use such as unsprayed margins
and beetle banks. At the moment, implementation of CPMPs is too
underdeveloped and slow (see below).
4. Outside the cropped area, measures are
needed which minimise the effects of pesticides on semi-natural
habitats, such as hedgerows and watercourses, by reducing the
risks of spray drift and run-off or leaching from the site of
application, or losses to the environment during disposal. The
Voluntary Initiative should help here through the following improvements:
(a) Training and improved information on
risks.
(b) Encouraging the uptake of improved application
technology and providing a scheme to improve the condition of
crop sprayers.
(c) Raising awareness of local habitats and
species at risk through implementing Crop Protection Management
Plans.
(d) Promoting awareness of and compliance
with measures to protect watercourses.
(e) Implementing pilot stewardship campaigns
for the protection of water within catchments.
The focus of the VI over the past 18 months
has been on the development of these programmes, and there is
as yet limited take up of relevant programmes on farms. An acceleration
in the rate of implementation is required if we are to reduce
the risks to biodiversity. We are concerned about the time it
is taking to achieve change.
PROGRESS AGAINST
THE VOLUNTARY
INITIATIVE OBJECTIVES:
5. Training and awareness:
Improved awareness of risks to the environment
is an essential part of the programme. The VI addresses this issue
well, with programmes for training or training standards directed
at operators, adviser/distributors and, importantly, farmers themselves.
The initial survey of current practice carried out under the VI
has been useful in identifying significant gaps where training
must be strengthened. Willingness of training and certification
organisations to take part has been encouraging. It is disappointing
that due to delays in development of Crop Protection Management
Plans (CPMPs) the development of key training modules has been
delayed. Interim targets for the completion of training modules
and take up of training need to be agreed urgently.
6. Environmental information:
Better availability of environmental information
on pesticides has long been necessary, and the development of
Environmental Information Sheets and further information on insecticides
is an important part of the VI programme. The advisory material
must fully reflect likely risks. Whereas action to address the
rate of production of the Environmental Information Sheets is
in hand, we are concerned that some areas of potential risk are
not well-covered (such as indirect effects on biodiversity). Some
areas of provision of environmental information therefore need
further work.
7. Crop Protection Management Plans:
7.1 We regard the CPMPs as critical for
delivery of the biodiversity benefits from the VI. They will provide
the primary mechanism whereby a farmer or his adviser will identify
specific risks to biodiversity on the farm (as well as risks to
water quality) arising from his crop protection practice, and
will enable evidence to be gathered on whether measures have been
taken to address those risks. Particularly important is the requirement
for the farmer to identify measures to compensate or mitigate
for the indirect effects of pesticides on farmland biodiversity,
for example the effects of broad spectrum herbicide and insecticide
use on food availability for farmland birds. Possible options
for mitigating measures that the CPMP should explicitly identify
might include conservation headlands, wildflowers strips and beetle
banks.
7.2 Progress with the CPMPs has been unsatisfactory.
Although the components of the CPMP are broadly accepted, key
issues that still need to be finalised are mechanisms for both
assessing and encouraging or incentivising their adoption and
implementation. There is a significant opportunity here to build
links between the VI programme and the entry-level "broad
and shallow" agri-environment scheme. Given the intention
to make the entry level "broad and shallow" scheme widely
available to farmers, this could act as an effective incentive
for farmers to take up the mitigating measures under the CPMPs,
such as those outlined above. Correspondingly, the requirement
for such action under the VI should encourage farmers to look
more widely for opportunities to adopt measures to enhance biodiversity
under such a scheme as the "broad and shallow".
8. Incentivisation
Incentivising or motivating farmers to adopt
the package as a whole remains a concern. Final recommendations
on incentivisation have yet to be confirmed by the Steering Group
and there is still uncertainty as to the effectiveness and likely
comprehensiveness of mechanisms proposed. It is likely that uptake
of individual components of the package could be best incentivised
by different means. In the view of English Nature there is still
further scope for distributors and suppliers to consider their
own role in assessing the uptake of measures at the individual
farm level, and in encouraging the adoption of practices which
are potentially less damaging to the environment. Our concerns
over whether the package will be taken up sufficiently to make
a difference remain and to some extent this concern has been strengthened
by the slow rate of progress on this issue over the past year.
