Memorandum from the Royal Society for
the Protection of Birds
The Royal Society for the Protection of Birds
is grateful for the opportunity to give evidence to the Environmental
Audit Committee as part of its enquiries into the progress of
the Voluntary Initiative. The RSPB is concerned about the impacts
of pesticides on wildlife and the wider environment, and seeks
to identify and reduce these impacts wherever possible.
PESTICIDE IMPACTS
ON FARMLAND
BIRDS
Regulatory improvements have greatly reduced
the direct toxic effects of pesticides on birds to a point where
direct effects of legal applications of agricultural pesticides
are now of low conservation importance. The major concern regarding
pesticide impacts on farmland birds relates to their potential
to disrupt food-chains, the so-called indirect effects of pesticides.
The insecticidal and herbicidal properties of
pesticides remove non-target insects and plants from sprayed crops.
Most birds feed their chicks on insects, and insecticide sprays,
particularly during the breeding season, can remove these essential
food sources. Herbicides remove plants and the over-winter food
they provide in the form of seeds, and also affect invertebrate
food supplies by removing the host plants they live on. As well
as the impacts on birds, these plants and insects may of course
be ecologically important in their own right.
Research on indirect pesticide impacts is a
relatively new field, but evidence is accumulating. Pesticides
have been shown to be the key factor in grey partridge declines,
and impacts on corn buntings, yellowhammers, turtle doves and
skylarks have also been identified in recent research. On balance,
although not all species are affected and pesticides are only
one of a number of factors which affect farmland birds, there
is widespread acceptance that the Government's Public Service
Agreement to reversing the farmland bird indicator, and over 20
BAP targets, will not be achieved without a reduction in the indirect
effects of pesticides.
THE RSPB'S
POSITION
The RSPB has supported the introduction of a
pesticide tax, and two years ago gave evidence to this effect
to the Environmental Audit Committee's review of green taxation.
The RSPB's position continues to be that a banded tax accompanied
a package of measures to promote better pesticide management,
funded through hypothecated revenues, is an effective and socially
justifiable means by which to secure pesticide impact reductions
and implement the polluter pays principle. However, we have always
acknowledged that taxation is not the only approach and that RSPB
will support an alternative route provided it can deliver equivalent
environmental benefits. For this reason, the RSPB has accepted
a place on the Voluntary Initiative steering group, with the aim
of continuing to support the content and implementation of the
package. Should genuine environmental improvements fail to emerge
within a reasonable period of time, the RSPB will advocate a pesticide
tax as above.
REDUCING THE
ENVIRONMENTAL IMPACTS
OF PESTICIDES:
THE VOLUNTARY
INITIATIVE
In order to meet its environmental targets,
the VI will need to effectively reduce biodiversity and water
impacts of pesticides. We will restrict our comments here to biodiversity,
although the RSPB is involved with and supports the water quality
aims of the VI.
To reduce indirect pesticide impacts on biodiversity,
the VI will need to address:
The RSPB is satisfied that the VI has suitable
projects within its portfolio to address these critical issues.
Success will depend on the effectiveness with which the projects
are implemented.
The value of the VI
The VI is valuable in that it is uniting elements
of the industry with a common aim, and fostering a sense of responsibility
for the impacts of routine activities. The concept of duty of
care has not been enshrined in most agricultural policy, which
has depended on a combination of externally imposed sticks and
carrots to guide agricultural activities. If the industry can
prove that it is capable of responsible self-regulation in the
matter of pesticides, it will send a significant message that
it is moving towards the vision set out in the Curry Report and
endorsed by Government, of an agriculture which is reconnected
to and rewarded by society's wider needs and priorities.
On a more practical level, steps to mitigate
the impacts of pesticides on the environment are likely to be
more effectively implemented if they are owned by farmers, agronomists
and pesticide companies, rather than imposed on them. Many of
these same activities would be necessary if the VI were discontinued
and a pesticide tax imposed.
Individual areas of the VI have already delivered
value and reflect a high level of commitment by different industry
participants. In particular, the re-organisation of the BASIS
and NPTC training syllabuses and certification registers, the
farm practice surveys, and communication and liaison within the
industry and to the farming media stand out as achievements.
Concerns with the VI
The effectiveness of the VI rests ultimately
on pesticide users undertaking the activities under the VI umbrella.
To date, it is not clear how this will be achieved for a number
of key projects, although progress is well advanced with others.
Two particular areas of concern emerge:
— Exactly what farmers will be asked
to do: Crop protection management plans were envisaged as the
means by which all pesticide-related activities on a farm were
co-ordinated and rationalised. Some discrete parts of this, such
as sprayer testing and filling, are well advanced. An appropriate
range of issues to be covered has been agreed, but it is still
not clear specifically what a plan will deliver for the environment
on each farm. The plans are likely to cover legislation and good
practice, including LERAPS, Green Code and training activities,
but are not likely to extend beyond this into activities which
directly compensate for pesticide impacts (eg: planting wild seed
mix to compensate for broad-spectrum herbicide applications).
This is the kind of activity which could have been funded through
tax revenues. Instead, heavy reliance is being placed on participation
in agri-environment schemes.
— Exactly how farmers will be helped
to do it: It remains unclear exactly what financial resources
have been allocated to implementing the VI. The final report of
the incentivisation sub-group has yet to be agreed by the steering
group. As stated above, much will depend on securing wider ownership
and full implementation of the VI in the farming community, and
it is not yet clear exactly how this will be secured on a project
by project basis.
THE ROLE
OF GOVERNMENT
Ministers in Treasury and DEFRA have retained
a close interest in the VI. Understandably, Government is regarding
the VI as a test of the industry's ability to deliver sustainable
pesticide use, and so is not involved in a hands-on way. However,
representatives of key departments observe VI meetings and provide
an appropriate level of scrutiny and input. It is the RSPB's perception
that continued pressure, in the form of interest in a pesticide
tax, may be necessary to keep the VI on course, as this appears
to have been the most powerful incentive in getting parties to
agree important deliverables.
Many of the activities of the VI could be regarded
as the remit of central policy, and the VI signatories originally
hoped for more of a partnership with Government. There remains
the question of whether some of the VI 's aims can be achieved
without central Government involvement and, if not primary legislation,
at least a formal tie into related policy areas (particularly
cross-compliance and agri-environment). As stated above, if the
pesticide tax were revisited many of the VI activities would need
to continue under Government leadership. The RSPB believes that
the Government should consider further how sustainable pesticide
use sits within its wider policy for sustainable agriculture,
and the future of its dissociation from the activities of the
VI.
IN SUMMARY
To date, while we are confident that it has
the potential to do so, it is unclear yet whether the VI will
be successful in reducing the environmental impacts of pesticides.
The value of the VI, in terms of building commitment and a sense
of ownership of the need to reduce the impacts of pesticides,
should be recognised and fostered. Further attention on the specific
environmental gains to be delivered at a farm level, and the means
of achieving them is needed.
October 2002
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