House of Commons - Environment, Food and Rural Affairs

Select Committee on Environment, Food and Rural Affairs Eighth Report

3 The Voluntary Initiative

27. The VI makes no attempt to reduce overall pesticide use. In fact, the proposals published in February 2001, which form the basis of the VI, argue strongly against a policy objective of reducing pesticide use.[36] Friends of the Earth (FoE) expressed concern that, within the VI, "there is no attempt to reduce overall pesticide use".[37] Pesticide Action Network-UK (PAN-UK) also argued that the only way of minimising the environmental impact of pesticide use was "to reduce the total amount used".[38] However, the CPA believed that "the key to success" was "how farmers use pesticides not how much they use".[39] The CPA illustrated this by describing how a small incident, such as a farmer throwing away the foil or screw cap on the pesticide container, could lead to a pollution event. It felt this was a clear example of how "environmental awareness is so much more relevant […] than the absolute amount of the material being used".[40]

28. FoE/PAN-UK also criticised the VI for not including "the principle of substitution, whereby more hazardous pesticides are avoided if safer chemical or non-chemical alternatives are available".[41] When this criticism was put to the CPA, it insisted this approach was not necessary since "pesticides are the most regulated and most tested chemicals that we have on this globe".[42] An example of how the principle of substitution might operate in practice was provided by the Royal Horticultural Society (RHS). Its advice to gardeners is to resort to synthetic pesticides only after first trying other options, such as resistant varieties, cultural methods, physical barriers and biological controls. This approach had led the RHS to almost completely eliminate pesticide use in its glasshouses and to become increasingly reliant on organic mulches for weed suppression.[43]

29. Health issues are hardly considered at all within the existing scope of the VI. In its published indicators and targets, there is only one reference to human health: it sets a target of "well trained operators follow[ing] best practice and mak[ing] best use of crop protection products through timely and accurate application with due regard to their own safety, the safety [of] others, and the environment".[44] Professor Coggon, Chairman of the Advisory Committee on Pesticides, did note, however, that "any improved training of operators has potential benefits in terms of minimising mishaps when pesticides are being used".[45]

Targets

Success of targets to date

30. There was a general consensus amongst witnesses that the VI had been successful in raising awareness and uniting the agrochemical and farming industries in a common sense of responsibility towards the use of pesticides.[46] While the Environment Agency (EA) was keen to underline that it had not given the VI an "unalloyed endorsement", it did agree that the initiative had "been a big success" in terms of bringing the industry, government and different stakeholders together and that it had "done a great job in actually raising the level of awareness, particularly amongst the farming community".[47]

31. The EA also noted that "the VI has made good progress despite a slow start, and interim targets for farmer uptake of CPMPs, NSTS and the NRoSO have been met".[48] Before the start of the oral evidence sessions, the CPA provided us with an update of the level of farmer uptake in what it described as "the key VI schemes".[49] At that time, the CPA asserted that most progress towards these targets tended to be made during the quieter times of the year for arable farmers. The most recent evidence seems to support this contention, with considerable progress being observed in the first two months of 2005. The table below sets out the latest data (updated to 1 March 2005), as well as the target for 31 March 2005.

Table 1: Achievements and targets of three VI projects in 2005

Indicator Target
31 March 2005
Achieved at
1 March 2005

Members of National Register of Sprayer Operators Members: 17,500
Arable area: 70%
Members: 19,600
Arable area: 75%

Tests under National Sprayer Testing Scheme Tests: 10,000
Arable area: 50%
Tests: 4,404
Arable area: 38%

Area covered by Crop Protection Management Plans 900,000 ha
Arable area: 22.5%
1,034,126 ha
Arable area: >25%

Source: VI website (www.voluntaryinitiative.org.uk)

32. On the basis of progress to date, it appears likely that the final NRoSO and CPMP targets, for March 2006, will be met.[50] Since there is normally a lag in processing the paperwork for sprayer testing, the CPA argued that it is possible to get close to, at least, the area target for the NSTS, before 31 March 2005.[51] Both the CPA and Professor Barry Dent, Chairman of the VI steering group, suggested that the original target for the actual number of sprayers being tested might no longer be appropriate because of farmers moving to using contactors, which had led to a significant reduction in the number of sprayers actively being used.[52]

