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UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 258-ii House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE environment, food and rural affairs committee (Sub-committee on Progress on Pesticides)
Tuesday 8 February 2005 MS EMILY DIAMOND, MR PETER RILEY and DR CLARE BUTLER ELLIS DR MARK AVERY, MR JIM DENSHAM, LORD PETER MELCHETT and MR MICHAEL GREEN
MS HILARY ALDRIDGE and DR ANDY CROXFORD Evidence heard in Public Questions 106 - 244
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Environment, Food and Rural Affairs Committee Sub-Committee on Progress on Pesticides on Tuesday 8 February 2005 Members present Joan Ruddock, in the Chair Mr David Drew Paddy Tipping Mr Bill Wiggin ________________ Memorandum submitted by Friends of the Earth
Examination of Witnesses
Witnesses: Ms Emily Diamond, Senior Researcher for Food and Farming, Mr Peter Riley, Consultant, Friends of the Earth and Dr Clare Butler Ellis, UK and European Programme Co-ordinator, Pesticide Action Network-UK, examined. Q106 Chairman: Can I start our second session of this Sub-Committee of the EFRA Committee on Progress on Pesticides. Can I welcome our witnesses for today, on behalf of Friends of the Earth, Emily Diamond, Senior Researcher for Food and Farming, Peter Riley, Consultant to Friends of the Earth, and Dr Clare Butler Ellis, UK and European Programme Co-ordinator from the Pesticide Action Network UK, who provided a very valuable background note to us on this Committee. Obviously we have seen your written submissions and we want to ask you some questions both in terms of what you have said to us and, also, to take up points which were raised by a number of other witnesses in our first session. Friends of the Earth has made a great deal of the issue that there should be a reduction in the use of pesticides and that has been said by the Pesticide Action Network also. Our other witnesses of last week said that was not the most important issue and they gave various examples of this. I want to begin by asking you why you feel it is important to reduce the absolute level of pesticides used in this country? Dr Butler Ellis: I think there are three important factors which influence the environmental impact of pesticides. Certainly the way they are used is very important, but there is also the issue of how much of them are used and, also, which pesticides are used in terms of the most hazardous versus the least hazardous. Clearly the Voluntary Initiative only tackles how they are used. We feel that even with current best practice being implemented, the pesticides which are being used are still not intrinsically safe, they are designed to kill and can be toxic. Even if you put them on in the best possible way, there is nothing to confine them to the area you are treating: spray drift, run-off, leaching, volatilisation, all these things can move them from where you want them to be to where you do not want them to be and where they can do damage. Therefore, we would say the only way of minimising that environmental impact is to reduce the total amount used. Q107 Chairman: You speak about things landing where they should not. We heard from the Crop Protection Association that, for example, a screw cap on a pesticide container, which is in contact with highly concentrated contents, can be more dangerous than anything if that is simply thrown away and ends up in a watercourse. Dr Butler Ellis: That is undoubtedly true. That, as a concentrated point source of contamination, can have a big effect, but that should not diminish the fact that there will be other things which can have an effect also. I do not think anybody really knows the relative importance of all the different issues. At best, I would say the sort of issues that the VI is tackling, such as point source contamination from a sprayer and from pesticide containers and so on, could never be more than half the problem. At best, we are only tackling half the problem at the moment and I would guess it is a lot less than half the problem. Q108 Chairman: Relatively speaking, where do you think the extent of environmental awareness and using the correct dose lies, vis à vis, reducing the absolute amount of material used? Dr Butler Ellis: Sorry, can you repeat that? Q109 Chairman: What do you think the balance is between using the correct dose and using it well and the absolute dose which is used? Dr Butler Ellis: That is a very difficult thing to answer and I am not sure I can give you an answer to that. Undoubtedly it is true that even if you use some pesticides, absolutely as they should be, perfectly, with no accidents, they can still end up in the water and still escape from where they are supposed to be. There is no such thing as zero spray drift, for example, and we have seen pesticides coming from the fields into the water. I do not think I can give you a figure on what the relative percentages are. I do not think that is possible. Q110 Chairman: Are you perhaps just advocating no pesticides, therefore no risk? Dr Butler Ellis: Absolutely not "no pesticides", because we want to secure food supply, we want to preserve British agriculture, that is really important. We want better emphasis and incentives to move away from the dependence on pesticides. We want better development of alternatives, non-chemical controls, integrated farm management, all these things which can help us to reduce our dependence on pesticides. I think there will always be a need for some pesticides for the foreseeable future. Q111 Chairman: Let me test you again on what the Agricultural Industry Confederation said to us. "There may be a product which is used at a rate of a kilo per hectare, which is safer than something which is used at a quarter of that rate, quantity can be misleading". Dr Butler Ellis: Absolutely, yes. Ms Diamond: I was going to say we do not advocate use reduction simply on that kind of basis, and particularly a simple, based on weight, approach would mean, for example, quite low toxicity compounds, such as sulphur compounds, could be targeted first with very significant apparent reductions but, in fact, the impacts of that are quite minimum. We are talking about a hazard based approach, for example, looking at the risk of the pesticides, the hazards which they cause to a healthy environment and using that as a basis for reduction. We consider that the kind of benefits we would like to see, for the environment and health, go hand in hand with reduction. Also, that would be part of a strategy including things like alternatives and there do need to be alternatives in place. At the moment everything is very focused on pesticide use, we need to move away from that to look at all the other options there are for pest management. Q112 Chairman: In evidence Friends of the Earth have referred, quite a lot, to the residues occurring in food also. We know of your concern about the safety of food which has been treated. I would like to ask you a little about that, beginning with what are your concerns regarding the current system of approvals for pesticides? Ms Diamond: Specifically in relation to food? Q113 Chairman: Yes. Ms Diamond: In terms of the approvals process, we feel that may be a step behind where we are looking at the risks for consumers, in particular with food. We are saying there should be residue-free food at the point of sale. That does not mean pesticides would not necessarily be approved and that would be a way of doing that, it means looking at how they are used, for example, harvest intervals, that kind of thing, and ensuring that pesticides are not on the produce when people buy them in the shops. There are lots of reasons why there are problems with that and some of that is down to, for example, cosmetic use due to high standard demands from supermarkets. There are various issues which relate to why you get residues in food. In terms of the regulatory process, what we are more concerned about is ensuring that, for example, the maximum residue levels are set such that acute reference doses and accessible daily intake levels are met for consumers. That takes into account also the more vulnerable consumers; small children are smaller so they are more vulnerable to pesticides in the food they eat because they eat proportionately more. Those are the areas we are particularly concerned about. Q114 Mr Wiggin: I am very interested by what you said about the cosmetic view of foods because, obviously, people shopping at supermarkets can choose to buy organic foods if they so wish and most supermarkets have an organic section. Are you suggesting that people do not know what is best for themselves and, therefore, they are picking the pretty carrots, if you like, because - I suggest perhaps slightly patronisingly - they do not know what is best for themselves. Is that the case? Ms Diamond: No, not at all. When I say cosmetic standards from supermarkets, I mean they are standards which are imposed by supermarkets upon their suppliers. They have very high standards of physical appearance, for example, they are very, very intolerant of any kind of blemish. These can be completely inconsequential in terms of the quality of the fruit, but there are to do with supermarkets' demands, things like down to the level of blushing on pears and apples. Q115 Mr Wiggin: That is what the customers want, is it not? Ms Diamond: Is it, that is the question? Q116 Mr Wiggin: If they do not, they can buy from the organic section. Ms Diamond: For a start, we are not saying the only option for people should be to buy organic, we feel they should be able to be confident of non-organic produce as well. What we are saying is the supermarkets have set a standard for produce and it is very difficult, for example, even to find class two produce sometimes in supermarkets. They are setting a standard and then saying that is what people want, but there is no good evidence, no research, or anything, that if you presented a person with one apple which was at class one and one which was at supermarket standard - which is often above class one standards - they would automatically choose the better one and that is really what they are demanding and that is really what they are going for. It is a question of, is it demand led or is it led by the supply from the supermarkets? Dr Butler Ellis: The other point is they are not aware of what pesticides are used to produce that food and if they had more information they may then