House of Commons - Environment, Food and Rural Affairs

Select Committee on Environment, Food and Rural Affairs Eighth Report

5 National pesticides strategy

85. On 16 February 2005, Defra launched a public consultation exercise, seeking comments and views on a draft national strategy for the sustainable use of plant protection products.[162] The consultation is due to run until 30 June 2005 and the expectation is that the final strategy will be published after responses to the consultation have been fed into the development process and after the final document has been approved by ministers.[163]

86. The UK's national pesticides strategy should fulfil its EU obligation to develop a national plan. The need for each EU member state to develop a national plan was emphasised by the European Commission's 2002 communication on a thematic strategy on the sustainable use of pesticides. The objective of this thematic strategy was to reduce the impact of pesticides on human health and the environment and, more generally, to achieve more sustainable use of pesticides and a significant overall reduction in risks, while ensuring necessary crop protection.[164] The national plans were intended to set out how each member state should reduce hazards, risks and dependence on chemical control of agricultural pests and diseases and improve controls on the use and distribution of pesticides.[165]

Time taken

Environmental Audit Committee report

87. The draft national pesticides strategy was launched two years after the Government's response to the EAC report had promised to make its development a "priority".[166] In November 2002, the EAC recommended that the Government must "as a matter of urgency, develop and publish a pesticides strategy".[167] The Government response, published in February 2003, noted that "the development of the plan will be a priority for the Pesticides Safety Directorate in 2003" and confirmed that it did "not intend to wait for the eventual adoption of the [EU] thematic strategy before beginning work on a national plan".[168]

Evidence received

88. Several witnesses, including the EA and the RSPB, expressed disappointment at the amount of time it had taken Defra to release the draft national pesticides strategy for consultation.[169] The RSPB and Water UK noted that the delay had meant that an opportunity "to combine pesticides issues with the consultation on catchment-sensitive farming" had been lost.[170] The RSPB also suggested that the strategy's delay had been particularly unhelpful for the successful operation of the VI, both in terms of reducing confidence amongst farmers and in failing to provide the policy context into which the initiative might fit.[171] The RSPB felt that the delay had "caused a problem for the VI because it does not have a clear steer on what it is aiming at".[172]

89. The Minister explained that one of the reasons the strategy had taken so long to produce was "that it actually covers quite a complex range of issues".[173] He admitted that the "issues and challenges faced" were "more complicated than we had initially hoped".[174] PSD officials also said that there was new environmental legislation coming through that would impact on pesticides, so the strategy was delayed to enable it to mesh with those other initiatives.[175]

Our conclusions

90. We are unconvinced by Defra's justification for the lengthy delay in launching its national pesticides strategy. Despite promising, in February 2003, that the development of the plan would be a "priority", the Government did not publish the plan until February 2005—a time lapse of two years. The delay indicates to us that the sustainable use of pesticides has not been given the priority it deserves. We recommend that the Government publish its final strategy document, as a matter of urgency, to establish a clear policy framework within which the VI, or its successor, can operate.

Components of the strategy

91. The draft strategy sets out the existing legal controls on pesticides in the UK, as well as other measures that influence the use of plant protection products. It considers the development and use of alternative products and techniques for pest control. The most significant components of the strategy are proposals for five 'action plans' that would cover the following areas:

water

biodiversity

availability of plant protection products

amenity sector and amateur use, and

targeted use reduction.[176]

We consider two of these action plans below.

Amenity sector and amateur use

92. The draft strategy aims to cover "all uses of plant protection products" and proposes an action plan to look specifically at the non-agricultural use of pesticides.[177] Defra describes the strategy's inclusion of the leisure and amenity sectors as "timely", adding that it "should bring particular benefits given the significant use of pesticides in these [sectors] and the fact that to some extent they have existed 'in the shadows' of agricultural uses".[178] The strategy acknowledges that amenity uses, "including the landscape, sports turf, highways and parks sectors", and amateur use in gardens, "have historically received less attention than farm uses".[179] It also notes that "amenity users may not be required to hold a certificate of competence and amateurs are not required to have been trained".[180]

93. The amenity sector action plan contained in the draft strategy lists a series of desired outcomes it hopes to achieve against a corresponding set of issues. The possible measures under consideration include a new code of practice, dissemination of best practice and the introduction of a regular usage survey in the amenity sector.[181]

