Supplementary memorandum submitted by
PAN UK (Z 41)
PAN UK would like to submit the following further
information, in response to the questions asked during the evidence
session on 8 February 2005.
1. PESTICIDE
TAX
1.1 Administration costs and Hypothecation
There are a large number of reports and publications
relating to the use of a pesticide tax. The most comprehensive
of these is the Ecotec report to the DETR.[14]
In none of these documents are we aware of any information relating
to the cost of implementation and therefore cannot respond further
to the suggestion that the high cost of administering a pesticide
tax will make such a tax unjustifiable.
PAN UK would like to point out, however the
following:
— There is currently a levy on pesticide
sales to cover a number of costs, including monitoring of wildlife
incidents, pesticide usage and pesticide residues. This is set
at a much lower level than most proposed taxes and yet is seen
as cost effective.
— Taxes, both flat-rate and banded,
are implemented in other countries and revenues are raised successfully.
There also appears to be no difficulty in hypothecation of these
taxes. A brief report outlining these schemes was prepared by
PAN-UK for Friends of the Earth and a copy will be provided for
your information.
We would suggest that any problems that are
envisaged with either successfully hypothecating the tax or with
unreasonably high administration costs should be addressed to
the Treasury.
There has been some suggestion that, using the
principle of "the polluter pays", it could be appropriate
to hypothecate the tax to pay for the removal of pesticides from
drinking water. While this sounds reasonable and logical, we would
not support this unless it could be ensured that farmers themselves
do not shoulder this burden. There would be a danger that the
resulting reduction in farm incomes would lead to a greater reluctance
to move towards potentially more risky strategies such as non-chemical
alternatives or lowered doses. Farmers would thus be locked into
a high-pesticide-use strategy. We would support hypothecation
only for the development and promotion of reductions in pesticide
inputs and non-chemical alternatives.
1.2 Design of a Banded Tax
During the evidence session on 8 February, I
suggested that we could send some details of tax banding schemes.
I have found it difficult to identify the necessary information
within a reasonable time frame—PAN itself has not developed
such a scheme, but has worked on this with other organisations.
Since the option of a tax is suggested in the consultation on
the National Strategy for Pesticides, this will be an appropriate
opportunity for a fuller discussion about possible taxation schemes.
A brief outline of some of the proposed/existing
schemes are outlined below:
A number of studies have addressed this issue
and there are therefore a several "off the shelf" options.
In particular, banded taxes have already been implemented in Norway.
A review of some tax banding options is contained in the Ecotec
report, and other organisations have more recently undertaken
studies on classifying pesticide hazards—eg the Environment
Agency in 2003 proposed a ranking method for chemicals based on
their direct environmental effect; work undertaken by the RSPB
and PAN-UK built on this and took into account the indirect effects;
The Co-op, in conjunction with a number of organisations including
PAN-UK, is developing a system for classifying pesticides by the
hazard they present. PAN-UK is not in a position to supply details
of these schemes, but more detailed information may be available
from the relevant organisations.
Some of the above schemes are based solely on
hazards, others attempt to take into account the way they are
used by included some level of risk assessment. Since there are
a wide range of pesticide impacts which could be included in the
banding system, and risk assessment is far from straightforward,
PAN is concerned that an attempt to include them all and to satisfy
all the relevant stakeholders, could lead to an immensely complicated,
and ultimately unworkable scheme. We recognise that the more complicated
the tax becomes, the greater the administration costs are likely
to be. This may be a valid reason for keeping to a relatively
simple scheme, such as a flat rate tax that is supported by PAN
Europe.
It is important that whether a flat-rate or
banding system is employed, some attempt to account for the differences
in application rate between pesticides is required. A simple tax
per kg will discriminate against high volume products even when
these may have lower levels of impacts than low volume products
and an ad valorem tax may be most appropriate. A discussion
of the likely effects of some of the different tax options is
given in the Ecotec report.
Whatever scheme is employed, it is likely that
some anomalies will be generated whereby the tax system encourages
moves towards less desirable pesticides. There will be a need
for good monitoring of pesticide usage and regular reviews of
the banding system to ensure that these anomalies are eliminated
quickly.
Evidence from the countries that currently have
a pesticide tax show that a tax does not, on its own, appear to
result in a large reduction in pesticide usage, although as part
of a package of measures to reduce pesticides it has been successful.
In summary, PAN UK would support:
— A fully hypothecated pesticide tax.
— A relatively simple scheme that can
be applied at the earliest opportunity.
— The revenue raised to be used for
providing independent, free advice to farmers on how to reduce
their dependence on pesticides and for research and development
into non-chemical pest control methods.
2. CURRENT VI
TARGETS
2.1 Three of the main VI targets (Crop Protection
Management Plans, Sprayer testing and National Register of Spray
Operators) relate only to the "means" of achieving a
reduction in impact, rather than the end itself. We believe that
there is likely to be a relatively poor correlation between these
targets and reduced environmental impact, even if the targets
were met in full.
2.2 The targets are largely only quantitative
and there seems to be no element of "quality".