choose a more blemished version than a less blemished if they knew there was less pesticide used in its production. Q117 Chairman: Overall, are you suggesting the present system of monitoring is not sufficient in terms of pesticides in food to guarantee consumer safety? Ms Diamond: We have consistency said we think there should be more monitoring. The specific concerns we have been raising recently have been relating to acute reference doses. What we have said is we have done research which shows these can be seen in children and we would like the Government to ensure that maximum residue levels on acute toxic pesticides are set so that acute references doses are not exceeded. In terms of monitoring for pesticides, there is a wider problem in that it does seem that for routes of exposure there may be only one or two routes which are monitored at all. One would be exposure for food and one would be occupational exposure possibly. There are all sorts of other risks of exposure to people, including home use or bystander exposure or going to parks where they may be used by local authorities. That kind of wider monitoring of pesticide exposure is something which we think should be looked at because until then you do not know what risk people are exposed to. Q118 Chairman: Presumably that is part of your reasoning also, that more toxic pesticides should be substituted for by less toxic pesticides? Ms Diamond: Yes, exactly. When we talk about use reduction, one of the focuses of that would be a targeted approach, so you tackle the most toxic or the most environmentally damaging pesticides first. It is not simply done on a per kilo basis. Q119 Mr Wiggin: Sorry, I do not understand. It is perfectly clear what you mean by the most toxic, but is there not a danger that if you have a less effective pesticide, people will be forced to use more of it and then you return to the toxicity problem that you are trying to tackle in the first place? Ms Diamond: I think there are absolute hazards which you can consider, for example, endocrine disruption or carcinogenicity and, also, things like nerve-affecting pesticides, like organophosphates, where there is not some kind of level at which, if you then substitute it with something else, there would be an equivalent risk because you are talking about specific toxicity and the mode of action. That is the kind of thing you can target. Q120 Mr Wiggin: If you did that, as you suggest, would you not find that the cost would be different - and I say different rather than higher or lower - to what is being imported? How much monitoring of that is going on? It is no good bashing the UK toxicity levels if we simply buy from abroad and replace it with cheaper food which potentially may be more dangerous. How can you get that balance right? Ms Diamond: Obviously monitoring does cover imported produce as well. In some respects that is a policy of the supermarkets, or whoever is buying the food, to decide whether they buy their produce from the UK or abroad. That is also something we have been doing a lot of work on and pointing out that, for example, supermarkets are not buying more produce during the UK season. That is a more difficult thing to say, that you should be regulating for it in this case because this is about pesticide use. I do not think we should be suggesting that we do not do anything on UK problems because something might be happening elsewhere in the world, we have to address the problems here. Q121 Mr Wiggin: I think you are right and I agree with what you are saying because I think what you are trying to identify is that the supermarkets control what is available for us to buy, and the danger is if we come down too hard on our domestic production, they are simply substituted, as you identified, by the supermarket with foreign imports which may be more toxic. Mr Riley: I think a lot of the supermarkets are trying to apply the protocols to their overseas producers as well as domestic work. In time we will see that the pesticide protocols which apply in the UK, will apply to their overseas producers from whom we import. That is going to take some time to achieve. The people I have talked to in the supermarkets are all saying that is their goal. We are nowhere near there yet, but that is the ultimate goal. Q122 Mr Wiggin: Essentially it is a balance between the beautiful field fruit, which you were talking about earlier, and the levels of toxicity. We have got to get that right for all consumers irrespective of where they produce the food from. Ms Diamond: There might be an assumption that, for example, more expensive pesticides are more environmentally friendly or the more toxic ones, which we are talking about, are cheaper. There is not that relationship - I do not think that is proven - that just by eliminating the more toxic pesticides we automatically make farmers' costs go up. In addition, there should be a lot more emphasis on alternatives. We know there are lots of non-chemical, biological methods which can be used. In fact, in other countries in Europe they are far more advanced in introducing those than we are in the UK because of blocks in the regulatory system which we have here. It does not automatically follow. Q123 Mr Wiggin: Can you give us some examples because that might be helpful? Ms Diamond: The way the approvals process looks at biological organisms. At the moment it examines them as if they are chemicals and requires the same kind of information and it is very difficult to provide that biological organism because we operate in the same way. It has meant that producers have found it extremely difficult to get approvals. That is not the case in other countries, so we are disadvantaging our farmers. This argument that by getting rid of more toxic pesticides or reducing use is adding cost to farmers is only because we have got a system which is not providing alternatives. Chairman: We ought to move on to, the Voluntary Initiative and progress or not. Q124 Mr Drew: Can I start by asking a fairly basic question. All the way through your written evidence you are pretty clear that the Voluntary Initiative has not worked. What independent work have you done yourself to try and make sense of whether there is any benefit in the Voluntary Initiative at all? Mr Riley: It would be hard for us to argue that the training of people to use sprayers properly would not be beneficial in the long term. The question is whether it should be a voluntary process or whether it should come under a regulatory process. I think, logically, if people are using toxic chemicals in the environment it should be under a regulation rather than a voluntary process. We have looked quite closely at the progress in the six catchment projects in terms of what is being delivered and in terms of reduced levels of herbicides in rivers which then have to be filtered out by water companies. In fact, there is no evidence that the Voluntary Initiative catchment projects have made any difference at all to date. The largest amount of data relates to the herbicide IPU in the Cherwell catchment, where there has been a historic problem with the levels of IPU in the river exceeding the EC threshold for drinking water. If you look at the historic data going back before the VI started, you could find very low levels of IPU in the river in 1996-97 and higher levels in the last year for 2003-04. There is absolutely no evidence that the VI has made an overall difference to the concentrations of IPU in that river through the programme which has been instigated. The reason for that is because IPU is incredibly mobile in the soil and if it rains soon after it is applied, it will wash into the river and you cannot stop it. If there is heavy rain after application, no amount of Voluntary Initiative will stop IPU getting into the river. You can do things to reduce the amount of IPU that washes off as a result of filling and cleaning operations in the farmyard, but the vast bulk of it comes as a result of direct washing and leaching from the fields. Thames Water are on record saying they believe 90 per cent of IPU in the rivers, which gives them the problems, comes from the field rather than from any other source. There is no evidence to support the claims that these catchment projects have made any difference at all to date and they are very expensive. Q125 Chairman: For the record, you are talking about Isoproturon. Mr Riley: Yes. Q126 Chairman: Are you taking account of the Environment Agency's announcements in terms of the reductions in water courses? Mr Riley: Yes. We have looked at the data going back eight years. It is clear in one year, in 1996-97, there was very little IPU in the river before the VI started. It is possible that is entirely due to the weather in that particular year. As I say, if it rains you cannot stop it, it is an inevitable consequence, and if you use IPU on cereals it will get into rivers, you cannot stop it, it is a physical characteristic of the product. Q127 Mr Wiggin: I am sorry to be difficult on this one. What you are saying is it is weather dependent, and your initial premise was that something should be compulsory rather than voluntary. If it is weather dependent it does not matter whether it is voluntary or compulsory. Make your mind up. Mr Riley: My premise before was if you are going to train, it should not be voluntary but regulatory. In the case of IPU, I think there is a very good case for saying that the only way to deal with the problem is to selectively ban it from sensitive catchments because you cannot stop it. Q128 Mr Drew: Is an alternative to the Voluntary Initiative the idea of a statutory code and that in itself would remove the argument that a pesticide tax is the appropriate way forward? Can I be clear what PAN's and FoE's position is on these different positions given that you do not accept the Voluntary Initiative is working? Dr Butler Ellis: From PAN's point of view, we would like some elements of the Voluntary Initiative to become mandatory, such as the spray testing, sprayer operating training and so on. That should be taken away from the Voluntary Initiative. Because we feel very strongly that we need a pesticide reduction strategy, to a certain extent that is going to have to be by changing the behaviour of farmers, and some voluntary programme to do that may still be appropriate. I believe the Voluntary Initiative can be extended to cover just that. Evidence suggests that the alternative of applying a