Criticisms of targets

Moving the goalposts

33. FoE criticised the VI targets for being weak, and suggested that some of the VI targets may have been weakened to make them easier to meet.[53] To support this claim, FoE cited a VI steering group paper which stated that "as the VI has progressed it is clear that some of the targets proposed in 2001 are unrealistic or are no longer appropriate".[54] The paper concluded that the steering group needed to agree "new realistic and achievable targets".[55]

34. In response to these criticisms, Professor Dent outlined to us where targets had been added or amended and gave reasons for the changes.[56] He admitted that "the changing face of agriculture […] and other factors have necessitated some changes to the originally proposed package of 24 projects. In response, the steering group has agreed to drop some, to amend or expand others and to insert new projects into the programme".[57] He did feel, however, that if anything, the VI was "trying to make the targets a little bit harder".[58]

Crop Protection Management Plans

35. Some VI targets were also thought to be lacking in ambition. In particular, the targets for the CPMPs attracted widespread criticism. English Nature described the current target as "unambitious" and Defra/HM Treasury noted that "the Government continues to believe that the proposal [for the VI] to cover 30% of arable land by 2006 is not sufficient".[59]

36. FoE and PAN-UK also criticised the fact that the VI target will measure only the number of farmers who fill in a CPMP rather than changes in practice or the effectiveness of the plans. They said:

Farmers who tick all boxes with a 'poor' rating will still count towards meeting VI targets. For example, a farmer who has no safe storage for pesticides, sprays too close to water courses, and is totally dependent on chemical pesticides would count as a success just for filling in the form.[60]

37. In countering this point, the National Farmers' Union (NFU) noted that, in order to be farm assured, it was necessary for farmers to reach at least the second-from-highest grade on the CPMP. The Royal Society for the Protection of Birds (RSPB) described a 'benchmarking' exercise in which it was involved, which provides farmers with an analysis of their form, so that farmers "can judge themselves" and "try to see where they fit" in relation to the rest of the industry and their peers.[61]

38. Professor Dent referred to the inclusion of CPMPs in the entry-level stewardship scheme, and suggested that the provision of agri-environment money under this scheme would be a good way "to move farmers through from average practice to better practice to best practice to excellent practice".[62]

Water pollution

39. Some witnesses considered that the VI's water quality target, for a 30% reduction in detections above 0.1 parts per billion for all pesticides, did not go far enough. The EA felt that, with changes to formulations and the banning of some of the nine problem chemicals, the levels of pesticides in water were likely to reduce anyway, even in the absence of the VI.[63] This led the EA to conclude that the 30% target was not sufficiently ambitious, and it called for a "much more challenging" target that would lead to "a substantial reduction in the cost of treating water used for drinking".[64]

40. Professor Dent announced that, at the repeated request of the Minister, the VI steering group had recently provided conditional targets for water quality that go beyond those currently agreed.[65] The steering group had "accepted that a 30% reduction in exceedances will be the minimum that we would hope to achieve and, in a conditional sense, if certain things are in place, we would hope to get nearer to a 50% reduction".[66] The Minister for Rural Affairs and Local Environmental Quality confirmed that he had received the new proposals from Professor Dent and stressed his conviction that, "unless the industry is working towards challenging targets […] it is not going to be convincing to others".[67] Officials from Defra's Pesticides Safety Directorate (PSD) also confirmed that Defra had been pushing the steering group to strengthen the VI's targets on the CPMPs, and on water pollution in particular.[68]

Our conclusions

41. The credibility of the Voluntary Initiative is critically dependent on the targets that are set for it. Setting strong and robust targets—and then meeting those goals—is the best way of deflecting criticism of the VI and averting the possibility of alternative measures, such as a pesticides tax.

