Memorandum submitted by the Country Land
and Business Association (CLA) (Z12)
1. TERMS OF
REFERENCE
The Inquiry is intended to review progress under
the Voluntary Initiative to minimize the environmental impacts
of pesticide use, and in particular to assess whether the Voluntary
Initiative is proving successful; and to look into related matters,
such as the proposal for a pesticides tax.
2. EXECUTIVE
SUMMARY
— The VI has made very good progress
and met or exceeded its original targets which were then acknowledged
as being extremely challenging.
— The fact that the VI steering group
has reviewed and increased some targets and projects is welcomed
and creditable.
— The strong partnership between stakeholders
and the experience and goodwill that has been developed will be
extremely important as the VI expands and hopefully becomes a
national initiative.
— De-coupling and the introduction
of new agri-environment schemes will complement the work of the
VI and help achieve greater take-up of improved practice.
— The record of the public and amenity
sector on addressing the incidence of Diuron in water is poor
despite the efforts of the VI to engage the sector.
— The contamination of water by pesticides
or other inputs can take time to reduce but already the VI appears
to have achieved significant reductions in at least some of the
pilot catchments. The VI must be given time to succeed and the
momentum and partnership of VI stakeholders not wasted by counter-productive
moves towards a pesticides tax.
3. INTRODUCTION
The CLA has nearly 40,000 members who between
them own approximately half the rural land in England and Wales.
The majority of our members have a keen interest in the responsible
use of pesticides because their land is actively farmed, and in
addition they may have sporting interests where the quality of
field or water habitats is extremely important.
4. The Association recognises that reducing
the contamination of water by pesticides is an environmental priority
which will lead to improved water quality for the public and wildlife.
We also recognise that pesticides play a crucial part in the economic
management of farmland, forestry, conservation projects and public
amenity areas. With the imminent introduction of de-coupling and
greater exposure to world markets it is imperative that the management
options available to UK farmers are not unfairly constrained.
Good long-term stewardship of the land and the health of the rural
economy are core issues for the CLA. We are aware of the impacts
on countryside management caused by a declining and aging workforce
and are concerned that increased regulation or restriction of
any description may simply compound the problem of encouraging
skilled people into countryside employment.
5. THE VOLUNTARY
INITIATIVE
Because of our views on the importance and sensible
use of pesticides we contributed to the inception of the Voluntary
Initiative and are keen to support and promote its work through
membership of the steering group and sub-groups, and publicising
key issues and achievements. The CLA believes that because of
the diverse range of farming conditions, the impact of extreme
weather events such as this years heavy spring and summer showers
and the fact that pesticides can be used with minimal risk to
the environment, a voluntary approach was the only constructive
way to tackle this complex issue.
6. The Initiative has resulted in a partnership
of different organizations who have generally worked together
in an extremely positive and committed manner. There are no less
than 31 different projects being carried out under the general
headings of Research, Training and Communication & Stewardship
and they are currently all on target, although a high level of
continuous effort is needed. These have included innovative projects
as diverse as the new H2OK promotion, the introduction of new
Biodiversity and Environment Training for Advisers (BETA), text
messaging spray alerts and operator roadshows. The three Headline
Targets for changing behaviour have also showed very good results
up to 31 March 2004 with the National Register of Sprayer Operators
accounting for 60% of the arable area, the National Sprayer Testing
Scheme 40% of the arable area and Crop Protection Management Plans
18% of the arable area. We feel these are very creditable and
encouraging results, particularly set against a backdrop of major
change and uncertainty for the agricultural industry. We do not
doubt there is much to do but are convinced that the VI has already
demonstrated that it has the ability to meet Government targets
and retain the support of farmers and their advisers.
7. REDUCING PESTICIDES
IN WATER
Of course the key outcome is to reduce pesticide
contamination of water. The national target of the VI is to reduce
exceedences of the Drinking Water Standard by 30% with a high
figure of 50% adopted for the pilot surface water catchments by
2006. Improvements in water quality and the biodiversity of farmland
will often take years to become apparent which is why the VI Steering
Group quite correctly selected indicators of improved awareness
and practice which will lead to improvements in environmental
indicators. However very encouraging reductions in pesticide levels
have already been noted in the Leam and Blythe catchments which
is helping to promote interest in the VI generally and enthuse
the partnerships in these and the other pilot areas. It has been
reported that the overall reduction in pesticide loading in the
Leam would have been 70% this year if it had not been for a particularly
severe torrential shower at the end of April which took the reduction
back to 60%. However even this is well over the increased target
of 50% adopted for the pilot surface water catchments. The promotion
of the VI in the pilot catchments has increased awareness and
has changed practice through the use of newsletters, weekly text
messaging, the use of a champion farmer and local meetings to
explain eg sprayer testing. Currently there are efforts to analyse
the Crop Protection Management Plans in the pilot areas and establish
links between the management adopted and improvements in water
quality. It is hoped that this will provide invaluable information
which can be related to farmed land all over the country.
