Memorandum submitted by Friends of the
Earth (Z17)
1. EXECUTIVE
SUMMARY
1.1 Friends of the Earth is very concerned
that the Government's reliance on the industry-led Voluntary Initiative
(VI) has delayed progress on reducing the use and the impacts
of pesticides in the UK. The delay in tackling pesticide use has
significant implications for biodiversity as well as the health
of consumers, pesticide operators and people living near farmland.
By delaying action the Government also risks failing to meet its
own objectives on pesticides. Government policy is to minimise
the impacts of pesticides on the environment and to minimise the
presence of pesticide residues in food. In addition the Government
now has specific obligations to meet on improving water quality
to meet the requirements of the Water Framework Directive.
1.2 Friends of the Earth and Pesticide Action
Network UK (PAN-UK) have raised concerns about the effectiveness
of the VI for the past two years. 1, 2 These have not been addressed.
Additionally we do not consider that the VI has addressed the
concerns raised by the Environmental Audit Committee in their
2003 report.3
1.3 Our concerns about the VI include:
— There is no attempt to reduce overall
pesticide use, or substitute pesticides with safer alternatives.
— Some targets have been weakened to
make them easier to meet; some projects have only met their targets
by using compulsion.
— Some targets are very weak and some
do not measure real environmental outcomes.
— There has been a lack of progress
in delivering real environmental outcomes.
— The VI ran a misleading anti-tax
campaign.
— Where there has been success in reaching
farmers this has involved pilot cases with an intense use of resources
that would be difficult to replicate on a national scale without
significant new resources.
1.4 Evidence from other EU countries shows
that taxation as a tool within a package of pesticide reduction
measures can be effective and accepted by farmers. Friends of
the Earth considers that a package of measures, including economic
instruments, is required in the UK to discourage the use of pesticides
and raise money to support farmers in moving towards more sustainable
practices. The Government should make a commitment to the introduction
of a pesticides tax in Budget 2005 and consult on its design.
This should also form part of the Government's National Pesticides
Strategy. So far the development of the strategy has suffered
significant delays; it should now be brought forward as a priority
for Defra.
2. THE HARM
CAUSED BY
PESTICIDES
2.1 Pesticide residues are found in around
a quarter of food of UK origin4 but for some foods the incidence
of residues is much higher, for example residues in UK grown winter
lettuce. Some of the residues occurring in our food are known
to be a threat to human health, for example because they are suspected
carcinogens or hormone disrupters. Other pesticides pollute water,
including drinking water supplies. The removal of these residues
from drinking water costs around £125 million a year.5 Pesticides
also have a significant impact on biodiversity. In the case of
aquatic biodiversity these effects are direct, but pesticides
also have indirect effects on, for example, bird life where the
insects they feed on are eliminated.
3. CONCERNS ABOUT
THE VOLUNTARY
INITIATIVE
3.1 Friends of the Earth and PAN-UK have
raised concerns about the effectiveness of the Voluntary Initiative
since its inception. Both organisations sit on the steering group
of the VI and our assessment of the lack of progress of the VI
is therefore informed by involvement in that group. We have produced
two critiques of the VI, one in 2002 and another in 2003, and
we have seen little progress in 2004 to increase our confidence
in the measures. We do not think that the VI has addressed concerns
raised by the Environmental Audit Committee in 2003, including
shifting of targets and lack of progress towards real environmental
outcomes.
Our concerns include:
3.2 There is no attempt to reduce overall
pesticide use, or substitute riskier pesticides with safer alternatives
3.2.1 Friends of the Earth supports an approach
that reduces overall use of pesticides but targets the most harmful.
In its response to the Environmental Audit Committee in 2003 the
Government accepted that "in many cases a reduction in absolute
use will contribute to reducing impact".
3.2.2 Within the VI there has not even been
an agreement to reduce the inputs of single priority active ingredients
such as the herbicide isoproturon (IPU), one of the most common
contaminants of sources of drinking water. The most effective
way of ensuring that use reduction also results in reduction of
impacts is to take a hazard based approach to prioritise particular
pesticides where there is strongest evidence of harm to the environment,
risk to human health, or high clean up costs due to water pollution.
If this approach is not taken then the danger is that certain
high-use products such as sulphur will be targeted in order to
demonstrate an overall reduction in use, but adverse impacts may
not be reduced for some time. However, provided that there is
a targeted approach we do consider that aiming for overall reduction
will be more likely to result in the substitution of chemical
pesticides with non-chemical means of control wherever possible
rather than the substitution of one chemical pesticide with another.
