Examination of Witnesses (Questions 199-219)
8 FEBRUARY 2005
MS HILARY
ALDRIDGE AND
DR ANDY
CROXFORD
Q199 Chairman: We are moving on now to
the Environment Agency. Thank you very much for attending. We
have Hilary Aldridge, who is the Head of Environmental Quality
and Dr Andy Croxford, who is the Pesticides Policy Manager. Welcome
to both of you. I have to tell you that we anticipate a vote at
four o'clock. We are having a debate on climate change so I do
not know why we are not all in agreement, but currently we may
not be and we may be obliged to vote, so we need to get ahead
as quickly as we can. I think I would like to quote you what may
be a slightly embarrassing quote, but it has been quoted to us
with some frequency, which says, "The Voluntary Initiative
on pesticides has been a wonderful success, says Environment Agency
Chief Executive, Barbara Young."[10]
"A wonderful success", but of course in your written
evidence you give us a lot of reasons why you think it is not
certainly a total success. But you say some good progress, et
cetera, et cetera. Just how successful has the Voluntary Initiative
been in your estimation?
Ms Aldridge: I think we may have
heard already some of the other views that have been put forward.
We would agree it has been a big success in terms of bringing
the industry, government, different stakeholders together, who
I think in our view certainly had quite polarised views about
how we try and tackle the pesticides problem, so I think from
that point of view it has been a good step forward. There has
been some success in meeting some of the targets set, although
admittedly some of those targets, we feel, have not been stringent
enough, and I think we may well come on to the issue around the
reduction in pesticides in rivers that we have been talking about
earlier on. So I think it has also done a great job in actually
raising the level of awareness, particularly amongst the farming
community. But where we would perhaps say that we still need to
do more work is actually raising the level of awareness with pesticide
users who are not farmers. There has been a lot of discussion
about arable farmers but of course there are amenity users, government,
Railtrack, big organisations like that who also use pesticides
and we should not lose sight of the work that we need to do with
them to ensure that they are complying with the same standards.
Q200 Chairman: It is important that you
raise those particular issues because we have very little evidence
on that and we have subsequently tried hard to get some new evidence,
of which we have a little. Do you have ideas about how it should
be extended? We know it has a very limited life ending in 2006.
How much more time does it need to prove that it can deliver real
environmental benefits and how do we get it into the amenity sector,
particularly, which, as you say, is really not being addressed?
Ms Aldridge: I think in terms
of the amenity sector there are some examples where work has been
done, where we have had separate arrangements, for example with
Railtrack, but those sort of arrangements are quite resource intensive
if you have to negotiate with the Railtracks of the world and
everybody else. I think in terms of how much more time we give
it; we need to take stock really of what the benefits have been.
Clearly the environmental benefits, but some of the benefit we
may not see for a long time in terms of bird population growth
and so on. Certainly we have been doing quite a lot of monitoring
and continue to do monitoring of the river environment to see
how the standards are declining or increasing, and I think our
view is that post-2006 the Voluntary Initiative, or elements of
it, need to sit alongside other elements so as, we have heard
already, it should be part of a package of measures so that we
can actually tackle problems using the appropriate solution. I
think potentially we argue with whether should we have a tax,
should it be a Voluntary Initiative, but there might be a range
of different things we could use depending on what the particular
target audience is, if you like.
Q201 Chairman: So not just going on after
2006?
Ms Aldridge: No.
Chairman: Thank you very much. I think
we can move on directly to the issue of water pollution. I think
your evidence was quite clear, however we have heard that Friends
of the Earth today would completely disagree with it. So we want
to explore that a little and Paddy Tipping will do that.
Q202 Paddy Tipping: What is happening
though? How far are pesticide levels down in rivers?
Ms Aldridge: I am going to hand
over to Dr Croxford to answer that.
