Memorandum submitted by the Royal Society
for the Protection of Birds (RSPB) (Z05)
EXECUTIVE SUMMARY
1. The RSPB seeks a reduction in the impacts
of pesticides because of the long-term risks they pose to birds,
other wildlife and the places where they live.
The RSPB recommends:
— development of a comprehensive National
Pesticide Strategy, which should include a package of measures
to reduce the impacts of pesticides. This should consist of regulatory,
fiscal, agri-environment, voluntary and other approaches. The
Strategy should be introduced at the earliest possible opportunity.
The Voluntary Initiative (VI) should be seen within this context.
— strengthening of VI targets designed
to determine whether it successfully minimises the environmental
impact of pesticides. The VI has helped raise awareness of the
impacts of pesticides on the environment, however the targets
it has set are not challenging enough.
— introduction of a carefully designed
banded pesticides tax if the VI fails to produce genuine environmental
improvements.
INTRODUCTION
2. The Royal Society for the Protection
of Birds (RSPB) is represented on the steering group of the Voluntary
Initiative and Pesticides Forum, has practical experience of pesticide
use on our landholdings (c110, 000ha) and undertakes research
into the effects of pesticides on wild birds and their habitats.
The RSPB recognises that issues such as human health are also
important considerations in the development and implementation
of pesticide policy although, clearly this is best addressed by
others whose expertise is within this field. The RSPB seeks to
reduce the impacts of pesticides on bird populations, other wildlife
and the wider environment.
ENVIRONMENTAL IMPACT
OF PESTICIDES
3. The RSPB's major concern regarding pesticides
and the environment focuses on the disruption of the ecological
food chain in terrestrial and aquatic environments. This is the
so-called food-chain effect of pesticides. Pesticides are designed
to kill invertebrates, plants or fungi in the crop. Many are very
efficient at this and the result is that there are fewer non-crop
plants to produce seeds or on which insects can live (both of
which birds eat). Growing scientific evidence implicates pesticides
(herbicides and insecticides) in the declines of many farmland
birds.[3]
4. The deliberate and illegal use of pesticides
to poison wildlife continues in some parts of the countryside—threatening
wildlife, pets and people alike. This is despite a long running
Government campaign to "stop illegal poisoning". The
RSPB believes that this issue should be addressed within the National
Pesticide Strategy and that new legislation should be implemented
to strengthen controls on the possession of pesticides as has
occurred in Scotland, with the Nature Conservation (Scotland)
Act 2004. We believe the powers available to the statutory enforcement
agencies to deal with such incidents should be extended in particular
with reference to interviewing the employers of those charged
with offences. The range of penalties available to the courts
on conviction, for pesticide offences, should also be broadened.
NATIONAL PESTICIDES
STRATEGY
5. The RSPB believes there is a need for
and has recommended the introduction of a comprehensive National
Pesticide Strategy (NPS). This Strategy should provide the framework
for minimising pesticide impacts. It should integrate the Voluntary
Initiative (VI) with other pesticide control and mitigation measures,
including a pesticide tax.
6. The RSPB is disappointed that the draft
NPS has been in development for over a year by the Pesticides
Safety Directorate without yet being released for consultation.
An opportunity was recently lost to combine pesticide issues with
the consultation on Catchment-Sensitive Farming (CSF). In order
to ensure the sustainability of CSF, Government policies should
integrate pesticide, nutrient, silt and veterinary medicine management
in a coordinated manner. The RSPB believes that pesticide impacts
can only be successfully reduced if integrated into the wider
policy context.
Strategy contents
7. Any national strategy must include all
products, all uses, across all sectors as each will have a potential
impact on the range of issues within the scope of the Strategy
and thus influence the achievement of the Strategy's aim and objectives.
8. The RSPB believes that the Strategy should
address the direct and food-chain effects of both legal and illegal
use of pesticides embracing:
(i) the terrestrial environment (described
in paragraphs 3 and 4).