3.3 Some targets have been weakened to make
them easier to meet; some projects have only met their targets
by using compulsion
3.3.1 In February 2001 the CPA put forward
a series of targets for the VI. "We have set clear targets
for each of our proposals. Together they form a substantial set
of goals, within the five-year period, that we are confident can
be achieved."6 Yet at the very first meeting of the steering
group7 it was agreed that the original project milestones needed
to be reviewed. Then in a paper to the steering group8 it was
suggested that "As the Voluntary Initiative has progressed
it is clear that some of the targets proposed in 2001 are unrealistic
or are no longer appropriate. The Steering Group needs to agree
new realistic and achievable targets"
3.3.2 For example, the target for the number
of members of the National Register of Sprayer Operators has changed
several times over the course of the VI. The current target for
17,000 members has now been exceeded but is significantly weaker
than the original target for all active sprayers to be members.
Part of the problem is that having set the target, the VI signatories
admitted they had no idea how many pesticide sprayers are active.
They have estimated that there are between 40,0009 and 60,500
spray operators, 10 so aiming to get just 17,000 signed up is
at best unambitious. In March 2004, in a paper to the Chair of
the VI, the RSPB, English Nature, the Environment Agency and PAN-UK
recommended that the original target be restored.
3.3.3 This is also an example of how the
target has been met by compulsion. The project reported a rapid
increase in application forms received once membership became
compulsory to meet Farm Assurance Scheme requirements11. Farmers
would find it very hard to sell their crops if they did not meet
Assurance Scheme requirements making compliance effectively compulsory.
3.4 Some targets are very weak and some do
not measure real environmental outcomes
3.4.1 For example, claims that the "VI
campaign is a success"12 because targets for Crop Protection
Management Plans have been exceeded need to be closely examined.
Although this target was raised after being explicitly criticised
by the Minister for being unambitious, the figure that has now
been reached (770,954 ha covered by plans) is still below 20%
of the total arable area. More fundamentally, the target only
records the area being covered by a plan; it makes no distinction
between farmers scoring a "poor" rating and those achieving
"good practice". In fact a farmer ticking all the "poor"
boxes would count towards the target. It is therefore impossible
to evaluate the effectiveness of this measure in reducing the
environmental impacts of pesticides. Friends of the Earth, RSPB,
English Nature, the Environment Agency and PAN-UK have all raised
this issue with the VI but there is still no measurement of changes
in practice.
3.4.2 Targets set for reducing water pollution
are also weak. The VI has set a national target of reducing the
frequency of detection of individual and total pesticides above
EU drinking water maximum concentrations by 30% by 2006. Analysis
by the Environment Agency has shown that revocations of particular
pesticides and changes in pesticide formulations, which will happen
over the time of the VI, will result in a significant contribution
to meeting the target without any action from the VI. A more meaningful
target would be for pesticide contamination of all surface waters
to be below 0.1 g/l, which would allow water companies to reduce
or abandon the costly treatment of raw water.
3.4.3 The ecological impacts of herbicide
pollution are not addressed by the VI. Herbicides have direct
impacts on aquatic biodiversity and indirect effects on terrestrial
biodiversity as they remove sources of food for birds and butterflies.
3.5 There has been a lack of progress in delivering
real environmental outcomes
3.5.1 For example, although reductions in
water pollution incidents are being claimed it is not clear whether
these are due to the action of the VI projects or simply down
to the weather, eg prolonged wet weather preventing spraying.
Even where improvements have been noted the VI water project admits
that a one-off severe rainfall event can still lead to pollution
problems, 13 suggesting that the action is not enough to prevent
water pollution incidents.
3.5.2 The VI catchment project has placed
a good deal of emphasis on changing farmer behaviour and practices
as a way to reduce the pollution of surface water. The VI claims
that 40-60% of herbicide pollution can come from mixing, filling
and cleaning operations being carried out on paved surfaces which
drain into water courses. However, these claims and the resulting
recommendations for changes in practice are based on one pilot
project in the upper Cherwell catchment, near Banbury, in 1998-2000
which only examined IPU pollution. Friends of the Earth's analysis
of the pilot study14 found that the amount of pollution from mixing,
filling and cleaning practices was very small compared to the
amounts leaching from fields after spraying if significant rainfall
occurred.
3.5.3 The VI catchment projects cover five
surface water abstraction catchments in England and Scotland,
and one groundwater catchment in England. Part of the VI's catchment
advice package is a decision tree to help farmers decide when
to spray. For IPU this advice includes that field drains should
not run for 14 days after spraying. The VI has also produced laminated
"cab cards" which tell farmers not to spray if rain
is forecast in the next three days. Friends of the Earth's analysis
of the winter rainfall in the four English surface water catchments
from 2000 to 2004 shows that dry spells leading to periods when
there would be no drain flow are rare events. Dry spells ranged
in length from 1 day to 19 days. On average 86% of dry spells
were three days or less in duration over four winters. In one
catchment 92% of dry spells lasted 3 days or less. In fact, long
wet spells are more common in winter. It is therefore very difficult
for farmers to follow the advice of the VI. The advice is also
unrealistic because if faced with an urgent weed problem, farmers
are likely to get on with spraying even if rain is forecast. Climate
change is forecast to make winters wetter which is likely to make
the problems worse.
