Select Committee on Environment, Food and Rural Affairs Minutes of Evidence


Examination of Witnesses (Questions 320-339)

24 FEBRUARY 2005

RT HON ALUN MICHAEL MP, DR SUE POPPLE, DR IAN DEWHURST AND MR PAUL O'SULLIVAN

  Q320 Chairman: After four years of experience. The evidence that we have taken does not convince us that there has been a great deal of achievement in terms of environmental aims. There has been quite a lot of achievement in terms of good practice of operators but in terms of environmental gains we have not seen the proof of that, so I am wondering why after four years it is still considered the best approach.

  Alun Michael: When you say that you have not had any evidence, the evidence from the Environment Agency is that the incidence of pesticides exceeding the EU Drinking Water Directive limits of detection of 0.1 g per litre has dropped by 23% over a five year period to 2003. What we have been looking for is, if you like, not just overarching indicators like that but better tools to demonstrate a positive link with changes in practice, whether it be in the farmyard or in spraying practice, or another issue which is the maintenance of spraying machinery, for instance. There is evidence of considerable progress. Certainly I would not say that it is perfect or where we want to be but, as I say, this is about changing behaviour, changing attitudes, changing professional practices, and that should see a continual improvement over time rather than a one-off improvement.

  Q321 Chairman: Minister, I need to respond to that because, again, we have taken evidence from the Environment Agency, we have taken evidence from a lot of sources, but what we are unable to be absolutely certain about is that these improvements, particularly in water pollution, are a direct result of the Voluntary Initiative. Even the Environment Agency, I think, says that there is uncertainty around that causal relationship.

  Alun Michael: I am not sure whether uncertainty is the right word. I think proof of a direct relationship is more challenging and that is why we have been trying to develop tools which will allow us to be much more precise. I acknowledge entirely the need for that to be developed but there are the six Voluntary Initiative river catchments and on all six of those pesticide reduction trends are promising. We are not complacent. As I said, the relationship between Defra and the Voluntary Initiative is one of challenging. What we want to do is to challenge the Initiative and, therefore, those who are actually undertaking the work on the ground in a way that pushes them as far as possible without being unrealistic or asking for changes which cannot be achieved within a reasonable timescale, but it has to be continual improvement both in terms of the challenge, the targets set, the improvement of the methodology that we use and then trying to take everything a step further again.

  Mr O'Sullivan: Really, I think the initial position about why a Voluntary Initiative rather than a pesticides tax, as put forward, is wholly consistent with Treasury thinking at the time and the position now. The reason why we did not pursue a pesticides tax at the time was initially the ECOTEC work and then the subsequent consultation work on the Voluntary Initiative suggesting that if you want to get reductions in water pollutions and the environmental outcomes you want it is far more important to tackle where pesticides are being used, when they are being used, how they are being used, how they are being handled in farmyards, those sorts of issues. If you had a straightforward tax you would have some impact on the overall level of pesticides used depending on how you price it but that would have none of the behavioural changes in terms of how pesticides were being applied that you were trying to achieve. So you would have a tax on farmers that might in many ways be interpreted as them doing their bit via a tax on pesticides but without those changes in behaviour you would not have any of the impacts coming through in terms of pollution and environmental impact. I think our view is given the Voluntary Initiative as put forward by the industry at the time, that was potentially a much better and more cost-effective way of changing behaviour without the administration and complexity required in setting up the tax. Whether it has been fully implemented and whether it has achieved any of those outcomes remains to be seen. I think the key test is the evaluation in 2006. Clearly as we and Defra have been discussing this with the industry and with the Steering Group we have been learning about this and we have been providing some of the targets and we have seen some good progress there. I think the key test will be in 2006 with the evaluation of the Voluntary Initiative as to how it has performed against the targets it has set itself and then how well those targets have translated into the reduction of pollution and environmental outcomes.

  Q322 Chairman: So wait until 2006 is your view?

  Mr O'Sullivan: I think having set in place a Voluntary Initiative it would be premature at this point in time to start concluding that the Initiative was not delivering, particularly given some of the good signs of success we have seen coming through and the ongoing engagement improvement in some of the indicators and some of the targets that have already been set under the Voluntary Initiative are currently being brought forward.