Dr Croxford: We have done a lot
of work as part of the Voluntary Initiative in support of the
Voluntary Initiative to come up with a more robust indicator of
pesticide levels in water and that now shows that if we look at
the period between 1998 and 2002, which is in effect before the
Voluntary Initiative got properly into action, the levels of pesticides
in rivers are pretty much unchanged. However, in 2003, which was
the first effective year of the Voluntary Initiative, the levels
are 23% down compared with that previous period. We cannot say
that that is down to the Voluntary Initiative; as you heard earlier,
it could be down to the weather—we did have a particularly
dry autumn in 2003—and it could be down to a change in which
products are being used as well because we only have about nine
pesticides which are causing the vast bulk of the problem. So
if there has been a reduction in the use of those products we
would expect to see an environmental response as well. So there
are three possible reasons and we are not sure which at this stage,
unfortunately.
Q203 Paddy Tipping: When will you be
sure?
Dr Croxford: We are going to do
further work with the Crop Protection Association to correlate
our figures with their figures on sales and usage of these particular
problem pesticides, so we should be able to tackle that area.
The weather one is a much harder one to tackle and I think we
are only going to be able to tackle that one by looking at following
years' data to see whether we can still see a reduced level or
continuing downward level or whether the level comes back up,
which might indicate a response due to weather.
Q204 Paddy Tipping: So this is a bit
difficult because we have to make changes in 2006 and your fieldwork
is not going to be available.
Dr Croxford: In 2006 we will have
the 2005 data, so we will have two more years' data, so we will
have a three-year run of the effective years of the Voluntary
Initiative, 2003 through to 2005. So we will have more information.
Q205 Paddy Tipping: The part about the
target of 30% reduction, which I think you are on the record as
saying that we should not be complacent about, if the Voluntary
Initiative could produce a 30% reduction, is that sufficient?
Dr Croxford: We do not believe
it is sufficient, no. We think that the Voluntary Initiative should
be more ambitious than that. There are indications that of these
nine problem pesticides some are going to be banned, others have
had changes in their formulations, which should mean that even
in the business-as-usual state the levels of pesticides in water
would come down to a degree, and therefore a 30% target does not
look terribly ambitious to us. We have been discussing with the
signatories about what that target should be and it looks as though
we have now agreed a 50% target conditional on not having extreme
weather conditions in the next couple of years.
Q206 Mr Wiggin: 50% on which base year?
Dr Croxford: It will be a 50%
compared with the mean from 1998 to 2002.
Q207 Paddy Tipping: So not another 50%?
Dr Croxford: No, not another 50%.
Q208 Paddy Tipping: Can you just clear
up for us how much it is costing the water companies to get pesticides
out? Mark Avery told us £122 million; I have seen the figure
of £100 million; I am told there is a parliamentary question
that says it is only £1 million. What is the real cost?
Dr Croxford: The £120 million
is the sort of figure that we have quoted previously, it is the
sort of information we have been provided by Water UK and Ofwat,
and that is our current understanding of the cost. However, I
was interested to see that PQ response as well and it may be that
we need to go back to Water UK and check with them precisely what
the figure is.
Q209 Paddy Tipping: So we are making
decisions on science that we do not have yet about costs that
we are not certain about. It is not a good base for policy making!
Ms Aldridge: I think some of the
water industry costs, as Andy said, we are working on the figures
provided by Water UK and Ofwat. Some of the lower figures that
have been quoted I think were just for capital costs and we need
to take account of both capital and obviously the operating costs
as well. So I think there are different figures that have also
been quoted for slightly different purposes. But you are right;
we do need to have a clear evidence base before we actually make
some policy decisions on this.
Q210 Paddy Tipping: Perish the thought
to think it might be in the interests of water companies to argue
that costs are higher than they are when you review water prices!
Ms Aldridge: I am sure they would
not.
Paddy Tipping: No, I am sure they would
not! Thank you.
Chairman: David Drew is going to ask
about the pesticides tax and the Environment Agency's approach.