3.5.4 Although success has been claimed,
results from the five surface water catchments do not show any
demonstrable impact from the VI measures to date. For example
in the Leam catchment, VI claims15 that "IT'S WORKING"
in respect of IPU levels in the water courses are premature because
in the year in question (winter 2002-03) very little IPU was used
because of very wet weather preventing spray operations taking
place.
3.5.5 The pesticide data so far available
to Friends of the Earth is patchy for most herbicides and catchments.
Good and bad years for pollution cannot be linked to the VI measures
because in earlier years comparable results are reported. The
data is presented in summary form so it is difficult to judge
how reliable the figures are in characterising how much herbicide
actually got into river systems each year. The VI will need to
present far more data on pesticide levels and loads in relation
to the prevailing weather, different soil types and locations
and cropping patterns to provide evidence that the voluntary approach
is a success.
3.5.6 Based on the evidence we have seen,
we believe that the VI approach will not be adequate and that
the only solution for some highly mobile herbicides will be a
ban on use with proactive help for farmers in finding alternative
means of weed control.
3.6 The VI ran a misleading anti-tax campaign
3.6.1 Last summer the Crop Protection Association
produced anti-tax campaign materials to promote the VI stating
that the tax would cost farmers £125 million a year. This
is repeated in the newsletter distributed to farmers in the water
catchment projects16, which state that a tax would "wipe
£125 million a year off UK farming's bottom line". But
the tax could raise £130 million a year which could, and
should, be recycled back into farming. The VI has not carried
out any comparative assessment of the costs to farmers of a well
designed tax compared to the costs of implementing the VI. For
example, under the VI a farmer may need to employ an agronomist
to help with a Crop Protection Management Plan, whereas if a tax
was paying for an advisory service such advice could be free to
farmers. Evidence from Denmark shows that a pesticide tax combined
with other measures can even save farmers money as they reduce
inputs.
3.7 Where there has been success in reaching
farmers this has involved pilot cases with an intense use of resources
that would be difficult to replicate on a national scale without
significant new resources
3.7.1 Although information is now made available
about overall costs there is still a lack of transparency about
the detailed costs of different projects, and we are concerned
that future costs to farmers may be underestimated. For example
the cost per farmer of the water catchment projects have not been
provided by the VI. However, the financial data available to date
suggests that costs of rolling out such programmes nationally
will run into millions. The Government needs to be assured that
the industry will fund such projects rather than loading costs
onto farmers.
3.8 Learning from other EU countries
3.8.1 Research for Friends of the Earth
into pesticide reduction programmes in Denmark, Norway and Sweden
shows that taxation as a tool within a package of pesticide reduction
measures can be effective. The research gathered information from
officials in these countries. Each of these Scandinavian countries
are well ahead of the UK in tackling the use and impacts of pesticides,
having had reduction programmes in place since the 1980s. Initially
these were aimed simply at reducing the amount of pesticides used,
but have since been refined to tackle the impacts of pesticides.
For example, Sweden estimates risk to human health was reduced
by 77% between 1997 and 2001, and environmental risk by 63% over
the same period. Norwegian risk indicators show a reduction of
33% and 37% for health and environment respectively during 1998-2002.
In Denmark the frequency of pesticide use has been successfully
reduced by 21% from 2001-2003 and the tax has been estimated to
have cut pesticide use by 5%.
3.8.2 There is considerable variation in
the approaches to pesticide taxation in these three countries,
with Norway the only country to have a banded tax system. However,
there is a high degree of agreement about the clear factors for
success of the wider pesticide reduction programmes. The three
factors identified by the three countries as being of highest
importance were:
— High level awareness among Ministries
on the need for use/risk reduction.
— Extensive advisory service to reach
farmers.
— Strict pesticide registration criteria.
3.8.3 The funding, via a pesticide tax,
of an independent advisory service for farmers is one of the measures
that Friends of the Earth is recommending for the UK. In the UK
advice is often taken from pesticide company agronomists whose
incentive is to sell pesticide products, not to reduce pesticide
use. By contrast, the Danish Agricultural Advisory Service assists
farmers in developing pesticide reduction plans at farm level.
And in Sweden advisory services include forecasting and warning
services and advice on how to reduce dosage rate.
3.8.4 There are differing views about the
cost impact to farmers. In Norway farmers say costs have increased.