42. The VI's current targets for the area of land under Crop Protection Management Plans and for water quality are insufficiently challenging, and should have been strengthened earlier. We welcome the VI steering group's offer to strengthen the target for water quality, but feel the conditional nature of the offer undermines its credibility. We recommend that the target on CPMPs be similarly strengthened to reflect the inclusion of the plans in the entry-level stewardship scheme. The VI steering group should also be able to show evidence that the CPMPs are leading to real improvements in agricultural practice, rather than just being a form-filling exercise.

43. In relation to farmers seeking to improve their environmental practice, as indicated on their CPMPs, the Government should have regard to Professor Dent's suggestion that agri-environment money could be used to promote such improvement.

Demonstrating the environmental benefits

44. Further concerns were raised by Defra and HM Treasury regarding "the crucial issue" of demonstrating that the VI's measures were leading to real environmental benefits.[69] The CPA was in full agreement that producing tangible environmental benefits needed to be the target of the VI, but Professor Dent explained this was "really a very difficult area".[70] The NFU explained that quantifying the link between the practical changes under the VI and environmental benefits was difficult because the current evidence was "largely anecdotal".[71] The NFU hoped to be able to provide proof of a link by correlating CPMP data from the pilot catchments with data on the reduction of pesticides in water.[72]

45. The Minister referred us to evidence from the EA which showed that "the incidence of pesticides exceeding the EU Drinking Water Directive limits of detection of 0.1 ìg per litre has dropped by 23% over a five-year period to 2003".[73] However, the EA had told us previously that, while this reduction might have been down to the VI, it could also have been due to the weather or a change in the products being used by farmers.[74] When confronted with these other possible causes, the Minister conceded that "proof of a direct relationship is more challenging and that is why we have been trying to develop tools which will allow us to be much more precise".[75]

46. Defra has been working on developing supplementary tools for evaluating the VI for some time. In its response to the EAC's report on the VI, the Government said it was "in the process of commissioning work to develop a framework to enable subsequent assessment of the VI" and indicated that the study was "intended to be completed by Summer 2003".[76] Defra told us that this project had been awarded to a team of academics from Newcastle University, who had found the work "quite difficult and challenging".[77] The Newcastle team had come up with three tools for evaluating the VI: the use of focus groups, an ecological network model, and a socioeconomic study to link changes in farmer behaviour to environmental improvement.[78] Defra commented that these tools "might not be as useful as we would have liked".[79] The report was subject to peer review and was now likely to be published only "towards the end" of 2005.[80]

47. Assessment of the environmental benefits of the VI was also impaired by data quality and availability.[81] Professor Dent noted that the database on drinking water standards had its drawbacks, but was at pains to point out that the EA had worked hard to refine it.[82] The EA acknowledged that a further year's data would be required to determine whether the reduced level of pesticides in water was caused by the VI or the weather.[83] Since the indicator farms project offered potential for evidence in demonstrating the environmental benefits of the VI, several witnesses also expressed regret that it has suffered delays in getting under way.[84]

Our conclusions

48. Since the objective of the VI is to minimise the impact of pesticides on the environment, the ability to measure achievements in this respect is fundamental. Data problems and delays to projects have meant that we have little irrefutable evidence of the environmental benefits of the VI, just one year prior to the completion of the programme. We recommend that Defra, the Environment Agency and the VI steering group move rapidly to put in place the necessary arrangements to allow for a proper assessment of environmental benefits of the VI to be undertaken in 2006. We are concerned that Defra is not only unable to provide assurances on the environmental benefits of the VI at this time, but appears to have little confidence in the usefulness of the research it commissioned specifically to provide tools for this assessment.

Inclusiveness

49. Whilst the VI has been successful in involving an increasingly large proportion of pesticide users in its projects, it is still not totally inclusive. The Soil Association highlighted the problem of the 'free-rider' effect: "unless the VI achieves 100% coverage, there will be a proportion of farmers not incurring the additional costs associated with compliance to the VI".[85] The Soil Association felt it was inevitable that:

A voluntary scheme of any sort will attract those who are most enthusiastic about its objectives and be least good [at] covering those who are least enthusiastic. In other words, people who are most irresponsible in their use of sprays are the people who it is going to be the most difficult, if not impossible, to get into a voluntary initiative.[86]