(ii) the aquatic environment (direct and
food-chain)—Pesticides can enter water courses from a number
of both point and diffuse sources; for example from sewage treatment
works and spray drift, respectively.
(iii) human health—The action of pesticides
on the endocrine system of vertebrates has caused concern for
human health[4]and
is potentially of importance for wildlife.
(iv) the economics of land-use businesses—Changes
in pesticides regimes will impact on farm and rural businesses[5]
9. To address these problems, the RSPB believes
the NPS should adopt a three-pronged approach, using financial,
regulatory and voluntary instruments to reduce pesticide impact.
The Voluntary Initiative should not aim to replicate the actions
required by the NPS. The NPS should aim to:
(i) establish a pesticide reduction strategy
that is closely integrated into existing Government policies.
(ii) establish a sustainability classification
system for all existing and newly developed pesticide products
on the basis of their direct and food-chain impacts on health
and the environment.
(iii) establish protocols for all impact
reduction mechanisms.
(iv) raise awareness amongst all pesticide
users of their sustainable use and best practice through the work
of the VI.
Mechanisms of delivery
10. The RSPB recommends the introduction
of a co-ordinated approach to the delivery of the NPS and that
it include three broad mechanisms:
(i) financial mechanisms to redress
the current financial imbalance existing between the use of target-specific
products and broad-spectrum ones. One potential method is a tax,
discussed later in this document. Agri-environment schemes are
an increasingly important set of options, which provide incentives
to encourage the reduction of pesticide impacts. Financial penalties
such as fines for breaching pesticide regulations and possible
extension of cross-compliance to include crop protection plans
could also be included.
(ii) voluntary mechanisms, such as
the VI, to positively engage with pesticide users and the Industry
on issues such as raising awareness and training in sustainable
pesticide use.
(iii) regulatory mechanisms, such
as the pesticide approval process and pesticide use regulation.
Such regulation would need to reflect the needs of the European
Pesticide Directive (91/141) and the Water Framework Directive
although we would like to see greater emphasis on addressing food-chain
and direct effects. Regulation would also be needed to cover potential
Pesticide Vulnerable Zones (PVZs) the need for which should be
assessed.
Measuring success
11. The RSPB recommends that the NPS uses
the indicators proposed by the Pesticide Forum to measure pesticide
impacts on the environment, and that it supports the identification,
development and use of new indicators to aid meaningful assessment
of NPS achievements. Food-chain effects of pesticides are currently
assessed via the population changes of grey partridge, yellowhammer
and corn bunting populations. There remains an urgent need for
an indicator to assess short-term effects on invertebrate and
plant populations.
Use reduction policy
12. The RSPB believes that the main focus
of the NPS should be on environmental impact reduction rather
than use reduction policy per se. Use reduction should be viewed
as a tool to reduce impact. Mechanisms for use reduction should
aim to ensure future pesticide applications are based on economic
thresholds of pests rather than prophylactic doses. This approach
will not only reduce both use and negative impact but will lead
to cost savings by avoiding excessive and wasteful pesticide use.
Research needs
13. We believe the Strategy should identify
gaps in our knowledge of pesticide management and impact, and
clarify how these research needs should be met.
14. In summary, we believe the NPS must
set meaningful, time-bound and quantifiable objectives which undergo
regular assessment to ensure significant reductions in the negative
impacts on health and the environment are achieved.
THE VOLUNTARY
INITIATIVE
The RSPB's Position
15. The RSPB has supported the Voluntary
Initiative (VI) since its inception. Our aim in actively working
with the VI is to support the content and implementation of the
package of measures that the VI has employed to achieve its goals.
However, should the VI fail to produce genuine environmental improvements
the RSPB would actively seek the introduction of a carefully designed,
banded tax on pesticides.
16. The RSPB believes that VI should have
a place within the NPS and thereby report to Government on progress
to achieving its aims as set out in the Strategy.