pesticide tax, just to try and change behaviour, would not do that very convincingly unless you put on such high levels of tax that you risk damaging British agriculture. As part of a complete package we would say a tax has its place in order to raise money to fund the necessary changes in behaviour, the advice which farmers need, the alternatives that need developing, and so on. A lot of that might have to be done through something equivalent to the Voluntary Initiative or an extended Voluntary Initiative or whatever. Q129 Mr Drew: What is FoE's point of view? Ms Diamond: What we would like to see is a package of measures, as part of a Pesticide Reduction Strategy, including a tax. I think simply replacing the VI with some statutory measures, which are essentially the same, does not go nearly far enough. That has been our concern with this, that it addresses a very small aspect of the problem. Really you do need this much wider package, including a tax and an advisory service, which gives farmers independent advice about how they can reduce use. It needs to go beyond what the Voluntary Initiative provides. Q130 Mr Drew: Have you given up on the Voluntary Initiative, because there has been some criticism that you are not attending the Steering Group meetings? Is that a fair criticism and really this is because you see it as a waste of your time? Ms Diamond: Part of the reason why we have not attended some of the meetings simply has been capacity, but I do not think that we feel any more that it is doing the job which it ostensibly sets out to do at all. In that sense we do not see it as something which can be used in the future. This is why we want to see this wider package including monetary measures and fiscal measures in order to address the problem of pesticide use. Q131 Mr Drew: To be absolutely clear, you do not see any opportunity to renegotiate the Voluntary Initiative even though there are some apparent benefits in terms of farmer co-operation and certainly better sprayer techniques? Dr Butler Ellis: I think there is scope for renegotiating the VI and taking it beyond 2006, but it has to think much wider and much bigger and not focus solely on arable farming, there are a lot of other pesticide users out there who are not being targeted. Q132 Mr Drew: Is that a problem? Here we are talking about farmers as though they are the only ones who use pesticides, gardeners use pesticides, why are they not subject to the same? Dr Butler Ellis: Exactly. Things like spray operated training and sprayer testing should be mandatory for all pesticide users, not just farmers. That is one way of getting to the difficult people. Yes, I think the VI has to be broadened more than just farming and much broader than just tackling the way pesticides are used rather than how much is used and which pesticides are used. Ms Diamond: I think Friends of the Earth's position is we do not see that there has been any real historical benefit from voluntary approaches to environmental issues. There are many cases, including pesticides previously, before they were regulated, where voluntary approaches have not worked efficiently and that is why we want to see regulation and fiscal measures as well. Q133 Mr Wiggin: My understanding is 75 per cent of all arable land comes under the Voluntary Initiative, is that your understanding? Mr Riley: No, not yet. I do not think 75 per cent is right. Q134 Mr Wiggin: You do not think it is as high as that? Mr Riley: No, I do not think so, I think it is well short of that. Chairman: That is what we have been told. Q135 Mr Wiggin: You have been able to answer the question but let us assume that is the case, the Government - I am not in any way a fan or supporter - has plenty of pieces of legislation it would like to put through. If that is where we have got to already with the Voluntary Initiative, do you not think you are being incredibly negative by knocking it? Surely you should be pushing for the other 25 per cent that is missing? Dr Ellis, I think you were making that point and I think you are right. Dr Butler Ellis: They have tackled the easiest bit of the problem. I do not know exactly what the numbers are but they do say it is the 80/20 rule, is it not, 20 per cent of farmers probably farm 80 per cent of the land and 80 per cent of the farmers probably are responsible for the other 20 per cent. How are you going to get that other bunch of people? As far as I am aware the Voluntary Initiative currently has no strategy for doing that, therefore making it mandatory would take the responsibility away from them. I think it is a difficult job, I am not knocking or getting at them. Q136 Mr Wiggin: The 80/20 rule is the same as speeding. That is pretty compulsory, there are cameras and all the rest of it, and that does not work either. If it did, that would be super, but it does not. Unfortunately legislation does not necessarily deliver the results you want. Mr Riley: There is a difference between putting forward a crop management plan and seeing tangible benefits in the environment. What I am saying is if you look at the catchment projects, where they put an awful lot of effort in and potentially a high expenditure per farmer, they are not delivering anything in terms of reduction in the amount of herbicide getting into the watercourses. As I said, that is because of the nature of the products they are dealing with. You have to deal with that in a different way completely which is to legislate against the use of that product in a sensitive catchment where public water supply is being abstracted. Chairman: Clearly there is a dispute here, we are being told there are reductions. We will be seeing the Environment Agency later today and we can question them, but clearly there is a complete divergence of view as to how successful this Voluntary Initiative has been in terms of reducing the amounts of pesticides in the catchments which have been tested. There has been a clear acknowledgement that they have been working with the biggest farmers, with the greatest acreage, therefore we can all agree the easiest ones are the ones which are being tackled. Q137 Paddy Tipping: I just want to talk about water pollution, Mr Riley, since you have already talked to us about this, in that the whole exercise is dependent very much on weather conditions. Mr Riley: Yes. I have done an analysis of four of the catchments in terms of winter rainfall of the two years prior to the VI starting and two years during the VI. Actually finding dry periods during the winter where you could actually say that that is safe to spray is very, very difficult. Most dry periods are less than three days in duration and that will be the bare minimum to try to prevent certain herbicides washing into rivers. So it does require a very good weather forecasting service, but also for farmers to be mindful of that because if you have a field of winter cereals which has weeds in it and the ground suddenly becomes dry enough to go and spray herbicides on it, you will take the opportunity to get on that ground because it might be the only opportunity you get that winter. The consequence of that is that you have sprayed and you do not know if it is going to be absolutely bucketing down with rain in two days, and if it is bucketing down the evidence we have from the Cherwell catchment is that IPU will find its way into the river very, very rapidly indeed. Paddy Tipping: This is all about good management practice, is it not? Mr Wiggin: And weather forecasts. Q138 Paddy Tipping: Absolutely. I think that is part of it. Mr Riley: What I am saying is that it is extremely difficult. The weather forecasters in the Met Office will not predict the weather five days ahead, and for good reason because the weather is extremely unpredictable. The weather patterns in two of the catchments I looked at, they had almost the same rainfall but the average length of dry spell during the winter period is quite different. So it is down to each catchment, almost, what the weather is going to be doing in that catchment if you are going to give farmers the sort of advice they need on when then can spray safely, and it will depend on the soil as well because some soils will be able to absorb rainfall much more and therefore the drains will not start running quite so quickly. Therefore, the advice will have to be tailored very much to the farm level if you are going to prevent these very soluble herbicides finding their way into rivers, and the evidence we have before us from the catchments at the moment is that that has not worked. I think in the Leam catchment there was a claim that there were reductions in one year, and the reason there was a reduction in that year was that the ground was simply too wet for any farmer to get on the ground and spray, so no products were actually sprayed. Q139 Paddy Tipping: Given the vagaries of the weather, it does not matter if it is a voluntary or mandatory system then? Mr Riley: That is what I am saying. If you are going to deal with this particular problem of water pollution by herbicides you have to tackle it and say, is this product going to be a running sore for the water companies forever because of its physical properties, i.e. solubility? And for a whole group of herbicides, if it rains soon after it has been applied they will wash out and leach and end up in rivers. It is a consequence of their properties and you cannot avoid that. So you have to deal with that either by banning them selectively or banning them altogether. Q140 Paddy Tipping: Let us just stick there because we have a spectrum of views. Dr Ellis is telling us that she favours a Voluntary Initiative, provided it is coupled with mandatory elements plus a pesticide tax. Emily, you seem to be in the middle, and Peter has just told us he would ban the whole shooting match. Mr Riley: No, no, I am saying selectively ban the herbicides that are causing you the problems. Dr Butler Ellis: We would agree with that as well. Mr Riley: And Thames Water supports that position, as far as it is my understanding, because it is costing them a lot of money. Q141 Chairman: I just want to check here. We have been talking about one pesticide and its properties and I think the Leam catchment was the one where we heard evidence that there was a reduction. Were measurements made of anything other than Isoproturon? Mr Riley: There is data for a number of products, Mecaprop and MCPA2,4-D. We only have data that we have been given, and so all I can