Agreement over a practicable incentivisation scheme and close
monitoring of progress against interim targets must be a priority
for the Steering Group.
9. Indicators and targets
Although progress has been made on agreeing
a range of appropriate indicators of the progress of the VI, agreement
has not yet been finalised over the targets that will indicate
success. A range of response indicators has been selected which
relate closely to the actions under the VI, however it is the
environmental indicators that will be particularly crucial in
gauging its success. The complexity of the interactions between
most environmental parameters and pesticide use, as well as the
lack of good baseline data for other potentially suitable indicators
against which progress may be measured, place limitations on the
environmental indicators which can be adopted now. The current
range of proposed environmental indicators has been developed
from those adopted by the Pesticides Forum, which has recognised
the need to develop additional more specific indicators than those
currently available. The way in which this issue has been explored
through the Pesticides Forum has presented some difficulties for
the government departments involved. It is important that rapid
progress is made in developing additional environmental indicators,
as well as indicators and targets for changes in product usage
patterns so that effective indicators of changes in environmental
burden are put in place.
10. Biodiversity Officer and Strategy
The appointment of the biodiversity officer
and recent draft strategy are welcome aspects of the programme.
There is potential here for greater involvement of individual
companies in UK BAP for farmland habitats and species, which we
welcome. Real commitment is needed by individual companies to
make progress against targets, which should include further commitment
to biodiversity considerations in product stewardship and product
development/manufacturing.
11. Cost of the package
Accounting for the costs of the individual components
of the VI has not been adequate to enable assessment of progress
against the forecast costs of around £11 million per annum
to the farming sector, and £2.4 million per annum for the
CPA member companies. At present it appears that expenditure has
been less than that planned at the outset, although delays in
starting projects and in transferring programmes out to individual
farmers may account for this. It is essential that accounting
and reporting procedures are tightened up in order to enable the
Steering Group to monitor more closely the projected and actual
costs of the package, and that these are commensurate with the
scale of potential problems. The scale of change that could be
achieved by reinvesting the potential take from a pesticides tax
is an important criterion in evaluating whether the scale of delivery
is sufficient.
THE NEED
FOR A
WIDER POLICY
FRAMEWORK
12. We consider that the Voluntary Initiative
must be part of a coherent package of measures to reduce the adverse
impact and risks of pesticides in the environment. Government
policy on pesticides currently is aimed at the promotion of responsible
use and reducing the impact on the environment. English Nature
believes that this policy should be strengthened and broadened
as an explicit risk reduction strategy with an overall government
action plan. This should take into account wider policy initiatives
such as those to increase the area farmed organically and reductions
in the range of pesticides available following the EU pesticides'
review programmes. Where voluntary measures are not succeeding,
or where there is evidence of failure to comply with statutory
requirements, there must be a clear commitment by Government to
increase surveillance and enforcement activity.
CONCLUSIONS
13. English Nature's overall view is that
the measures contained within the Voluntary Initiative could change
farmers' behaviour and lead eventually to measurable environmental
and biodiversity benefits, but only if widely taken up. This voluntary
approach has been slow in development, and it is still uncertain
whether it will deliver the required benefits. Although it is
probably too early to say that the Voluntary Initiative cannot
deliver up to expectations, there are certainly risks in waiting
much longer. Baseline standards for agriculture and "broad
and shallow" schemes under the agrienvironment programme
offer an opportunity to help drive forward measures under the
Voluntary Initiative.
14. The present Environment Audit Committee
review should give renewed momentum to the Voluntary Initiative,
and we recommend that:
(a) The process is reinvigorated and driven
harder by the Steering Group.
(b) The actions identified above are progressed.
(c) Government adopts a stronger policy framework
within which the Voluntary Initiative should sit.
(d) Progress should again be assessed at
the end of 2003.
Government should make it clear that it is determined
to act if the voluntary approach fails to deliver and the threat
of a pesticide tax should remain as an alternative approach. A
possible future consideration might be to introduce a tax for
those who do not take up the Voluntary Initiative.
October 2002
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