VI Successes
17. The VI has succeeded in uniting the
agrochemical industry to a common aim and developing a sense of
responsibility towards the use of pesticides. Awareness of this
need for responsibility has been raised amongst farmers, agronomists
and pesticide companies and has helped to raise standards in pesticide
use, albeit in a limited way. This has been achieved through good
and continued communication through the farming media. VI projects
have already delivered results. There has been good commitment
to many of the tasks that the signatories to the VI have set themselves
in the areas of training, research, communication and stewardship.
Concerns About the VI.
18. The VI's remit is to change standard
pesticide practice to improve the situation for wildlife and water.
It is important to recognise good practice where it is already
used, but it is more important to raise standards where they are
not.
19. In the 2003/04 reporting period the
VI surpassed its three major targets for Crop Protection Management
Plans (CPMPs), National Register of Sprayer Operators (NRoSO),
and National Sprayer Testing Scheme (NSTS). The RSPB welcomed
these results but is concerned that the targets that the VI has
set for itself are relatively unambitious. The RSPB shares the
Government view that the VI would be more convincing if it was
able to meet more demanding targets. The Government's last budget
statement called for "challenging and rigorous" targets
that are "directly related to their environmental and biodiversity
impact",[6]requirements
which the RSPB believes the VI must address, if it is to satisfy
those who believe taxation provides a simpler and perhaps more
effective solution for society and wildlife.
20. One of the VI's current goals is to
have CPMPs across just 30% of arable area by 2006. Achieving this
target will mean the VI has only engaged with a minority of one
farming sector, many of whom are likely to have been at the forefront
of best practice already. The RSPB believes that the VI should
set itself the challenge of having 80% of arable land and 50%
of all other farmland under CPMPs.
21. CPMPs at present have little value other
than as a tool for farmers to assess their own pesticide regimes
and practice and to see positive progression year on year. The
RSPB has sought to persuade the signatories to the VI, through
our role on the VI steering group, that the valuable information
resulting from the completion of CPMPs be used to analyse progress
in the UK as a whole and between sectors. This is in order to
help target limited resources to where they are most needed in
the worst performing areas. The VI has now accepted the value
of this approach but valuable time has been lost given the lifetime
of the initiative.
22. Targets for sign up to NRoSO and the
number of sprayers tested under the NSTS have been downgraded
from original targets. The RSPB believes that these targets are
now not challenging enough and should be altered to cover 100%
of all operators and sprayers or sprayed land in order to give
confidence that crop protection is practiced by registered operators
using approved equipment.
23. The VI Indicator Farm project aims to
demonstrate the benefits of VI advocated practices on the environment
but lack of sufficient funding and subsequent delays in data collection
have set back the project. This situation should be redressed
with funding from the agrochemical industry and further time to
show results from this important project.
24. Removing pesticides from drinking water
costs well over £100 million every year—a cost that
is passed on to consumers. The VI's current approach to avoiding
pesticide contamination peaks in water, mainly involves text messaging
farmers once a week to advise on the suitability of weather conditions
for spraying. Whilst being innovative, it is risky as weather
patterns can be unpredictable, and one heavy rainfall incident
can cause severe environmental damage. Furthermore, scaling up
this approach would be very expensive, and there is no guarantee
that it would deliver protection to watercourses.
25. The VI should show leadership within
the industry and commitment by not settling for unambitious targets
or methods which will not address the scale of the problem. Although
changing the targets at this stage may mean that they will not
be reached within the 5-year timeframe of the initiative, adopting
targets that more clearly reflect need would show acknowledgement
of the scale of the problem and commitment to continue to deliver
real environmental results. Turning the VI's valuable awareness
raising role into actual environmental delivery would make a valuable
contribution to achievement of NPS objectives. With less than
two years remaining of the current VI programme, we consider that
the VI must be developed now to engage more farmers and demonstrate
the potential of the voluntary approach. By not doing so, they
risk isolating farmers who are undertaking best practice and failing
to meet the expectations of Government.
26. The VI should not aim to replicate the
actions required by the NPS but should be encompassed by the NPS
and instead take a lead on voluntary approaches within the Strategy.