go on is what I have seen. The really detailed data is on Isoproturon, and I think the VI has focused on that particular product because it is a big problem for the water companies. Their original catchment, their pilot project was in the Cherwell where they solely focused on IPU, and the results from that are very clear. They ran it for two years and in the first year it was very dry and there were very low levels of IPU getting in, and the proportion of IPU that they calculated came from operations like cleaning and filling was between 40 per cent and 60 per cent. In the second year it bucketed down just after it was applied and the levels of IPU in the river in that small bit of the catchment rose by 981 per cent. It is quite clear. Q142 Chairman: What I was trying to work out was, was there anything else? When we have heard that there have been reductions of 23 per cent, is Friends of the Earth saying that that is entirely due to weather and that there are no reductions that could have come from some other cause, perhaps not from that particular chemical but from others? Mr Riley: I think it is difficult for me to answer for other chemicals because I have not seen enough detailed data, but for IPU I think the only way that you could get a really dramatic reduction would be if it was a very dry year and people who were filling and washing did it extremely carefully, but if the weather forecast was wrong and it rained heavily and unexpectedly then the result would be high levels of IPU in the river. You can match rainfall to IPU levels and it is a perfect fit, just about. Q143 Paddy Tipping: We have talked a lot about pilot areas. There are only six pilot areas. Mr Riley: Yes. Q144 Paddy Tipping: And I think in your evidence you make some comments about scaling up the costs nationally from these six pilots. Can you take us through that and try to put some figures on it? Ms Diamond: We have somewhere got some detailed figures on the actual costings. I think it is partly because of the kind of levels of intervention that they are using, for example texting farmers to inform them about the weather, and things like that. So it is a very concentrated on these farmers in these catchments. What we are concerned about really is to scale that up would be extremely expensive and it is not entirely clear who is going to pay for that. In fact in some of the discussions recently in the papers it was suggested that the water companies might like to pay and they suggested that they really would not like to pay for this. So although in the sense of intensive advice to farmers about how they can best manage their pesticide use is something that we would like to see, and we would like to see that independently provided to them, in this case the question is who is going to pay? And it should not be the water companies who already have to pay for clean up costs and it should not be taxpayers. So, in that case if the pesticide companies would like to pay for this role out of this project then that is fine by us. But that is the question that we are raising: who is going to pay for this to roll down? Q145 Paddy Tipping: You said you had some figures, which you do not seem to be able to find at the moment. Mr Riley: I have got them here, if you want. They are examples. The Boston Park catchment, which is a ground water catchment for public extraction in South Yorkshire, just the calibration for text messaging in that catchment cost £5,700, and there were only 60 farmers in the catchment, so that is £95 per farmer. Obviously there will be economies of scale but you can see that costs will escalate quite rapidly and, as Emily says, the question is who will cover those costs? With the current state of the farming economy it is unlikely that farmers are going to be too keen on covering that cost, so it really comes down to either water companies or the pesticide manufacturers and the "polluter pays" principle really has to come into play, and it is the pesticide companies who have to finance it if this is going to be rolled out. Q146 Paddy Tipping: But you are not telling us that the experiments, the good practice of the pilots can be rolled out and therefore the costs will reduce as you roll them out? Mr Riley: Some of them will be reduced by longer print runs and things like that, but a lot of the information, as I hinted at earlier, is that it would have to be tailored to the catchment concerned because the leaching of pesticides is a lot to do with the local soils. So it will not just be a text message that goes out to every UK farmer because, as we have seen, rainfall varies enormously, even within quite a small area. So you can get very high rainfall in one catchment and a relatively reduced rainfall in another. So it is by no means easy to plan such a rollout for the whole of the UK without incurring significant costs. Chairman: Bill Wiggin, pesticides tax. Q147 Mr Wiggin: I am going to ask you about taxation, but one quick question on this solubility thing you mentioned before. If IPU is so soluble it is not actually staying where it is wanted, which is doing its pesticide job, it is washing away, and surely the easiest way to deal with this is to get a pesticide that is actually more permanent rather than more soluble? It is the nature of the pesticide. Mr Riley: I do not think there is any evidence to say that IPU is an ineffective herbicide in cereals. Q148 Mr Wiggin: So it does the job, but is washed away and carries on doing it. Mr Riley: You only need a tiny fraction of what is applied to wash off the field to cause a problem, and that is the problem that the pesticide companies have and the problem that we are paying for as water consumers at the moment. Q149 Mr Wiggin: One of the questions about this is how you justify the high transaction costs of administering and collecting a complicated banded tax on pesticides, because I think that is one of the things you ask for. How would you deal with that? Ms Diamond: We justify the high transaction costs? I think actually at the moment there is still some discussion even within the NGOs that are supporting a tax as to exactly how it would be done and whether it would be banded or whether it would be quick to apply - a quick and easy approach, that kind of thing. In terms of the high transaction costs I have to say, not being a specialist in this area of taxation, I cannot really --- Q150 Mr Wiggin: Would you like me to ask you another one then? What criteria would you use? Ms Diamond: I do not know what the transaction costs are and because I do not know what percentage of the tax would go to the transaction costs in the way that you are suggesting - I have not seen any figures on what that level of cost to that process is - it is difficult to comment on something in that way because it is like how long is a piece of string? It depends how big the costs are that you are talking about, whether they are justified or not. Q151 Mr Wiggin: No, it does not, but let me ask you another one. What criteria would you use to categorise pesticides into different tax bands and to what extent could this categorisation be scientifically based? Ms Diamond: Actually there has been quite a lot of research done already; looking at what kinds of measures could be used. So various organisations have done so. For example, the CARC has looked at issues around eliminating pesticides, so they have looked at it on that basis for their own purposes; the RSPB has looked at it; PAN has looked at it; and the Environment Agency has looked at it. So there are various different processes taking different aspects. So eco-toxicology, the impacts on biodiversity, for example, the impacts on water pollution. So there are various measures you could use. You could incorporate them all. There is also the issue of gaps, because there are enormous gaps in terms of what we know about the toxicity and environmental impacts of some of these pesticides because the regulatory system is quite narrowly focused and so that information is not being generated. So there is an issue about whether you might band something quite highly because there are gaps in the information about it, which would then encourage the research to be done by the pesticide companies into actually what the effects of their pesticides are. Although it is not straightforward it is not starting from a complete blank; a lot of work is being done and that can be built up. Q152 Mr Wiggin: How would you ensure that the revenues raised by a tax would be directed back into improving the sustainability of agriculture, rather than being siphoned off by the Chancellor? Ms Diamond: I think that is a question really for the Treasury, unfortunately. We would like to see it hypothecated. Q153 Mr Wiggin: There is a hard point here, which is that it is no good turning up and saying you do not like the Voluntary Initiative if you cannot answer these questions, because this is what you are asking for. It does matter because this is what you are asking for and it does matter because the Voluntary Initiative is reaching 75 per cent or whatever of, at the moment, the most vulnerable areas, and therefore we need answers and this is a good opportunity for you to tell us. Dr Butler Ellis: The point is, we want money raised to be channelled back into farming. Whether you decide to do it through pesticide tax or whether the Treasury opens its coffers and lets us get at some of that money really probably does not matter to us. It is important that farmers have independent advice, help, support to move away from this heavy dependence on pesticides. If that is what we are trying to achieve we have to pay for it. Q154 Mr Wiggin: I think you are right, but 75 per cent of arable farming is already covered. They are volunteering, they want to do the right thing. Dr Butler Ellis: But they are not being encouraged to reduce the pesticide use, they are not being encouraged to move to anything different. If you like, current best practice is being put in a box and they are saying, "Go on doing that indefinitely," and we would say that that is not sustainable. We want to move to less toxic products, we want to move to fewer pesticides being out there, being a burden on the environment, and we want to help you do it. We do not want to charge you for doing it, we want to find ways of supporting it, and a pesticide tax would --- Q155 Mr Wiggin: Yes, but when I ask you how you are going to categorise it, it is difficult to answer. Dr Butler