PAN-UK, a member of the VI steering group, said that if the VI did have a strategy for attracting pesticide users currently outside the programme, it was not aware of it.[87]

50. CPA explained that the VI was "starting with the big farmers and working down" because that was where the most dramatic results are most easily achieved.[88] The Agricultural Industries Confederation (AIC), the representative body of the agricultural supply trade, described how it was targeting infrequent users with information on training and sprayer testing, through the distributors of pesticides.[89]

Assurance schemes

51. A marked increase in participation had resulted from the incorporation of some VI measures into the requirements of assurance schemes (including CPMPs, registration with NRoSO and testing within the NSTS). The Food Standards Agency (FSA) welcomed this incorporation as a highly effective way of ensuring widespread adoption of VI measures, "since membership of assurance schemes by farmers is a pre-requisite for suppliers to the retailer sector".[90] The production of over 80% of the combinable crops area in Britain is now covered by assurance schemes.[91] However, the FSA felt encouraging uptake of the VI measures amongst those farmers whose produce is destined for the wholesale market or the food processing sector would be more challenging, since they were less likely to be affiliated with any assurance schemes.[92]

Amenity use

52. The EA felt that more work was needed in order to raise the level of awareness of pesticide users who were not farmers.[93] The Country Land and Business Association (CLA) noted that the herbicide diuron was one of the most commonly detected pesticides in water, but that it was used exclusively by the amenity sector (that is, use associated with sport, leisure and landscape). The CLA's assertion that "the VI steering group has been frustrated with the difficulty of engaging with local authorities about the use of this chemical for management of amenity areas" was supported by Professor Dent.[94] He said that local authorities were failing to ensure that their contracts were managed by people who had appropriate training. Since the VI had very little leverage in the amenity sector, Professor Dent agreed that regulation might be the only way to deal with use of pesticides in this sector.[95]

Our conclusions

53. The incorporation of some VI measures into the requirements of assurance schemes was worthwhile. Nevertheless, the VI must cover the significant numbers of farmers operating outside the schemes. Setting challenging targets for levels of participation by farmers is an important aspect; so too is engagement with non-farming sectors. However, the VI can never be sufficiently comprehensive so as to include all pesticide users. Therefore, we recommend that the Government strengthen enforcement of existing regulations in the amenity sector and, if this does not succeed in bringing about the desired improvement in practice, that the Government then consider introducing further regulatory measures.

54. Local authorities have a particular responsibility to ensure that their contracts are carried out by suitably trained operators, using equipment that has been properly checked. The Government should ensure that this responsibility is communicated clearly to local authorities by central government. Prior to the introduction of any legislation, the Government should work with local authorities to agree a code of practice on the use of pesticides. This code should apply across all types of local authority.

Failure of Government to engage with VI

55. We heard criticism of the way in which Defra has engaged with the VI. The EAC found that the VI's chairman and steering group were "isolated—and indeed alienated" from Defra.[96] The Government's response to the EAC's report made clear that "the Government regards the VI as an industry initiative and does not see itself as having an equal role in its delivery".[97] It also noted that "the Government has never agreed the targets in the original VI proposals".[98] Professor Dent confirmed to us that the VI targets have never been agreed to by the Government.[99] He reported a five-month delay between the steering group submitting its first paper on indicators and targets and a response being received from Defra.[100]

56. Professor Dent described how, at the very beginning, the VI was given the "cold shoulder" by the Government.[101] He said it "was made fairly clear to me, at the first meetings, that the VI [was] on its own and [was] not going to be supported in any way by Government".[102] He described the relationship over the last 18 months as "cordial" but "hardly a partnership".[103]

57. The Minister admitted that, initially, "there was something of a gap between those involved in the initiative and the aspirations of [the] Government". However, subsequently, "it has become much more of a partnership".[104] The Minister felt it was Defra's role "to challenge the initiative", in a way that "pushes them as far as possible without being unrealistic".[105]

58. During the evidence sessions, there was a feeling that while the Government was happy to threaten pesticides users with the 'stick' of taxation, there were very few 'carrots', by way of incentives for users to adopt VI measures.[106] Professor Dent was adamant that maximum environmental improvement would come only from the VI activities being assisted by Government.[107] He said it seemed "entirely right and proper that the Government should make some contribution towards the training necessary to keep [sprayer operators] on the professional register, to upgrade their professional skills".[108] He thought that funding under the England Rural Development Programme would be a very good way of achieving this.