ROLE AND
DESIGN OF
A PESTICIDES
TAX
27. The RSPB continues to believe there
is a role for a pesticides tax, with the twin objectives of modifying
behaviour through encouraging selection of less environmentally
damaging chemicals over more heavily taxed higher-risk chemicals,
and of raising revenue to pay for pesticide mitigation action
through hypothecation. We recognise that a badly designed tax
could fail to deliver environmental benefits whilst penalising
the farming community. The best design is likely to be a banded
tax, accompanied by a package of measures to promote better pesticide
management, funded through hypothecated revenues. A pesticide
tax designed in this way would secure pesticide impact reductions
and implement the polluter pays principle. The RSPB believes that
the objectives of a tax on pesticides should be to reduce the
negative external effects of pesticides rather than solely reduce
pesticide use.
Tax Implications
28. A banded tax is necessary to allow different
rates of tax to be applied to pesticides according to their negative
external impacts. Such a tax would create an incentive to switch
to less environmentally hazardous products. The level of tax needed
to affect behaviour change on a large scale (demand elasticity)
may be punitively high, and therefore the RSPB advocates a lower
rate of tax and a supporting package of measures designed to improve
pesticide management. This would have the effect of recycling
revenue to the farming community and benefiting those who are
providing good environmental stewardship. We recognise that those
pesticides with the greatest environmental impacts are not necessarily
those with the greatest danger to human health—and so the
design of a tax is not completely straight forward.
Including food-chain effects on wildlife in a
banded tax
29. In 2003, the RSPB commissioned a study
to examine the food-chain effects of pesticides on wildlife and
in particular examined how to incorporate these effects in a potential
tax design. The results, which addressed a small sample of around
50 pesticides, showed that including the food-chain effects on
wildlife in the ranking system increased the ranking of a significant
minority of pesticides. The RSPB compared the results of the analysis
with the provisional pesticides' scores in the Environment Agency's
draft chemical ranking system which ranks chemicals based on their
environmental hazards and exposure. The RSPB believes that such
a ranking system could provide a framework for placing pesticides
in tax bands according to their health and environmental impacts.
Including the food-chain effects of pesticides on wildlife is
important as the food-chain effects of pesticides are not closely
correlated to their overall hazard to humans.
Missing Data
30. Where toxicity data are missing (as
was found in the dataset for the RSPB study) tax design could
penalise missing data with a rate of tax that started relatively
low and with an announced tax escalator. Such a system would initially
not penalise the chemicals that lack data too harshly but would
provide an incentive to manufacturers to test their products for
risks to non-target species or otherwise be penalised. Where a
product is expected to fail, resources would not need to be used
in completing the test.
Further Work
31. The RSPB recognises that further development
on a pesticide tax would be needed before it could be introduced
by Government. This includes: assigning individual pesticides
within a banded structure, determining levels of tax within tax
bands and assessing the distributional effects of a pesticide
tax. The RSPB is continuing to contribute to the development of
these ideas.
CONCLUSION
32. The RSPB believes that the VI has demonstrated
value but should not be seen as the only method to deliver a reduction
in the impact of pesticides on the environment. The VI should
be seen within the context of a comprehensive National Pesticide
Strategy, which provides central leadership on pesticide issues
and integrates all the tools for reduce environmental impacts
of pesticides, including the VI, regulatory instruments, and financial
instruments including agri-environment schemes, green taxation
and cross-compliance.
7 October 2004
3 Campbell et al. 1997; Aebischer & Potts,
1998; Brickle et al. 2000 Back
4
Pesticide Action Network UK, 2001, The List of Lists: A catalogue
of lists of pesticides identifying those associated with particularly
harmful health or environmental impacts. Back
5
Morley Agricultural Consultants Ltd, (1998), An analysis of "Private
costs and benefits of pesticide minimisation". Back
6
HM Treasury, Budget 2004, para 7.70 Back
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