Ellis: It is a very technical question. We could send you information about how it has been done in other places, and I think Norway already has a banded tax, which is immensely complicated. As Emily says, we are not starting from a blank sheet of paper. The PAN view is, possibly, do not worry about banding to begin with, put on a flat rate tax just to raise the money, just to start raising awareness. But I do support the idea of having more tax on the more environmentally damaging products because that sends a very clear message to farmers not to use them. Q156 Mr Wiggin: The problem I have with this is that there is a separation here between the theory - put the tax on, raise the money, when there is a strong chance that it will not raise any money and people will simply substitute, so it does not work - and then you have the issue of why you wanted to raise the money, which is effectively to nail the worst sort of pesticides. A very, very good idea but difficult, and I think perhaps written evidence would be the best way to get over this. Dr Butler Ellis: Yes, we can send you something. Q157 Mr Wiggin: Because this is not adding up at this stage. Ms Diamond: I was going to say that there is this figure of 75 per cent under the Voluntary Initiative but what we are saying is that it is only tackling one part of the problem. So, yes, there is 75 per cent of people maybe doing these Crop Protection Management Plans but, as we know, simply ticking the boxes is enough to say they are covered. There is not a good linkage between being covered by the Voluntary Initiative and environmental benefit. What we would like to see - and this is why we have been calling for fiscal measures - is to make that link better and to raise money. Yes, obviously hypothecation is an issue but we would not be calling for a tax simply to raise money for Treasury, we are calling for it because we believe that there is a need to reduce pesticide use and there is a need to raise revenue to help farmers to do all the enormous number of demands that are being placed on them now to switch to the kind of farming they have been encouraged to do for the last 50 years, to a new kind of farming which is more about sustainability and environmental protection. Essentially at the moment what is happening is that they are being asked to do this without this kind of support that they had before. We had an advisory service for about 50 years that encouraged farmers about how to use pesticides and now we are saying do not do that any more, do all these new methods of farming, without any equivalent support system, and that is what we are really concerned about. Q158 Chairman: I just want to say to you that we are running out of time and David Drew wants to come back in, but I think you said something important that we will be taking account of, which is that you do not appear to be - and I want to make sure that I am right - wedded to a pesticide tax, all you are saying is that the money has to be there so that every farmer can be helped to do the things that you think should be done in relation to pesticides? Ms Diamond: The reason that we are saying pesticide tax is because we do believe that it should be part of the polluter pays principle. So whilst we do want to have money for farmers to do these things we do think that those companies that have benefited over the years from pesticides sales should also help to fund that, and the pesticide tax is the way to do that. That is why we talk about pesticide tax. Q159 Mr Drew: Of course, the reason the Treasury backed off the pesticide tax, besides being lobbied extensively by the agricultural industry, was the simple fact that because there are so many pesticides that are out there already there was a view that it may be counter productive if you try to put a tax on it because people will just stock up in advance with all the stuff that you want them to get rid of and misuse them, at least in the short run. How would you overcome that possibility? Dr Butler Ellis: I think it is inevitable that if you propose a pesticide tax people will stockpile, but I think that was one of the reasons why we thought flat rate, quick and easy, do not procrastinate for too long, just get on and do it. Not at a level that is seriously going to damage farm incomes and the viability of the farming operation, and preferably in a way that it does not actually transmit itself through to farmers. But in discussions we cannot think of a way that that would actually happen; that if you level the tax on the pesticide company they are almost inevitably going it pass it on to their customers. Yes, it is not going to be perfect and the banding does mean that perhaps farmers will not move from less toxic to more toxic pesticides, bizarrely, because it just happens to suit what is going on, and it will not necessarily distort the market. It does need some thinking about but, let us face it, is there another solution on the table as to how we are going to tackle this? So far it is the best one, so far as I can see. Mr Riley: I think you have to view this as a package of measures, of money from a tax, increased regulation in some areas, selective bands in other areas where there is a particular problem, and a very well financed training programme, so that we get a relatively rapid transition from where we are now to where we want to be. It seems to us if you put it all together it would work effectively, and the evidence of ADAS in the past is that it is extremely effective at changing farmer behaviour. In the 1950s and 1960s new technology was taken on very rapidly by people going around and talking to farmers face to face. Chairman: Thank you very much. We are getting behind time, as we always do, because there is so much interest in what you have to say. Thank you very much for coming, all of you. If, on reflection, there is anything you want to clarify please do contact us in writing. And we will be glad to have the Norwegian experience on a banded tax. Thank you very much indeed.
Memoranda submitted by the Royal Society for the Protection of Birds and The Soil Association Examination of Witnesses
Witnesses: Dr Mark Avery, Conservation Director, Royal Society for the Protection of Birds, Jim Densham, Agricultural Policy Officer, Royal Society for the Protection of Birds, Lord Peter Melchett, Policy Director, Soil Association and Michael Green, Policy Officer, Soil Association, examined. Q160 Chairman: We will continue with evidence from the Royal Society for the Protection of Birds and the Soil Association and I would like to welcome Dr Mark Avery, the Conservation Director from the RSPB, Jim Densham, the Agricultural Policy Officer, and from the Soil Association Lord Peter Melchett, the Policy Director, and Michael Green, the Policy Officer. Thank you all very much for coming and for your written evidence. Unlike the previous witnesses, I think both of your organisations have had a lot to say about the positive results of the Voluntary Initiative, such as being successful in uniting the agrochemical industry in a common aid and developing a sense of responsibility, which is what the RSPB said. The Soil Association said that they succeeded in raising awareness, generating some management plans, getting the farmers to inspect their sprayers, and so on and so forth. So you have seen some very positive elements. I want to begin by asking you just how successful you think that the Voluntary Initiative has been in achieving the targets that were set for it? Dr Avery: If we could kick off? We would not want to be churlish. We think that the Voluntary Initiative has achieved some things and, as you say, we think it has helped to bring the agrochemical and farming industries together and concentrated their minds. We are disappointed with progress though, and can I just clear up the 75 per cent figure that has been mentioned in the last few minutes? 75 per cent of the arable area in this country is sprayed by operators who are on the National Register of Sprayer Operators. That does not mean that those operators have actually gone through the sprayer-testing scheme; it does not mean that there are Crop Protection Management Plans for all of that area. If there are Crop Protection Management Plans it does not mean that they are actually being implemented over the whole of that area, and even if they were they would not necessarily be good enough to reduce the pesticide impacts that we are all worried about. So I would not want the Committee to think that we are 75 per cent of the way there - wherever there is - because we are a long way away from that. We think VI has been useful, but I would say that we are losing patience with it because we do not think it has been as good as it should have been. Q161 Chairman: Can you pinpoint the main successes? Dr Avery: I think the main successes are that it has concentrated the mind, that people have worked together. Q162 Chairman: Does that matter if they are not achieving? That is the question, is it not? Dr Avery: It is a start. As I said, we would not wish to be churlish; we think it is a start towards the right direction. But the end point of all of this policy work, Voluntary Initiatives and everything else, ought to be a National Pesticide Strategy which has clear end objectives of where we want to be, which sets objective for pesticide residues in food, pesticide levels in water courses and the impacts of pesticides on wildlife. Voluntary Initiative is a useful first step towards that end point, but it is quite a long journey and it is only a small step so far, we would say. Q163 Chairman: As you have the floor, before I bring in the Soil Association, do you want to say what the major weaknesses are - you have just referred to some - so that we have a clear picture of the successes and major weaknesses, before we look elsewhere? Mr Densham: I think the major weakness is that it was put as a VI or a tax and it was not fitting in to any sort of strategy, any sort of formalised National Pesticide Strategy, which we have been waiting for for two years, from Defra. Without those targets and those clearly set out ideals, end results set out in a strategy, it has been quite hard, I think, for the VI to know where it is really aiming at and to have a good steer. That is what we feel has been a problem and a weakness. So there have been positive points; we really think that it has - as Dr Avery said - given a good awareness raising and that is a positive