Q211 Mr Drew: You have both been in on
both previous sessions so I do not think we need to labour the
pre-emption of the debate that has taken place before. I just
think it would be quite interesting, without putting you on the
spot of interfering with the legislatures, let alone the role
of government, to know what work you have done as an Agency on
the possible implications of the introduction of a pesticides
tax. Is this something you have looked into, seeing if it makes
any difference in terms of water run-off?
Dr Croxford: Yes, I cast my mind
back many years to when the pesticides tax was first looked into.
We considered a situation where there was a proposal for a 30%
tax on pesticides which we were told would lead to a 20% reduction
in pesticide usage and we were then able to model that data to
see what it would mean in terms of levels of pesticides in water
and that then corresponded to a 30% drop in pesticide levels in
water, so that was the proposal prior to the Voluntary Initiative
that the pesticides tax could deliver a 30% reduction in pesticide
levels in rivers and that was part of the reason why the target
was originally set at 30% for this Voluntary Initiative.
Q212 Mr Drew: Did that include looking
at what we were talking about in the previous two sessions, the
idea of a banded taxation? In other words, a degree of more sophistication
of what particular pesticides you would want to reduce more quickly
than others, or was it just a straight tax?
Dr Croxford: I think it was just
a straight tax at the time. There was work done at the time looking
into a banded tax, which ran into some difficulties that you have
already heard about this afternoon. It may be worth mentioning
that we have not been specifically looking at doing a banded tax,
but we have been putting in place a piece of work to try to identify
which chemicals we should be most concerned about in the environment,
not just pesticides but across the board chemicals—can we
use a standard set of criteria to identify which chemicals are
of most concern? We have had an initial go at that and the RSPB
has been interested in this, so they have then done further work
to see whether we could apply our system to a system for banding
pesticides for pesticide tax purposes. As they said earlier, it
is feasible but complicated.
Q213 Mr Drew: What sort of engagement
do you have with the Pesticide Safety Directorate? Are you represented
on the PSD? Just remind me.
Dr Croxford: We are represented
on the Advisory Committee on Pesticides as an advisor, so we are
therefore able to raise concerns about the potential environmental
impacts of products that are coming forward for approval or review.
We also sit on the Pesticides Forum, which is the stakeholder
body that advises government on pesticides policy, which the Secretariat
is the Pesticides Safety Directorate.
Q214 Mr Drew: So you do not actually
sit on the PSD?
Dr Croxford: No, the PSD are their
own executive agency of Defra and we are a separate agency of
course.
Q215 Mr Drew: I accept that. They have
their own executive committee, which are eminent scientists that
are presumably the people who understand more about the science
of this than anyone else. Is that by your choice that you do not
have a particular representative role there? It seems to me that
there is a huge overlap with the sort of work that you are doing
with the sort of way you could direct that into the PSD.
Dr Croxford: As I say, we have
this role on the Advisory Committee on Pesticides but we are not
considered to be independent enough to actually be a member of
the Advisory Committee on Pesticides, actually making recommendations
to Ministers on the approvals of products. We can provide advice
but we are not actually a member of the Committee.
Q216 Mr Drew: Part of the problem when
I talk to farmers about this, and they get the manual out about
what pesticides do for what particular uses they want to put them
to, is this is incredibly complex stuff and it is also about huge
commercial interests. To get some of these new pesticides to replace
things like Lindane, which we all of a sudden discovered was pretty
awful stuff and got rid of, this is the front end of science in
more ways than one. Do you feel that you have the resources to
really be able to combat some of the malpractice that has happened
in the past and some of the problems that there clearly are with
needing to replace—notwithstanding what people's views are
of total removal—some of the current generation of pesticides?
And how would you go about doing this if we are not looking at
pesticides tax and so on?
Dr Croxford: One thing that is
being discussed is the idea of comparative risk assessment, the
substitution principle, so that we can look at particular type
of pesticide use, say controlling caterpillars on apples, and
we have a whole range of pesticides available to do that, all
of which may be approved and may have cleared the regulatory hurdle,
but some of them have sailed over and others have rattled the
bar on the way through, but they are all approved. We can then
sit down and look at those side by side and identify which ones
pose the lowest risk to the environment and only approve those
and not approve the ones which are posing the higher risk, and
substitute the higher risk products with the lower risk products.