In contrast research in Denmark has shown that farmers' costs
will be reduced if application frequency is reduced further, with
an overall saving of 13 euros per hectare. The return of revenues
raised to farming has helped with farmer acceptance of the schemes
in each country. In Denmark 75% of tax revenue goes back to farmers
through lower land taxes and the rest is used in pesticide use
reduction programmes and to fund research into pesticide effects.
In Sweden the reduction programme has the full support of the
Swedish Farmers Federation to which 80% of farmers are affiliated.
The potential for farmers to save money by reducing inputs, and
the revenue raising benefits of a tax have not been communicated
to UK farmers. Instead the VI has run an anti-tax campaign which
has sought to convince farmers that avoiding a tax will save them
money.
3.9 An effective package of measures
3.9.1 Friends of the Earth is calling for
a package of measures to reduce the use and impact of pesticides:
— Targets for reduction in the use
of pesticides.
— The phasing out/banning of priority
pesticides including those which are known to pose a risk to human
health, those which cause the most frequent pollution incidents
and those which are most damaging to biodiversity.
— A banded tax scheme for remaining
pesticides where the banding would take into account a range of
hazard triggers including toxicity, persistence, endocrine disrupting
effects and indirect effects on wildlife.
— Use the income from this tax to fund
a Government advisory body which will encourage sustainable farming
practices and promote viable alternatives to nutrient/pesticide
intensive farming.
— End the industry led Voluntary Initiative,
but apply any knowledge gained regarding best practice from the
VI via the new body and incorporate some measures into legislation
eg sprayer testing.
3.9.2 The Government should announce a decision
to go ahead with the pesticide tax in Budget 2005 so that it can
be included as a key measure in the forthcoming National Pesticides
Strategy.
3.9.3 Preparation would clearly be needed
to ensure that the design of the tax banding is robust enough
to avoid any perverse effects from increased use of pesticides
in the lower band. However, a significant amount of work in classifying
pesticides has already been done by the Environment Agency and
by the Co-op retailer. Lessons can also be learned from Norway's
banded tax. Some older pesticides may be so cheap that a banded
tax would not provide sufficient encouragement to farmers to stop
using that product, in which case a ban may have to be considered,
eg for IPU which is a common water pollutant. Perverse effects
will also be avoided by ensuring that the tax is part of a strategic
approach to reducing the use and impacts of pesticides.
3.9.4 A tax could raise approximately £130
million a year. Money raised should be used to:
— Fund the research and development
of non-chemical alternatives to pesticides.
— Fund an independent advisory service
to help farmers convert to more sustainable farming systems.
— Provide capital grants for farmers
to invest in non-chemical pest and disease control measures.
Friends of the Earth can provide the Committee
with more details about the above concerns including our research
on pesticide reduction in other countries and our analysis of
water catchment projects
REFERENCES
1. Friends of the Earth and Pesticides Action
Network UK, 2002. Why the voluntary initiative will not deliver
on government objectives, submission to the Environmental Audit
Committee.
2. Friends of the Earth and Pesticides Action
Network UK, 2003. Submission to the Environmental Audit Committee
on the Pesticides Voluntary Initiative.
3. House of Commons Environment Audit Committee,
2002. Pesticides: the Voluntary Initiative.
4. Pesticide Residues Committee, 2004. Annual
Report of the Pesticide Residues Committee 2003.
5. Environment Agency 2002. Agriculture
and Natural Resource Problems; Benefits, Costs and Potential Solutions.
6. CPA, 2001. Minimising the environmental
impacts of crop protection chemicals. Revised proposals—February
2001.
7. Minutes of the Pesticides Voluntary Package
Steering Group, 21 September 2001.
8. Paper to Voluntary Initiative Steering
Group, 2002. Indicators and Targets for the Voluntary Initiative,
Paper 02/0062, 4/9/02.
9. Minutes of the Voluntary Initiative Steering
Group, 26 November 2001.
10. CSL, 2001. A survey of current farm sprayer
practices in the United Kingdom.
11. Paper to Voluntary Initiative Steering Group,
2 December 2003. National Register of Sprayer Operators. Paper
03/0116.
12. Abel, Charles, 2004. "VI Campaign
is a Success" Farmers Weekly, 2-8 April 2004.
13. The Voluntary Initiative Steering Group,
2004, Minutes of meeting held on 6 September 2004, item 8.
14. Friends of the Earth, 2003. The Voluntary
Initiative and Water Pollution, briefing.
15. Voluntary Initiative, 2004. Leam Catchment
newsletter, "It's working!"
16. Voluntary Initiative, 2003. Ugie Catchment
newsletter, "Why worry about Water?"
8 October 2004
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