point. However, some of the projects that have been put in place, another weakness is that they have been relatively unambitious in their targets. For example, we have heard about the coverage of 75 per cent of arable area under the sprayer operators. However, one of our major criticisms is that Crop Protection Management Plans, even though they are a positive thing and they potentially could do really good work and get farmers to really see what they are doing on their farms - and that is included in the Entry Level Scheme - the target is only there to cover 30 per cent of arable land and that is only arable land at this stage. So we would really like to see that covering a much larger percentage of arable land as well as non-arable land. Q164 Chairman: Do you also have the view that a farmer could tick all the boxes but actually be performing very poorly, but would be credited with having the plan and that is a positive? Mr Densham: That is true. I myself sit on the VI Steering Group and we are working in a sub-group to look at Crop Protection Management Plans, and it is true that some farmers could say they have done it and they could just keep it on their shelf and not really refer to it throughout the year. However, we are trying to create ways that they can have feedback. So they fill them in, they have them analysed - we analyse them and send the results out - and they can judge themselves and they can try to see where they fit into the rest of their industry and their peers. So those things are positive and, like I say, there have been positives from the VI and good techniques and tools come out, but we would like to see the targets to be more ambitious in the future. Q165 Chairman: If I turn to the Soil Association and ask you the same questions really - the successes and the weaknesses? Lord Melchett: I agree with what the RSPB have said about what has been achieved, but I do not think it has been of great significance. I think the Voluntary Initiative has some major inherent flaws, inherent in the Initiative, and that there should be a tax, definitely. So that is our position, and quite unambiguous. The inherent flaws seem to us to be twofold: first, that inevitably a voluntary scheme of any sort will attract those who are most enthusiastic about its objectives and be least good covering those who are least enthusiastic. In other words, people who are most irresponsible in their use of sprays are the people who it is going to be the most difficult, if not impossible, to get into a Voluntary Initiative, and they are effectively free riders and they benefit. The irresponsible users of sprays benefit most from the Voluntary Initiative and that is an inherent flaw in a voluntary scheme, in which I do not see any way it can be addressed, and it is one of the reasons why a tax is required. Secondly, the Voluntary Initiative does nothing to address the current market distortion in food, whereby people buying organic food effectively subsidise the use of pesticides because they pay as taxpayers the costs which fall on society as a whole with the use of pesticides. Cleaning up drinking water they pay through their water bills, but all the other regulation and so on of pesticides, which taxpayers pay for, organic consumers are paying, and then they pay slightly more for food produced without pesticides. That market distortion is grossly unfair to the organic farmers and could only be addressed through a tax; it cannot be addressed through a Voluntary Initiative. So the Voluntary Initiative has had some impact in generating plans and inspection of sprays - not something I think as a matter of public policy but a factor of good practice in any event - but it has inherent flaws which a tax would address and only a tax would address. Q166 Chairman: Can I ask RSPB, do you think that there are ways in which the Voluntary Initiative can be improved, or do you think that it is necessary to go to compulsion in order to raise this from what is a positive but small contribution to a more comprehensive programme covering everybody who is a user, et cetera, which could either be done by a tax or by other fiscal incentives? Where do you stand on compulsion and improving the Voluntary Initiative as it is? Dr Avery: We believe in both. We believe that there is a place for voluntary action and that that could be done much better, but that ought to be seen as part of the package for regulation. A pesticide tax would be one option which we would still support. And it really is putting too much of a burden on the voluntary approach to think that it can do everything. It can do some things but it cannot do everything. So government needs a package of measures which deal across the board with the types of issues that there are, and it is unfair to think that the Voluntary Initiative can do all of it. Q167 Chairman: You probably know that the Farmers Union and the other witnesses that we saw on our previous occasion would all consider it entirely unfair to impose a pesticides tax. How can you justify that compulsion and the cost? Dr Avery: I think part of the deal for the Voluntary Initiative is that the industry is going to show great strides and progress without having a tax imposed on them, which we do not think they have done, in order to escape the tax. In fact if you look at the website for the Voluntary Initiative it says, "Voluntary Initiative helping biodiversity and making sure we do not get a pesticides tax." So I am not surprised that the industry is not keen on the tax, and I think that there are real difficulties about designing a tax which would work well to reduce the impacts and which would be a fair tax and not have perverse impacts. But we do think that a tax, if properly designed and implemented, ought to be part of a whole package of measures. Or at least it ought to be looked at. We should not discount it at the moment; it is there as an option and it is a real option and clearly it is an option that has been used in other countries in Europe who have already gone that far. Q168 Chairman: Soil Association? Lord Melchett: I agree with what Mark has said. You could argue that it is a little unfair for British farmers to be exempt from the tax when a number of other European countries, who are competing with our farmers in the market place, are already subject to a tax and a tax which, at least in some countries, there is good evidence it is having the desired effect of impacting on the use of pesticides, which is not what you were told in evidence in earlier session. But the report to Defra makes that quite clear. Q169 Mr Drew: If we can look at the issue of how you are working with the VI at the moment. Are you both represented on the Steering Board? Lord Melchett: The Soil Association does not have any great expertise in the use of pesticides as we do not use them! So it maybe for that reason we have not been invited. Q170 Mr Drew: There is always opportunity of education, Peter, on both sides. Obviously RSPB have been, as you have just mentioned. We heard quite a robust defence of the VI, both from the industry and farmers' representatives when we met them in the first session. Are you saying what you are saying to us to them and they have not quite got the message yet, or is there a complete and utter divide over this and they have a mindset now which is, VI good, tax bad? Mr Densham: I think the industry is more forward thinking than that, that it is starting to not really think about it as a pure tax versus the VI - one or the other. We have been there since the beginning and I hope our attendance has been very good. I have not been on it from the beginning, which is why I say that. So we have been there as advisors. We are not signatories to the VI, we are there advising those who are the signatories to give them the best of our advice, with the Environment Agency on water, with English Nature, with ourselves on birds and wildlife so that we can help them to steer and try to achieve their biodiversity targets. So we are very positive to try to help them because we want to see the best for farmland and farmland birds. Q171 Mr Drew: So are you taking part in some of the evaluations when you are literally going out and doing some measurement? You may be doing that anyway because you would be looking at the impact on birds' species. But there is cooperation, there is engagement there, that you could not criticise them for trying to shut you out - that is actually going on? Mr Densham: Absolutely, yes. We think that our working relationships are quite productive and we are always open about what we think, and I hope that they understand what we say. And we do try not to be very radical but try to work with them. Lord Melchett: Can I just say something about the relationship between different sectors of the farming industry? If you had been reading Farmers' Weekly the last couple of months I think you would have a pretty clear indication that there was not much coming together between organic and non-organic on the question of pesticides - there has been a vigorous correspondence. And it is not surprising. If you were a non-organic farmer and the taxpayers were effectively paying some of the costs associated with your use of pesticides you would fight very hard to continue to see taxpayers pay those costs because it gives you a competitive advantage - we think an unfair one. But you are not going to have them come along - either them or the industry - and say voluntarily, "No, no, the taxpayers should not be paying for this, we will cough up. Please tax us," that would be a pretty unique occurrence. But, frankly, that surely is the job of the Committee and the government to decide where these costs should fall? Should the costs fall on society as a whole or on industry producing the costs? We would say that they should fall on industry and that that is fair and normal practice outside agriculture. Q172 Mr Drew: Let us touch on this idea which obviously the Soil Association is firmly committed to, which is that there has to be a pesticides tax and you are equivocal that you are not happy with progress on the VI. It does seem that there is some questioning going on about the validity of that tax, and the whole point about taxation is that it has to be very clear what it is trying to achieve. In the previous session - and you all sat in on it - there were some mixed metaphors going on about is it really there to change attitudes or is it to do with raising