  Alun Michael: Can I just say that I do not think it is a question of waiting until then in the sense of the continual discussion and improvement. You will be aware of the work that we commissioned with Newcastle University, which I referred to a moment ago in terms of trying to develop tools. That has proved quite difficult and challenging. The work that has been undertaken is currently subject to peer review and will be published once we have it in a form in which we can be confident about what is being said. It demonstrates some difficulty in getting to exactly the point you referred to earlier of being able to demonstrate a direct relationship. One of the things that are worth bearing in mind is that 40% of water contamination is caused by run-off from farmyards. That is data that has been confirmed by the Crop Protection Association and Friends of the Earth. That means that it is not about the quantity of pesticide that is being used which would be addressed by a tax, but how it is being used, how containers are dealt with after material has been put into sprayers. Another issue is the efficiency and effectiveness of spraying machinery. I am not sure if this is a point that has been brought up, but it was rather a surprise to everyone concerned to find that actually very basic maintenance of spraying machinery makes quite a difference in terms of the unintended pollution. Those are very much about affecting the professionalism and the behaviour with which people undertake things. Finally, and this is an instinct of mine, Voluntary Initiative is the title but I would prefer to talk about it as the Initiative because in the sense of being voluntary, it does not mean it is optional. We need to emphasise with the industry that these are things that need to be done, not just things that are beneficial and it would be rather nice if they did them, they are essential. The pesticides tax remains there in the background as a possibility if the engagement of the industry does not achieve the outcome. I think there has been a shift in attitudes; certainly I have seen that in terms of discussions with the farming industry and leading figures in the NFU, for instance, over the past couple of years. We go back to your point can we demonstrate that it is sufficient and adequate, but the question still remains would a tax actually achieve more or would it possibly achieve less.

  Q323 Chairman: Perhaps you could tell us about the new tools that you hope to apply coming from the Newcastle study. When are you going to publish the findings of that report?

  Alun Michael: I think the point that arises out of this, and perhaps I will ask Sue and Ian to come in on these points, is that it has proved quite difficult. The Newcastle report came up with three tools: the use of focus groups; an ecological network model; and a socioeconomic study to link changes in farmer behaviour to environmental improvement. The idea is to go exactly to the point you were raising earlier, which is to assist in comparing benefits delivered by the Voluntary Initiative with those that might result from the introduction of a pesticides tax. It requires peer review and there is more work to be done before we can be satisfied that we have tools that would really work. We hope to be able to be more specific on that by publishing the report once that process is complete.

  Dr Popple: Following on from that, I think when we came to look at it we felt that perhaps just by assessing where they were with targets at the end of VI might not be sufficient in itself to be able to judge whether or not the VI had delivered environmental benefits over and above those a tax might deliver, which was why we commissioned the work at Newcastle to provide us with some new tools. They are not actually assessing the VI but they are looking at tools that we could use perhaps to assess it. I think it is perhaps fair to say that they found it quite a difficult challenge to take that forward and perhaps the tools might not be as useful as we would have liked. Certainly we are going to have the work peer reviewed and it will be put in the public domain so that people can see it. We felt that it would be helpful to us to try to have some additional measures to be able to see how the VI was doing.

  Q324 Chairman: But is it not going to be too late? By the time you have done all of this work and then published it, are we not going to be in 2006?

  Dr Popple: We need to be looking towards the end of this year to see how the VI is delivering across the board. It is quite challenging for them to be delivering environmental benefits within the short timeframe that has been given. This was to try to help to be able to pick out where they might be moving in the right direction.

  Alun Michael: I think also there is a series of questions to be asked in 2006. One is has the Initiative, as it is currently being developed, delivered adequately? Are the changes in farming practice, the professionalism with which substances are being handled, becoming embedded in standard practice rather than best practice? Are there other options in terms of driving that forward? The fact of the matter is that we are continually looking at wanting to diminish the use of chemicals that cause any harm to human health and the environment and to make sure that the materials used are better and safer and all the rest of it as well as looking at issues of run-off into pollution and so on. The thing that strikes me is that we come into a situation where the whole situation is diffuse, it is not like using a chemical in a paint shop where there are four walls and it is very tight. At the same time, if pesticides were not being used there would be a variety of crops in particular which could not be produced in the UK which can otherwise. The question is getting this balance to make sure that levels of impact are minimal and acceptable. It is not just about quantities or farm practices, there are other issues as well, that is what I am trying to say.

  Q325 Mr Wiggin: One of the things I have picked up from what you have said is that actually what you are concerned about is things like the 40% run-off and the way people handle things. I am just a bit surprised that perhaps you have not done more to support the Initiative because certainly from the evidence we heard before they did not feel that there was interaction between the Department and themselves. A good example is that they call it the Voluntary Initiative whereas you are very keen, and I agree with you, that it should be an Initiative and people should be getting on board. I just feel that perhaps there is something more that you could be doing.