94. To address the potential for problems in this very diverse sector, the VI has established an amenity forum.[182] However, as we have discussed, the evidence suggested that the initiative has been unable to engage properly with amenity pesticide users, particularly the local authorities.[183] Another issue raised in evidence was the disproportionate environmental impact of amenity pesticide use. The CPA told us that the whole amenity sector accounted for "only about 5%" of all UK pesticide use by weight, but that it resulted in "more than 15%" of pesticides found in surface waters.[184]

95. The Minister acknowledged that that the amount of pesticides used by the amenity sector was "sufficiently significant to be important in particular locations" and admitted that users in this sector might not have received the level of training that was becoming standard within the farming industry.[185] He agreed that amenity use of pesticides was an area the Government needed to address, and identified engaging with highway authorities and local authorities as being the first priority.[186] Even though amenity use represented "a smaller part" than agricultural use, the Minister assured us it would not be overlooked.[187]

Our conclusions

96. We welcome the inclusion in the draft national pesticides strategy of an action plan addressing the use of pesticides in the amenity sector. The amenity sector has participated very little in the VI, and has therefore been left behind in the adoption of best practice. We recommend that the Government bring forward this action plan as a matter of priority. The amenity use of pesticides should be controlled in the same way as agricultural use.

Targeted use reduction

97. The draft strategy's inclusion of a programme for targeted use reduction answered calls from the EA for further action on the nine pesticides which contribute most to water contamination.[188] While the draft strategy makes it clear the Government does not intend "to set a target for an across-the-board reduction in pesticides", it does commit the Government to studying whether "bearing down on particular areas of pesticide use" might further the central aim of reducing environmental impacts.[189] One option under consideration would be to limit the levels of use of the specific herbicides that cause the most contamination to drinking water, or the time of year for which they are used. Professor Dent endorsed this approach when he described the problems that can be caused by such a mobile chemical as isoproturon.[190] The Minister said that "looking for alternative products" was "not an immediate quick-fix", but was "very much part of the strategy" for the long-term.[191] Despite this, we received no evidence of specific examples of ongoing work aimed at developing new pesticides to substitute for the nine that have been particularly implicated in the contamination of drinking water.[192]

Making VI measures mandatory

98. The draft strategy suggests that "making some of the measures introduced by the VI mandatory", might be an example of a "more wide ranging" way of supporting and supplementing the action plans.[193] The draft strategy identifies the following benefits of such an approach:

it would focus action on those who have not signed up to the VI
it would not impose any new burdens on those who do currently follow best VI practice, and
it would help reduce the risk that the VI's 'best practice' measures are lost when the initiative comes to an end in 2006.[194]

The draft strategy notes that "legislation, unless EU wide, is often seen as disadvantaging UK businesses[,] so care would need to be taken in considering which, if any, of the VI's measures should be made statutory".[195] To this end, the draft strategy suggests:

It would be worth considering those VI measures that coincide with the areas being contemplated by the EU Commission for [its] thematic strategy. For example the initiative's current scheme for sprayer testing would seem to fit in well with the Commission's thinking in respect of 'technical checking of spraying equipment'.[196]

99. Several witnesses specifically picked out sprayer testing and operator training as being the two VI measures most suitable for statutory underpinning. PAN-UK said it "would like some elements of the VI to become mandatory, such as the sprayer testing [and] sprayer operator training".[197] Its joint evidence with FoE also noted that sprayer operator registration is likely to be required by the EU thematic strategy.[198]

100. The Government did not seem particularly anxious to make any of the VI measures mandatory. Its response to the EAC report suggested that legislation focussed on particular areas could help the initiative "deliver real results", but that "wholesale regulation" was "not appropriate to underpin the VI".[199] The Minister told us that he was looking more towards synergies between the VI and other policies, such as cross-compliance and the way the Water Framework Directive is implemented, rather than introducing "another totally separate set of regulations" to control pesticide use, which he thought would "go down like the proverbial lead balloon".[200] He thought decisions on making VI measures mandatory could be left until the evaluation in 2006.[201]

Our conclusions

101. We recommend that the Government move to legislate to make some elements of the VI mandatory—in particular, the initiative's schemes for sprayer testing and operator registration. This would force pesticide users not already participating in these schemes to take action, in particular, non-agricultural users. Since forthcoming EU legislation is likely to make sprayer testing and operator registration compulsory, such an approach should not compromise the competitiveness of UK agriculture.