some money which you could then put into ways of doing things differently, which may include making the Voluntary Initiative more effective? Can you help me get clear in my mind where you are at with the advantage of a tax? Dr Avery: We believe that a tax, if properly designed, could reduce the impacts of pesticides on the environment, and that is what we are interested in. That is not quite the same as the amount of pesticides used, as you have heard already, but we would want to reduce pesticide impacts. To do that the tax has to be carefully designed, and unfortunately because life is complicated those pesticides which are most potentially damaging to human health are not always the same pesticides that would have the biggest impacts on wildlife, and they are not always the pesticides that most easily find their way into watercourses. So you have a complicated system where different pesticides are good and bad along different axis, so that makes designing a tax where ideally you would just be able to say, "Here is a good pesticide, here is a bad pesticide, we will slap a big tax on the bad pesticide" rather more complicated. I would not say we are equivocal, we think the pesticides tax has a role to play, but it would have to be a pesticides tax that took that complexity into account in the real world because otherwise, as you have heard before, a pesticides tax could have perverse impacts and that would not suit us and it would not suit society. The other thing we would say about the design of the pesticides tax is that we would wish to see the revenues hypothecated back into the farming industry, ideally back into paying for other means to deal with the impacts of pesticides. We would not support a tax that just took money out and gave it to the Treasury. That would just clobber the farming industry. If it were badly designed it would not reduce pesticide impacts and that would be a bad tax, we would say. So we are not equivocal. I am afraid the RSPB does see the real difficulties of designing a tax, and we think work should be done on that. We think the Treasury ought to be doing that work, and if we had a proposed tax in front of us it would be easy for us to say that, yes, that is a good tax or no, it is a bad one, and I think just talking about the pesticides tax in the abstract probably is not helpful because everybody has a slightly different idea of what it should do and what it might look like. Lord Melchett: May I just say that our position is slightly different? Our priority would be to see a tax to level the playing field between organic and non-organic farming. That would be our first priority and that could be a simple tax. I agree with the position that the RSPB and others have taken, but you have with this tax the added potential benefit of banding the tax to achieve environmental objectives as well as simply raising money. So that would be a second, desirable objective which we would certainly support. But in the first instance, you could have a tax which would level the playing field and give the market a chance to work properly, which we would welcome. Q173 Mr Wiggin: So can I just clarify that? You would like to see the tax levied and then given to the water companies? Lord Melchett: No, I did not mention the water companies, I just said levy the tax. Q174 Mr Wiggin: But earlier you said that organic customers were penalised because they paid a premium for their organic products and then they paid their water bills. So when the money is levied from the pesticide users surely that means you want to give it back to the water companies? Lord Melchett: No, because that was not the only cost I mentioned. There are a number of costs which fall on taxpayers as a whole and the public purse as a whole, the cost of enforcement, of running the Environment Agency, and a number of other costs of that sort, most of the pesticide regulation - although some is already covered by a very modest pesticide tax, that is true. So that already exists. We are interested in seeing the market work properly, and you mentioned that earlier and that is something that we would support. And we do not think that organic farming should be disadvantaged by allowing those who use pesticides to call on the public purse to pay some of the costs, or on people as a whole through water courses. Q175 Mr Wiggin: How would you then level the playing field? Lord Melchett: By imposing a tax on the use of pesticides, and ideally then achieve additional and environmental benefits in the way that the RSPB have outlined. Q176 Mr Wiggin: That would not necessarily level the playing field, would it? That would change the pricing structure but it would not effectively do what you wanted to do. Lord Melchett: Yes, I think it would. It would go a long way. None of these economic instruments are going to be perfect and they are always fairly imprecise in their impact. That is true of all taxation and this would not be any different from that, just as it would not be any different if people were trying to stockpile pesticides as they try and stockpile cigarettes. I think those are arguments either against all taxation or they are not valid arguments. Q177 Mr Wiggin: What I am worried about is that the Chancellor would leap on the fact that it is not actually possible to level the playing field because of the reasons you have just given, and then keep the tax and we would all be at a disadvantage. That is why I am pressing you on this one. Lord Melchett: I do not think that farmers who do not use pesticides or who minimise their use of pesticides would be in the circumstances you outlined; they would be advantaged competitively and that would be good for them and it would be good in terms of achieving the government's new objectives for agriculture which are to see agriculture produce food that the customers want. We know that they want to avoid pesticide residues - that is the Food Standards Agency's advice - and we know that the government want agriculture to be more sustainable. Dr Avery: Could I just chip in that if there were a pesticide tax that reduced pesticides going into water then clearly the water consumer would benefit because we are paying as a whole in England and Wales £122m a year in our water rates as the cost of removing pesticides from water, and the water companies have invested something like £3.6m in capital investment to have the kit to take the pesticides out. So if you had a tax which solved that problem some farmers would lose out - unless the tax were hypothecated - organic farmers would benefit because the playing field would be adjusted in their favour, and the water consumers would benefit in that case. So exactly how --- Q178 Mr Wiggin: I am sorry, the Chancellor is going to keep the money for the Met Office because we clearly heard that the problem with pesticides is that when it rains they go into the water! We have to face up to the fact that it is going to be very difficult to get the level playing field that the Soil Association is talking about, all the benefits from taxation that you want. I am sympathetic but I do think that we are up against it. Lord Melchett: There are three separate issues being confused, I think: the level playing field; the banding, which achieves the objectives we both want; hypothecation, which will put the money back into farmers' pockets in some way, hopefully organic as well as non-organic farmers, which is the thing you are raising objections to. I think our objectives are met by the first two things, the existence of a tax and a banding system which impacts on those that do most environmental damage. I am not insisting on hypothecation because I know the Treasury do not like it. Q179 Chairman: We do need to move on, we are getting behind, but Dr Avery said that if we had a draft tax before us we could make a comment. I just want to ask if you have studied at all the Norwegian example, and if so what you have made of that? Does it work? Dr Avery: We have had a look at that and I will pass over to my colleague in just a moment. We have also done some work ourselves to look at the whole issue of whether banding is feasible in this country. We think it is but we think it is difficult, so we have done some work which convinces us that this is still a live issue and a practical way forward, but, as I say, we would want it to be banded and we would want hypothecation before we would be in favour of the tax. Chairman: I think I will leave it there without getting your colleague in because we need to pass on. Paddy Tipping. Q180 Paddy Tipping: You mentioned £122m a minute ago; where did you get that figure? Mr Densham: From Ofwat. Q181 Paddy Tipping: There are other instruments we could use. I know that RSPB are very interested in local environment schemes and cross-compliance, and this is a changing field at the moment. How could we use those to influence pesticide use? Dr Avery: I think you heard in your last session that some of the measures in the Voluntary Initiative could be built into agri-environment schemes. We think that is a pretty soft approach really because we think that the Voluntary Initiative is dealing with good practice and that therefore those elements of a strategy ought to be built into cross-compliance. These are things that one would expect every farmer or everybody operating a sprayer to be complying with, not something that ought to be rewarded. This is simply good practice. So that is how we would see most of what is in the current Voluntary Initiative as being dealt with under cross-compliance rather than agri-environment schemes. But then your broader question is what is the package of measures, how would we see everything fitting together? And that is in a National Pesticide Strategy. Mr Densham: Which should contain the five main points. So you would be looking at having a Voluntary Initiative within that, for voluntary efforts, with money from the tax not actually going into farmers' pockets but going to pay for those measures. Then elements in agri-environment schemes covered in that strategy, in cross-compliance also. Then looking at regulation, what farmers should not do, how they should not spray things inconsiderately, that sort of thing; that should also include elements of the approvals process. We would like to see indirect effects of pesticides on wildlife included in the approvals process and that could be included in the National Pesticides Strategy. Then finally the tax that we have already