  Alun Michael: So far as the name is concerned, as I think I said just before you came in, perhaps because I have got a background in the voluntary sector and volunteering I was a little uneasy to use this title but it is a title that was approved by ministers at the time when it was started and I do not think one can interfere with that now. 2006 is the time that we might look at the profile of the Initiative and the way that it develops. It is important that this is an approach developed from the industry side, owned by them and, in a sense, with our help, it is for them to prove that this is more effective than being taxed. As I also indicated in what I said right at the beginning in answer to the Chairman's first question, we have moved much more to a partnership approach. I do see people involved in the Initiative on a regular basis and make the point that the pressure for taxation or for more onerous burdens on the industry is bound to grow unless they, and we, can demonstrate that it is actually succeeding. I think people in the industry are now very well aware of that. It is support, encouragement, carrot and stick, if you like. I would be very surprised if there was any sense that the people involved in the Initiative did not think that we were both supportive and challenging to them.

  Q326 Mr Wiggin: I think that they accepted the challenging part but felt that it was challenging on a critical rather than a constructive basis and, therefore, they have upped their targets and they have sent us a list of what they want to do. What I was trying to do was to get back to the point that I think was made earlier about the behavioural side of it. It looks to me as though you are talking about a pesticides tax unless the industry improves, and while the standards or targets that the ministers keep challenging the industry to provide are being pushed forward we get this double message from you, if you like.

  Alun Michael: I am sorry, that is wrong. We are not actively considering a pesticides tax at the moment. We are discussing pesticides tax because it was there as an option in 1997 and because that is what the committee has asked us to address. It is not under active consideration. Of course, it will be one of the options that are considered in 2006 when we evaluate the story so far. I can see nothing that suggests to me that there should be a tax, which in many ways is a crude and blunt instrument which would be paid as much by those who were undertaking those professional activities which reduced the amount of substances that run-off from the farmyard, for instance, as it does those who fail to undertake such good practice. Just as we need better tools for measurement, which goes back to the Chairman's first question, we also need better tools for improving the behaviour. Yes, our approach is to challenge the Initiative, not to challenge it to breaking point by saying that we want them to increase their targets to the point that farmers will not be able to respond and produce because behavioural change requires engagement, but it does need to be challenging otherwise people would be asking the sort of questions that the Chairman was asking a few minutes ago, why do we not go further? I think between the two of you we maintain a reasonable and constructive and creative engagement.

  Q327 Chairman: Before we pass on, I know Paddy Tipping wants to come in on this issue, can I say that we did not get an answer to the question of when will the Newcastle study be published.

  Alun Michael: We are waiting for the outcome of the peer review. It will be within the next few months.

  Dr Popple: Yes, I think it will probably be towards the end of the year because peer reviewing itself is quite a timely process.

  Chairman: Thank you.

  Q328 Paddy Tipping: You mentioned Professor Dent and he came and talked with us. I got the impression in the early days the relationship between he, as Chairman of the Voluntary Initiative, and the Department was not good but now it is closer and he feels more consulted and included. Could you just comment on why that was the case and what has happened?

  Alun Michael: Obviously I cannot answer for the earlier period but I think I would be right in saying that initially there was a feeling that it was for those in the Initiative who have made a proposal to Government and brought together a partnership to convince Government that they could do it, so "It is for you, oh Voluntary Initiative Steering Group, to demonstrate that you can bring about the results that are wanted". I think over time we have become satisfied that the Steering Group genuinely wants to make progress and achieve the outcomes and to have testing objectives and to move towards them, therefore the relationship, while there is still some distance and it is a question of those challenging them, is one of saying "We are on a journey in which we all believe in the destination we want to reach". I think the engagement with officials is much greater now, is it not, Sue?

  Dr Popple: Yes, we have quite good relations with them and try to be helpful where we can. Clearly we cannot be helpful in all the areas but certainly where there is scope for it we do help.

  Q329 Paddy Tipping: Are you on the Steering Group?

  Dr Popple: I am an observer on the Steering Group.

  Q330 Paddy Tipping: So the Steering Group belongs to the industry but you go along and, in a sense, listen to what is being said and comment.

  Dr Popple: That is correct.

  Q331 Paddy Tipping: But this is a train that you are on board now, it is not one where you have got to justify what you are doing and were the judges, as it were; it is a joint enterprise.