Complementary policies

102. Defra said that, in addition to working up proposals for the five new action plans, the development of the draft strategy should involve "an assessment of existing policies and instruments that influence the use of plant protection products", including "not only pesticide policies but also related environmental and agri-environmental policies".[202] The Minister confirmed that there were a "number of measures which complement the work" of the VI, including agri-environment schemes and cross-compliance.[203] These two measures are included in the draft strategy's list of measures and policies to be assessed, and were the ones most frequently referred to in the evidence we received.

Agri-environmental schemes

103. Defra's new agri-environment scheme, Environmental Stewardship, offers farmers in England financial incentives to join one of three different conservation schemes.[204] Entrants into the basic, or entry-level stewardship scheme, receive £30 per hectare (or £8 per hectare if the land is within a less favoured area). This scheme allows farmers to choose from over 50 simple management options in order to accumulate the required points target of 30 points per hectare. One of the management options is the Crop Protection Management Plan (CPMP), one of the key schemes in the VI.[205] Farmers carrying out a CPMP receive two points per hectare towards their final total.[206] The VI's biodiversity project promoting skylark plots is also included in the entry-level scheme and can earn a farmer five points for each one.[207] Under this project, farmers leave patches of land unsown for skylarks to nest on.

104. The importance of agri-environmental schemes was recognised in evidence, with the RSPB describing them as "an increasingly important set of options, which provide incentives to encourage the reduction of pesticide impacts".[208] Incorporation of VI measures into agri-environmental schemes was welcomed by some witnesses, including the CPA, which advocated the use of fiscal incentives to integrate aspects of the VI into "wider policy initiatives".[209] The CPA illustrated this by noting the "inclusion of CPMPs, managed field margins and skylark plots in the entry-level scheme".[210]

Cross-compliance

105. To continue to receive direct subsidies under the reformed Common Agricultural Policy (CAP), farmers have to keep their land in what is described as good agricultural and environmental condition.[211] They also have to comply with a range of European regulations, including the 1991 Council Directive on plant protection products.[212]

106. In England, the conditions attached to the receipt of direct subsidies—known as cross-compliance conditions—include leaving areas next to living boundaries, such as hedges and ditches, uncultivated and unsprayed. The NFU described a change to the set-aside rules to allow six-metre strips next to water courses as "a really sensible and helpful move" that ties "CAP reform with environmental farm management".[213]

107. Opinions were divided on the question of incorporating VI measures into the cross-compliance conditions attached to the receipt of direct subsidies. The Soil Association believed that "the provisions of the VI could easily be made a requirement of cross-compliance by Defra, thus ensuring what is likely to be a significantly higher adherence to the initiative, at no additional expense to the taxpayer".[214] However, the NFU felt using cross-compliance in this way would be like "using the stick", whereas the VI was about a "partnership", "encouraging people down the route of environmental responsibility and good practice".[215]

Our conclusions

108. It is important that the scope of the national pesticides strategy is wide enough to enable the Government to explore how complementary policies can play a role in reducing pesticide impacts. Agri-environment schemes and cross compliance measures can—and should—complement and encourage a greater uptake of measures in the VI. We recommend that the Government look at ways in which different policy instruments can complement each other in achieving a reduction in the environmental impacts of pesticides.

162 "Pesticides-A UK Strategy", Defra news release 72/05, 16 February 2005 Back

163 Pesticides Safety Directorate, A Draft National Strategy for the Sustainable Use of Plant Protection Products, February 2005, paras 5.3-5.4 Back

164 European Commission, Towards a Thematic Strategy on the Sustainable Use of Pesticides, COM (2002) 349, p 4 Back

165 Ibid., pp 29-31 Back

166 HC (2002-03) 443, p 10 Back

167 HC (2002-03) 100, para 46 Back

168 HC (2002-03) 443, pp 9-10 Back

169 Ev 76 [EA], ev 58 [RSPB]; qq 163, 182-183 [RSPB], q 231 [EA] Back

170 Ev 58, 166 Back

171 Qq 197, 163 Back