8. SETTING DEMANDING
TARGETS
As we have previously stated we believe the
VI has already made great progress which should be recognised
and commended. We acknowledge that Government and some commentators
have expressed doubts over how demanding some of the headline
targets are but at time of being set they were seen to be extremely
demanding. It is creditable that these have been set and exceeded.
It is also very positive that the VI has already reacted to these
concerns by deciding to increase some of the interim targets and
to almost double the number of pilot catchments to monitor effects
before the planned national rollout. The responsiveness of the
stakeholder organisations and their commitment to achieve results
must surely underline the advantage of encouraging industry led
solutions rather than a adopting a regulatory approach. This was
recognised by Government when the following text was included
in the Chancellor's budget report of April 2004; "the Government
continues to believe that, if fully implemented, the Voluntary
Initiative is the most effective way of reducing the environmental
pollution associated with pesticides".
9. The CLA welcomes this acknowledgement
from Government. We are against command and control approaches
and especially the use of pollution taxes for pesticides, primarily
because we believe they would have little impact in reducing pollution.
It is the management of these products that should be targeted
than the fact they are used. The benefits from the use of pesticides
to agricultural production are such that practicable levels of
tax would have a negligible impact on usage rates and would simply
increase the cost of food production. In short a tax on any agricultural
input would be an ineffective way of reducing pollution and would
penalise all users, good and bad, which goes against the principle
of the "polluter pays". Furthermore the introduction
of a pesticide tax at this stage of the VI would send out a very
negative signal to all those involved, undermining the hard work
put in so far and the goodwill generated amongst stakeholders.
10. FUTURE CHANGES
AND THE
VOLUNTARY INITIATIVE
THE INTRODUCTION
OF DE-COUPLING
IN JANUARY
2005 WILL MARK
A WATERSHED
FOR THE
AGRICULTURAL INDUSTRY
AND ONE
WHICH WILL
POSE MAJOR
CHALLENGES FOR
FARMERS AND
THE COUNTRYSIDE
THEY MANAGE.
WITH PAYMENTS
NO LONGER
CONDITIONAL ON
THE PRODUCTION
OF CROPS
OR LIVESTOCK
IT IS
WIDELY EXPECTED
THAT UNECONOMIC
AREAS OF
CROPPED LAND
WILL NO
LONGER BE
CULTIVATED AND
LIVESTOCK ENTERPRISES
WILL BE
REDUCED OR
DISPERSED. THE
INTRODUCTION OF
CROSS COMPLIANCE
RULES, COMPLEMENTED
BY THE
INTRODUCTION OF
NEW AGRI-ENVIRONMENTAL
SCHEMES, WILL
SIGNAL THE
CHANGE OF
DIRECTION FOR
PUBLIC SUPPORT
OF AGRICULTURE,
FROM FOOD
PRODUCTION TO
THE DELIVERY
OF ENVIRONMENTAL
SERVICES. THE
COMBINATION OF
GREATER FLEXIBILITY
OF LAND
USE AND
A MUCH
HIGHER PROFILE
FOR ENVIRONMENTAL
PROTECTION SHOULD
BENEFIT THE
VI BY ENCOURAGING
ENGAGEMENT WITH
HIGH NUMBERS
OF FARMERS
AND ALLOWING
EASIER ADOPTION
OF BENEFICIAL
PRACTICES SUCH
AS BUFFER
ZONES.
11. ENVIRONMENTAL
STEWARDSHIP
Over the last two years Defra has been undertaking
a thorough review of the current agri-environment schemes, partly
in response to the Curry Report which highlighted that the vast
majority of farmed land is not managed under an agri-environment
agreement. The CLA has keenly supported this process and contributed
fully at all stages of the Review. Since before the introduction
of the first Environmentally Sensitive Areas the Association has
lobbied for payments to be made available to all land managers
for the delivery of environmental land management services. We
recognise the enormous environmental potential of all managed
land and believe that the new entry level, organic entry level
and higher level schemes comprise a very exciting and comprehensive
package. We are convinced that the options and structure of Environmental
Stewardship, complemented by the flexibility offered by de-coupling,
offers great potential to encourage widespread voluntary take-up
of the principles and experiences of the VI and so significantly
reduce the incidence of pesticides in water.