  Alun Michael: The sort of point one makes in discussion is that the option of a pesticides tax, while not under active consideration, has not gone away. There are people, like the Select Committee, who will be asking questions about the outcomes being delivered. It is part of our engagement both to look at what we want to see coming out of it and to reflect the interests which you are now reflecting, so I am glad I made that point, by undertaking this investigation. That is very welcome. Can I just make the point as well that there are other issues that we have been trying to address. The Voluntary Initiative on Pesticides—I insist on using the full title—is not the only approach that we are adopting. We have had a consultation recently on the impact of spray on bystanders. We have taken decisions as a result of that outcome in terms of recording and so on. Also, I asked our Chief Scientific Adviser to look at the science that underpins the work of the Pesticides Safety Directive and asked the Royal Commission on Environmental Pollution whether they would consider undertaking some work in this field and they are currently undertaking that work. We are both actively engaged ourselves and encouraging objective scrutiny of what has happened because I think it is in everybody's best interests to have the best possible information and independent scrutiny of everything that happens.

  Q332 Paddy Tipping: I think that is helpful. One of the things that have happened is that the National Pesticides Strategy has just been published. Going back to Professor Dent and the Steering Group, again my impression was that they were not formally involved in the debate about the Pesticides Strategy. Were they or were they not? Surely they had something to contribute.

  Dr Popple: There was quite a lot of input from stakeholders in the early stages of us developing the strategy. Most of the people who are on the VI are actually represented on the Pesticides Forum and we use that as our main body because that has about 24 different stakeholders who are interested in pesticides on it, so we used that as our main body when we were sounding out about things to put into the strategy. In addition to that, I did meet the chairmen of all of our advisory committees, including Professor Dent, and went through our plans with them as well. There has been quite a bit of dialogue.

  Q333 Paddy Tipping: Finally, just sticking with Professor Dent, in his evidence to us he was saying that there still was a threat of a pesticide tax in the background, that the stick was still there. He did not think that was helpful because he did not feel that encouraged farmers to become involved. If the stick is going to beat people, why not wait for that date rather than join the Initiative now? What is your view on that comment?

  Alun Michael: I think it would be foolish of us to rule out that option. Obviously it is a Treasury issue at the end of the day but there is more than one way of undertaking tax, there can be different levels, as we have seen with encouraging behaviour on the uses of lead-free petrol and diesel and things like that. One cannot rule it out but it is not under active consideration. I think what I would say, and do say when I get the opportunity, is "Do you want something that will be an undiscriminating added burden or do you want to work with us to get practical outcomes which are actually good for you, for your farm practice and for the wider environment?" I was quite interested just recently talking to a lecturer at one of the agricultural colleges and asking to what extent he felt there was an engagement with these sorts of issues and what he said was he was finding that the present generation of students going through the college are much more practical in terms of looking at the impact of pesticides, looking at soil quality, looking at issues that may affect the farm in the long-term, and many of them are obviously from farming families and going back and testing this out on their own farms. It is much more engaged and practical in terms of their studies than perhaps he had seen in the past. I think that is quite encouraging as well.

  Chairman: I want to go back because I think Alan Simpson wants to ask in a little more detail about the success or not of the Voluntary Initiative.

  Q334 Alan Simpson: I would hope that in the discussions about the policy options we are not ignoring the fact that between the tax and the voluntary agreements there is also the option of statutory obligations. I would hope all of those options remain open. My concern was the opposite of Bill's really about the squeeze. I know you said you did not want to challenge to breaking point but I want to see how far we have got beyond waking point. In your own assessment, your own and the Treasury's assessment, of the "success" so far, you pointed out amongst the failings of the Voluntary Initiative that it was slow to come up with sufficiently robust targets, the target of 30% of arable land covered by Crop Protection Management Plans was not sufficient, the water quality target was not sufficiently robust and the targets proposed for biodiversity are too vague. When going through that it reminded me that as kids we used to have hurdle races but in order to make them fair the hurdles were so low that everyone could get over them and we all counted it as a success because no-one fell at any of the hurdles. Is that the danger that the Voluntary Initiative is going to fall into, that the industry will set itself targets that they cannot fail but outside there is not going to be much credibility from the environmental movement that says this has had the effect that really as a Government we are looking for?