2.2.1 One example that has already been
outlined is that of Crop Protection Management Plans—the
VI only monitors how many are completed, not the levels that are
being achieved—a "poor" plan still counts towards
the target.
2.2.2 A second example is NRoSO and the
need to accrue CPD points. Firstly, spray operators have three
years to accrue 30 points, so in principle, few people will need
to have any points at all at the moment. It is important to have
targets for points awarded as well as the number of spray operators
registered. Secondly, points are available for activities that
many spray operators will already be doing—subscribing to
farming journals, attending shows and events—and so the
VI should really be monitoring increases in points obtained. Thirdly,
personal experience of giving talks at events where CPD points
are awarded suggests that, in some cases at least, (i) speakers
are given no brief of what to say; (ii) those allocating points
to the event have no knowledge of what is going to be said and
(iii) there is no feedback to speakers afterwards.
2.3 Current targets are aimed only at reaching
the most professional and environmentally aware farmers and so
they should be relatively easy to meet. There appears to be no
strategy for reaching the rest.
2.4 Targets should be based on environmental
impact, and include terrestrial as well as water contamination.
It may be difficult and expensive to monitor environmental impacts,
but it needs to be done. If further research is needed to establish
the best methodology, then this should be done as a matter of
urgency.
2.5 A target of pesticide use reduction
should be relatively easy to measure and we would be much more
confident of a correlation with environmental impacts than the
existing targets. But, we need to ensure it is measured sensibly—kg
sold is declining anyway as pesticides become more concentrated
in their effect so this would not be helpful, and won't take account
of moves to less hazardous pesticides which should also be encouraged.
3. OTHER ISSUES
3.1 A significant amount of training and
information is currently in the hands of the Ag Chem manufacturers
and distributors who rely on selling pesticides to make their
profits. We will never get a real emphasis on use reduction until
this is provided by wholly independent organisations.
3.2 Research has not been well targeted:
— The issues of the relationship between
pesticides and biodiversity and how to measure biodiversity impacts
have not been addressed. The SAFFIE project is largely aimed at
crop and field margin management techniques to offset the effects
of pesticides, rather than directly reducing pesticide impacts.
— The VI has not taken the opportunity
to contribute to the development of non-chemical alternatives
or other techniques for reducing use.
— There is a real danger that full
advantage will not be taken of the research funded through the
VI unless the Ag Chem industry have a commitment to following
it up in some way—eg there is a clear need in one of the
projects (Spray behaviour at reduced application volumes) for
individual companies to extend the work to their own products.
There is little sign of this happening, and little evidence that
agrochemical manufacturers are aware of the opportunities that
this project has highlighted.
3.3 The VI has put most responsibility for
reducing the environmental impacts of pesticides onto farmers.
They Agrochemical Industry has offered little in terms of supporting
lower doses or a commitment to developing less hazardous products.
3.4 The CPA in their evidence said (in response
to Q4)—"we will never ask people to use more than absolutely
necessary" and yet shortly afterwards, evidence from representatives
of distributors (response to Q57, Ms Doonan and Ms Bend) were
saying that in practice, rates lower than those recommended by
the manufacturer were often used and that there is a "misunderstanding
that pesticides are regularly used at the label rate". This
potential for reducing doses should be taken full advantage of—and
the necessary information should be freely available to all pesticide
users, not just customers of particular companies or members of
particular organisations.
3.5 There are a wide range of routes of
exposure to pesticides for the public and therefore, while not
originally a driver for the VI, it could now be extended to take
account of health as well as environmental impacts. A recent PAN
UK report[15]reviews
the issues relating to exposure of the public and a copy will
be provided for your information.
4. PAN UK RECOMMENDATIONS
4.1 A National Pesticide Strategy to provide
a complete framework for all pesticide-related issues, implemented
by a body that has a much wider remit than the current PSD, and
is effectively a "pest management directorate"
4.2 Some elements should be taken out of
the VI and made mandatory—this is the only way to reach
100% of spray operators—in particular sprayer testing and
spray operator training. These must apply to all non-domestic
pesticide users, not just those in agriculture. Steps should be
taken to ensure that these elements are not box-ticking exercises,
and that there is some independent assessment of quality.
4.3 We believe that voluntary action is
likely to be needed to implement the National Pesticide Strategy.
This could be achieved through a revised and extended VI, and
should include:
— A Pesticide Use Reduction programme.
— Monitoring of pesticide usage.
— Advice to farmers that is free and
independent.
— Targeted action on the most hazardous
pesticides and substitution of less hazardous ones.
— Specific action against those pesticides
causing particular problems, such as those regularly turning up
in water.
— Improvements in information to farmers
about how to minimise pesticide impacts.
— More R&D into non-chemical controls
and reduced pesticide usage.
— Monitoring of a wide range of environmental
impacts.
— Additional action to monitor and
reduce potential public exposure.
The costs of these measures could be met through
a Pesticide Tax.
PAN UK
March 2005
14 Design of a tax or charge scheme for pesticides
Ecotec report for DETR, March 1999. Back
15
Alison Craig, December 2004, People's Pesticide Exposures, PAN
UK. Back
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