So that might be one approach, certainly one we would support.
Q217 Mr Drew: Just to go back to the
point I was trying to tease out. Is that something that at a high
level the Environment Agency might be discussing with the PSD,
notwithstanding your membership of the Forum and the Advisory
Committee? To me, if we are going to crack this as a problem this
needs pretty high-level dialogue.
Dr Croxford: Yes, and we are discussing
with the PSD a whole number of potential options, of which that
is one. So there are concerns about bringing everybody up to a
basic standard of performance, so that we do not have a few good
performers and lots of poor performers—we want everybody
to get the same level of performance. We want to target some areas
of concern, such as the water contamination issue. You have heard
concerns about birds and products which has a very broad spectrum
that kills all insects as opposed to some that will only kill
the pest species. Then there are other issues to do with which
products are approved.
Q218 Chairman: If I can just ask a question
of my own in relation to what is being said to Mr Drew's questions?
To what extent has the thinking of the Environment Agency been
informed by practice in continental Europe where there has been
a range of taxes, a range of incentive schemes, a range of bandings
and all sorts of things? To what extent have you studied that
and the thinking that you are trying to take forward in consultation
with the PSD?
Dr Croxford: We have looked at
those very systems. I have been to conferences to discuss those
various systems. As usual there is a mixture of political, social,
economic and environmental drivers in each country and no Member
State is the same. So we can learn from what other people have
done and the approach they have used. We continue to support the
idea of looking across the board at the range of opportunities
we have, both fiscal, voluntary, regulatory measures, the use
of cross-compliance or the Entry Level Scheme and how we can put
together what is really quite a complex range of potential options
and how we can use those to address problems to get the right
balance, mix of policy instruments. That is not necessarily going
to reflect what is happening in any other particular Member State
but we can learn from what other Member States have done.
Q219 Chairman: My problem, as somebody
chairing this Sub-Committee, is that I am beginning to feel that
everyone is describing processes to us—endless processes,
processes, processes, and no solutions. We are trying to make
some assessment of where this Voluntary Initiative is and what
might be the way forward. I have to say we are not getting that;
we are getting a description of things that could be done and
could be considered but far less definitive suggestions in terms
of the way forward than I would have hoped. I do not know if you
want to add anything to what you have just said?
Ms Aldridge: You are right; we
have described lots of processes to you and different baskets
of measures and all that sort of jargon stuff really, when what
we are trying to do is to improve the environmental outcomes.
We do not want pesticides going into the rivers; we want to reduce
the amount of pesticides. We have the Water Framework Directive
coming up on the rails which is going to set good ecological standard
which we are going to have to meet, but we do not quite know what
that standard is going to look like yet. But there are some real
environmental drivers that we are going to have to ensure that
we can use these various tools and techniques to hit, and I think
the Environment Agency's viewpoint is that we do not want to lose
parts of the Voluntary Initiative because they are making progress,
it has raised awareness, there is work going on in terms of take-up
for the various targets. But I think we are saying that we need
to harden up on some of those things. So, for example, the testing
and the operators, perhaps they should have an MOT every year
in the sense that a car driver has? Let us make it statutory so
that they have to go through the process of making sure that they
know what they are doing with their equipment and they have up
to date current practices. Something that the Environment Agency
was very keen to do was to use catchment officers so that when
you are looking at whole catchment systems hopefully this year
we are going to put in some catchment advisors who can work with
farmers and other people within a catchment system to advise them
not just on pesticides but the whole raft of different activities
and initiatives that people need to take to achieve again the
better environmental outcomes we are after. But it is a tricky
area and we come back again to the lack of the overall strategic
direction. We desperately need that national strategy so that
we can plug the various bits into place.
10 Please see Supplementary memorandum on Ev 82 Back
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