  Alun Michael: I think you reflect the sort of dialogue that we have with the Initiative and with the industry more widely, which is unless the industry is working towards challenging targets and unless the Initiative is challenging the industry it is not going to be convincing to others and people are going to be making in a more confrontational way perhaps the points that you are hinting at. This is absolutely on the territory of our discussion with the industry. You are absolutely right to say that this is not a one stick approach and it is not just the Initiative that is the way of approaching things. Within the Initiative itself obviously we have got firstly the Crop Management Plans and the provision of guidance and advice on good agricultural practice, the identifying of environmental issues and looking for solutions at a farm level. Secondly, you have got the National Register of Sprayer Operators and there is a good deal of evidence that is leading to operator training and certification resulting in better practice. Thirdly, there is the one I referred to earlier, the National Sprayer Testing Scheme, and perhaps that has had more impact than we expected at the start in terms of demonstrating that the testing does actually bring about benefits. Then, of course, we have got the agri-environment schemes and we have got cross-compliance. We intend to use the new Entry Level Scheme to build on costs of the compliance standards so that, again, you are placing the requirements but also encouraging improvements. There are a number of measures which complement the work of the Initiative.

  Q335 Alan Simpson: I am trying to nudge those measures towards measurable outcomes. I just wonder whether your own views on this were, first of all, that it would be relatively easy to set a doubling of the target in respect of agricultural arable land covered by the Crop Protection Schemes. A 30% target is a pretty low hurdle. I am just wondering in terms of coverage, it is not difficult for us to set a higher target there. The measurement of this is more complicated but it is relatively easy to set a more robust target in terms of water contamination. In a way I would just like to know, not just the cross-compliance and other schemes, what robust measures you want to see put into the Voluntary Initiative that would make it more credible than it would appear to be now?

  Alun Michael: I think the first instance is the getting better tools that have a direct relationship with the improvements that we are looking for and a measurement of the outcome of changing activity, that is the Newcastle work and all of that. I think we will be in a better position to discuss that in more detail when we are able to publish the outcome of that research. Again, you are very much on the territory that, with the Steering Group, we are looking for them to go as far as possible in terms of increasing the standards, improving the targets in the way that you are suggesting over time. It is a matter of judgment as to how hard you push. I do not know whether you would like to say a little bit more from the experience of the Steering Group, Sue?

  Dr Popple: The targets particularly on Crop Protection Management Plans and also the targets on water were two of the ones that have been pushed on recently and on which Barry Dent has very recently come back to us with some changes. In terms of the Crop Protection Management Plans, the fact that those are going to be taken up within the Assurance Schemes is going to have a much wider impact. They will achieve a much bigger target than the one they have, so I think they could agree a bigger target on that with us. Certainly in terms of water, the Environment Agency has done some work looking at downward trends in water and feel it would be realistic for there to be a more stretching target there. Those are the two targets that the Minister went back to the VI on.

  Alun Michael: Can I just add one other area. In terms of volume, agricultural use is the big one but there is a significant quantity of plant protection products used for amenity use—landscape, sports, golf courses, car parks in out-of-town areas and so on—and very often the users in those contexts may not have the sort of training that is now becoming standard within the farming industry. We are intending to engage with local government and others. I have it as an item with the Rural Central-Local Partnership, for instance, in the near future to make sure that we do not overlook that even though it is a smaller part of the whole than agricultural use.

  Q336 Alan Simpson: I think everyone has recognised the value that there has been in terms of improved farm practices and that is to be welcomed. Baroness Young also clarified some of her points for us and said her enthusiasm about the success is that it is good to see people working together in ways that they have not for a long, long time but she did put the sting in the tail of her comments by saying that it is very difficult to see measurable environmental benefits that are coming out. Since ultimately that is the concern of the Committee, and I think of the Government, it is just nudging things up to accept the improvements in practices but say what the consequences for environmental quality and environmental impact are. Really that is what I want to know, how far you think you can push before you get anywhere close to breaking point.

  Alun Michael: I think it is one of those areas, as are so many when you are dealing with a complex situation, where you start off thinking we know what we want to achieve, let us just measure it and that is it, but then you discover that measurement is not that easy. We have the measurements which are made by the Environment Agency, which I referred to earlier, but relating those measurements where you can see an improvement over time to specific actions taken by specific farmers is a lot more difficult. We have got the six catchment area pieces of work that demonstrate some benefit but in a sense, as with so many things, you are using something as a proxy to demonstrate progress rather than something that is a practical test. That is precisely the reason why we commissioned the Newcastle research which has demonstrated, as both I and Sue have said, that it was not as simple as we hoped it would be to produce tools that are much tighter in terms of measurement. We would share entirely the aspiration that you are pointing towards to have something that is very, very stringent so that you can be very, very precise about whether people are doing what they should be doing or not, and we are certainly not at that point but we are working on it and we are looking to others to help us work on it. Perhaps as a non-scientist, as a politician, I could turn to our two scientists to perhaps supplement that from their experience.