12. A key aspect of the new entry level
scheme is that it will be available to the vast majority of land
managers and will not be constrained by a competitive budget.
The wide range of options proposed will allow the implementation
of exciting conservation strategies tailored to the needs of the
farm business and the environmental priorities. The inclusion
of Resource Protection as a formal objective of agri-environment
schemes has allowed a wide range of options to be introduced or
refined to deliver good management for soil and water.
13. The application process itself with
farmers having to complete a Farm Environmental Record will facilitate
greater awareness of the environmental features of the farm and
the most important environmental priorities. The inclusion of
management plan options for soil, nutrient, manure and particularly
crop protection are especially welcome and will raise the standard
of whole farm management. As well as the direct benefits in reductions
of diffuse pollution and soil erosion this should bring associated
benefits for biodiversity, landscape, historical interest and
public enjoyment. Defra's agreement that the VI Crop Protection
Management Plan will meet the requirements of the ELS CPMP is
welcomed and is a logical and constructive example of the integration
of Government policy and industry initiatives.
14. Although the Higher Level Scheme will
be competitive and highly targeted the fact that resource protection
will be a formal objective of this scheme as well means it will
also help to encourage more support and engagement with the VI.
The requirement for a Farm Environment Plan (FEP) before application
will ensure that the applicant is fully aware of the major environmental
issues on the holding or in the locality. The Environment Agency
and English Nature have prioritised a list of just over 100 river
catchments where soil erosion and/or water quality issues are
major concerns. To successfully achieve good results in these
catchments will rely on a combination of both entry level and
higher level options and, we would suggest, local co-ordination
and the full support of the majority of local land managers. The
messages of the VI and the experience gained from the existing
and new pilot projects will be valuable in ensuring that the priorities
in these different target catchments are successfully addressed.
Reducing the impact of agriculture on water quality alongside
the demands of commercial land management and while subject to
the weather extremes expected from climate change will be challenging.
Enthusing land managers through an industry led initiative supported
by agri-environment options rather than a regulatory approach
will offer the best chance of success.
15. THE ROLE
OF THE
PUBLIC SECTOR
The herbicide Diuron is one of the most commonly
detected pesticides in water but is used by the amenity sector
and not agriculture. 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. Their apparent
lack of interest and motivation contrasts sharply with the results
already achieved by the agricultural industry. It is also worth
noting that any proposed pesticides tax would not impact greatly
on this sector.
16. We know that the EFRA Committee highlighted
concern about the record of Local Authorities on the conservation
of SSSIs when it published its findings "Sites of Special
Scientific Interest: Conserving the Jewels of England's Natural
Heritage" on 15 July 2004. The same issues seem to be reflected
in the use of herbicides. Although we appreciate that local authorities
are under some pressure this does not compare well with the limited
time and financial resources available to our members or the great
economic pressures on the countryside. We would also point out
that the use of herbicides to treat amenity areas has much lower
economic importance than the use of pesticides in crop and livestock
production. The lack of commitment in seeking to reduce the use
of Diuron from the public sector and the apparent absence of even
recognition of the problem is extremely disappointing. When the
key priority for reducing the incidence of pesticides in water
is to ensure a continuous supply of safe water for the public
it is reasonable for land managers to expect public bodies to
take this issue seriously. We hope the EFRA committee will note
this point and that Government will be able to encourage full
participation from local authorities in the near future.
17. CONCLUSION
The CLA believes that the Voluntary Initiative
has made good progress towards its aim of reducing the incidence
of pesticides in water. The comprehensive range of projects is
innovative and diverse and the uptake by the agricultural industry
and their advisers has been good. Although it is accepted that
the results of changing land management practices may take some
years to become apparent there are already encouraging signs that,
in some of the pilot areas at least, the incidence of pollution
attributable to agricultural pesticides is declining.
18. Both the CLA and the VI Steering Group
know there is much more to do but the decision to react to concerns
about the robustness of some of the targets by increasing interim
targets and to expand the number of pilot catchments underlines
the commitment to making the VI work. The VI is building up a
great deal of valuable experience and knowledge prior to a potential
national roll-out. Equally important is that the Initiative is
gradually increasing the interest and engagement of the agricultural
industry at a time of huge change and concern for land managers.
19. As the VI has progressed we have seen
some very encouraging results emerge, especially given the nature
and complexity of the problem it is addressing. The lessons learnt,
complemented by the greater flexibility offered by de-coupling
and the new Environmental Stewardship agri-environment schemes,
suggests that this industry led initiative could achieve wide
scale reduction of pesticide contamination in the future. It deserves
continued support and the time to succeed.
7 October 2004
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