National roll-out of water catchment projects

59. All the costs of the VI projects have been funded by its signatories; the Government has provided no financial assistance.[109] A specific instance where government support might be beneficial is the national roll-out of the water catchment projects.[110] Without such support, FoE questioned the feasibility of expanding the pilot water catchment projects to a national level. It suggested this "would be extremely expensive" and that "it is not entirely clear who is going to pay" for such a roll-out.[111] FoE also cited analysis it had done on the costs incurred by the catchment project in Boston Park, South Yorkshire:

Just the calibration for text messaging in that catchment cost £5,700, and there were only 60 farmers in the catchment, so that is £95 per farmer. Obviously there will be economies of scale but you can see that costs will escalate quite rapidly.[112]

60. The NFU, on the other hand, felt that things like text messaging could be rolled out very easily.[113] Professor Dent noted that there were many water catchments in the country where there were no pesticide pollution problems at all.[114] Defra noted too that the VI, in rolling out its water protection projects to more catchments, was "particularly looking at the more generic issues" to maximise efficiency gains. When asked about the possibility of Defra funding the national roll-out of the catchment projects, officials said it was "a matter for ministers as to how we go forward with that and how it links in with catchment-sensitive farming".[115]

Our conclusions

61. It is regrettable that the Government co-operated so little with the VI at the beginning of the programme. Despite HM Treasury's initial welcome for the initiative, in 2000, the evidence we received indicates that the Government, and in particular Defra, did not engage meaningfully with the VI. Government agreement on the VI's targets, at that stage, would have assisted the initiative in planning for the achievement of those targets. We recommend that Defra continues to foster its newfound partnership with the VI. To this end, the Government should provide financial support for the national roll-out of the water catchment projects, and help to facilitate ongoing professional training, using rural development funds.

Future of the VI

62. The VI is due to come to an end in April 2006 and the Government has said it will "evaluate the success of the scheme and its environmental impact to assess which further actions are required beyond 2006".[116] The Minister described this evaluation as the "key test" of how the VI has performed "against the targets it has set itself" and of how well those targets have translated into the reduction of pollution and environmental outcomes.[117]

63. The CPA stressed the need for the positive elements of the VI to continue after April 2006.[118] The EA agreed, and raised concerns about the implications of a possible gap between the end of the VI and "whatever comes after it".[119] Professor Dent looked forward to a "strong future role for something like the VI", with a successor monitoring existing projects and developing new ones.[120] Professor Dent also saw a future role for the VI as a "kind of information centre", to which those dealing with water catchments could look for guidance on advising affected farmers.[121]

Our conclusions

64. It is crucial that the benefits of the VI are not lost after April 2006. The initiative should continue, at least until the Government has developed and fully implemented a national pesticides strategy. Even then, we believe there will be a continuing need for the establishment of a centre of best practice for the use of pesticides; the experience acquired through operating the initiative's programme leaves the VI steering group well placed to fulfil this requirement. As more of the VI's measures are encompassed by other schemes—such as food assurance and environmental stewardship—we consider that the initiative should evolve to focus more on catchment-sensitive farming and other water issues.

36 Above n 13, p 9 Back

37 Ev 46 Back

38 Q 106 Back

39 Ev 1 Back

40 Q 3 Back

41 PAN-UK re-submitted a memorandum to us, jointly authored with FoE, which both PAN-UK and FoE had previously submitted to the EAC: Environmental Audit Committee, Third Report of Session 2003-04, Pre-Budget Report 2003: Aviation Follow-up, HC 233-II, Ev 123. We have not reprinted this memorandum. Back

42 Q 6 Back

43 Ev 172-173 Back

44 The Voluntary Initiative, Indicators and Targets 2004/5, March 2004, p 27 Back

45 Q 310 Back