  Dr Popple: I think the thing I would probably add to that is that one of the more interesting projects that are in the VI at the moment is the indicator farms. These are coming slightly late into the Initiative but they are there and those particular farms will be implementing all the measures within the VI and all the measures of good practice. They should enable some measures to be seen on a local basis of what those environmental benefits are that you have talked about. Once you start to look on a global basis it is actually quite difficult to be able to sort out what is happening and what might have been caused by the VI and what might have been caused by something else, by other changes. I think that is quite an encouraging development. The downside is that they are going to take a little bit of time before they start to deliver those benefits and they can be seen. I think that they are in place and they have a baseline and, therefore, you can see the changes that will be put in place.

  Alun Michael: I have talked mainly about the practices but substitution is an issue as well and that is very much a central part of our strategy, to encourage the development and use of alternative products. One of the things that were a priority of the Initiative, for instance, was the issue of the use of IPU—Isoproturon—which is a particularly mobile chemical that has caused problems. One of the things that was identified was that there tend to be peaks, application followed by rainfall and, therefore, issues picked up by the Environment Agency as a result. That is the sort of area where there has been a measurable improvement, the Environment Agency tells us, in the figures that they were coming back with in 2003. We have to look for continuous improvement in that sort of thing. Looking for alternative products is not an immediate quick-fix but for the long-term it has to be very much part of the strategy.

  Q337 Chairman: I have to say, on that issue Friends of the Earth suggested to us that the reductions were actually due to the weather conditions. We have received conflicting evidence on the question of Isoproturon.

  Alun Michael: Which proves the difficulty of being absolutely, totally certain. There again, comparing year on year when we have the 2004 figures and so on, that may help us to draw further conclusions over a period of time. Certainly the fact that monitoring is going on is obviously a good thing.

  Q338 Chairman: Except for our variable weather patterns, of course.

  Alun Michael: If you are asking Defra to change the weather patterns, I am not sure that we can achieve that in the sort of timescale you would want.

  Q339 Chairman: Before I bring Alan Simpson back in on a new issue, I just want to clarify we may have recorded that you have said that a pesticides tax "is not under active consideration". I think that may be what has been said in the evidence this afternoon but I see that it is actually one of the things within the list of options in the draft Pesticides Strategy which obviously is inviting people to have a discussion about what types of measures should be applied. Just for clarity, how should we interpret "not under active consideration"?

  Alun Michael: We are not currently considering introducing a pesticides tax. It would be very odd, especially given that it is an option that was discussed when the Voluntary Initiative was put forward—it was the alternative at that time—not to include it as one of the options that is available to Government. We have not ruled it out forever and a day but I think it is important to say that it is not under active consideration because at the present time we think that the results we are getting out of the current Initiative are more demonstrably successful than we think the blunt instrument of a tax would be. It is not ruled out for the long-term. I think what will happen is that we will evaluate the outcome of the Initiative in 2006 and hopefully by that point we will have got a long way forward in terms of the tools for measurement of effectiveness and more sophisticated measurements of the impact of pollution and we will also have made progress, I would hope, on the issue of substitution and different products and at that point it will be considered. Personally, I would be surprised if at that stage the answer was "Right, forget all that, we will go for a pesticides tax" but it is not ruled out at that stage. Personally, I would think from what I have seen over the last couple of years what we are likely to say is we need more and more sophistication in both the measurement of the impact and the methodology for trying to reduce the amount of pollution and a more focused approach on particular chemicals either because they need to be substituted or they have a particular impact.

  Mr O'Sullivan: I would like to agree with that in terms of where we stand on work on a pesticides tax. We want to be fairly clear that in the PBR, in the Budget, that if the Voluntary Initiative and the way that develops over time does deliver both the targets and the outcomes that we hope, that will be the most effective way of reducing pollution in environmental impact. We have continued over time to produce or think about what work would be needed if we were at any point to go ahead with a pesticides tax, and you will have seen there was a report produced, that Defra worked with, with RPA on some of the administrative and technical issues about pesticides tax were we to implement that. I think we have seen that very much on a contingency basis. What I think we have tried to make clear is that the aim is that the Voluntary Initiative will work.


 
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