talked about. So there are five points that should be included in a National Pesticide Strategy, and they all do different jobs and they all fit together into that. Q182 Paddy Tipping: So where is this National Pesticide Strategy? Dr Avery: I think a Defra Minister will appear before you in the future. I think that is really a question for him, not for us, because we do not have a clue where it is. It is long awaited. Q183 Paddy Tipping: How much is it delayed? Mr Densham: It is delayed at least two years. It was called for by the Curry Report which said there should be a leadership in pesticides from Defra, and that was at least two years ago. So it has been in the pipeline, shall we say, but we do not know why it is delayed. Dr Avery: And it does not feel imminent, so I do not think we are being unfair. It is not as though we think somebody is just about to bring it out and show it to us; it just does not appear on the horizon at the moment. Q184 Paddy Tipping: Have you been consulted on it? Mr Densham: We will be consulted. Q185 Paddy Tipping: But not yet. Mr Densham: But not yet. Q186 Paddy Tipping: There has been no Bill towards it? Mr Densham: There was a pre-consultation consultation, but that was about a year ago and we thought that would be the precursor of the actual strategy but we have not seen anything since then, so we are still waiting. Q187 Paddy Tipping: It looks like we will have a stack of questions for the Minister. What do you think the problem is? Dr Avery: That is a good question for the Minister, but not one that we can answer! Lord Melchett: We are hoping that they have seen the light and they have realised that what they need is a no pesticides strategy. With the change in agricultural policy agriculture should now be sustainable. We do not have a public objective of producing food, or producing cheap food - that changed from the beginning of this year. There is no public need for pesticides at all, it is not an objective of public policy to enhance or even enable the use of pesticides and it should not be, and it is not part of new agricultural objectives. So we would like to see a no pesticides strategy or at least a rapid reduction of pesticides strategy. Q188 Paddy Tipping: As we are focusing on you, Peter, just remind me how you control pests - organic farmers? Lord Melchett: Organic farms, in almost all cases, control pests and diseases of plants and farm animals through systems which encourage natural immunity, natural resistance, which reduce the incidents of the disease or the threat. There are a couple of examples where that is not yet possible, apples and potatoes, where some pesticides, insecticides of fungicides but no weed killers are used in organic farming, but very small quantities of mainly copper and sulphur. Q189 Paddy Tipping: Copper and sulphur. Mercury? Lord Melchett: A little bit of derris; no, no mercury. Rotenone is the other. Q190 Paddy Tipping: So if we were applying a tax, because sulphur is a pollutant in its own right --- Lord Melchett: Sulphur is used primarily in agriculture as a fertiliser by non-organic farmers in very large quantities. The use dropped during the period when we had a lot of acid rain from power stations, which deposited sulphur free of charge on farmland. But now people are having to start to apply it again, and the quantity of sulphur used in organic farming is a very small percentage of the total applied. I do not have the figure in my head, but it is a tiny percentage of the total. Q191 Paddy Tipping: So you see these substances outside any taxation range? Lord Melchett: No, they should be taxed and we should stop using them. No, no, I am all in favour of a level playing field. Q192 Paddy Tipping: I was just checking out! Lord Melchett: The difficulty for non-organic farming would be that these are used as fertilisers, copper and sulphur, for soil conditions, so it might be difficult to tax the organic sector, but there could be, there should be, because we should be under more pressure than we are to develop new varieties of crops. You see that in other European countries, organic systems in countries where there is less use for pesticides and pesticides are discouraged, which are doing much more in the way of crop breeding and developing new varieties which avoid the use of pesticides on organic as well. Q193 Chairman: But hopefully not by genetic engineering? Lord Melchett: No, not by genetic engineering, by normal crop breeding. And very effective too. I have seen some very interesting new varieties of apples in Switzerland, for example. Q194 Mr Wiggin: As I understand it, copper, derris, sulphur and soft soap are the ones, and you have been very clear about your feelings on that, but they are not subjected to the same research as modern pesticides, are they? They do not fall into the scrutiny category, if you like, of pesticides? Lord Melchett: They have to be cleared, as all pesticides do, but most old pesticides or old substances used as pesticides did not go through the sort of scrutiny that a pesticide would do now. But then these are very, very simple substances - soft soap breaks down in sunlight very rapidly. They are used in a tiny area, mostly in tunnels or greenhouses and not in the open at all, and on a normal arable farm like my own we do not use any chemicals at all, and there are not any available for use. Q195 Chairman: Michael Green, did you want to come in? Mr Green: I was just going to agree that the four pesticides that are used in Soil Association farms have to go through the same approvals at the Pesticide Safety Directorate that any other pesticides would have to go through. And they are used in very small quantities. Rotenone and copper are only ever used as a last resort. For instance, Rotenone was used by 16 Soil Association organic farms in 2003 and Rotenone is also highly biodegradable and has very minimal impacts on the environment, which really does put the issue of pesticides in organic farming in context with the huge quantities that are used in non-organic farming. Lord Melchett: But we would like to see it stopped. We are not defending the use. They are an historical and unfortunate necessity which should be brought to an end as soon as possible, but we think that applies to all pesticide use. Q196 Mr Wiggin: What do you think the impact has been by delaying the publishing of the National Pesticide Strategy because effectively that has had an impact on the development of policy in the UK, has it not? Mr Densham: I think it really has caused problems for farmers because they do not quite see how the government is steering the use of pesticides or the strategy as much as the industry, as much as ourselves. As I said at the beginning, I think it has caused a problem for the Voluntary Initiative because it does not have a clear steer on what it is aiming at. Q197 Mr Wiggin: It does not fit in, effectively. Mr Densham: Exactly, it does not fit into an overall strategy and people do not know where the links are between so-called tax, VI, regulation, and that would all be very clear. After all, farmers are the ones that want to know that if they are doing something they are not going to be clobbered because something else is going to come in two months down the road, or also that their neighbour, who is doing bad practice, is not getting away with it. Mr Wiggin: Essentially I think that the Pesticides Safety Directorate have quite a lot of questions to answer because there are quite a lot of people trying to do the right thing without any clear steer from the government, apart from the fact that if they are not doing the right thing they will be taxed. Is that fair? Thank you. Q198 Mr Drew: Can I just be clear? One thing that I have been thinking about and talking to others about is this idea that there is a middle way between the pesticides tax and the Voluntary Initiative, and that is for a statutory code for at least part of the operation of a Voluntary Initiative and you heard me suggest this to both PAN and FoE. I would be interested whether you see any merit in this. It could of course include the pesticides tax as one component, but we clearly are talking about having a regulated law for government to try to deal with the bad end of the operation in the use of pesticides. Is this a way forward, or is it again going to fall down between the two stools? Dr Avery: If I understand what the statutory code would look like, that is akin to our suggestion that what is currently in the Voluntary Initiative ought to be built into cross-compliance. So this would be a list of things that you have to do and things that you must not do, and if you break those rules then you risk losing part or all of your single farm payment, and that is the system that we will have in agriculture from now onwards. There are many legal obligations that are already built into cross-compliance in that way, and I think that would be the right way to deal with some of these pesticide issues. So I am quite sympathetic to that, although I would rephrase the way that we would describe it, but, again, we would see that as part of a bigger initiative, a strategy, that actually sets, amends objectives for what we want to see in terms of public policy and then maps out all the ways that we can see those things being delivered. Relying on other attacks or a Voluntary Initiative is not very clever because neither can do the whole job. The government has to set out what the whole job is and then look at all the tools to deliver it. Lord Melchett: I want to agree that cross-compliance gives you a much simpler way through in getting farmers to obey the law or follow good practice, which is what we are talking about. I do not think it needs to get completed with different schemes and regulations and logos. But none of that addresses the failure of any of the things to both level the playing field between different sorts of farmers and ensure that the farmers who are determined to avoid doing the right thing are the ones that benefit as long as the scheme remains voluntary. Chairman: Thank you all very much indeed. If on reflection you want to add anything to what you said, correct anything, do write to us. Thank you very much. We will move on to the Environment Agency.
Memorandum submitted by the Environment Agency Examination of Witnesses
Witnesses: Ms Hilary Aldridge, Head of Environmental Quality, the Environment Agency and Dr Andy Croxford, Pesticides Policy Manager, the Environment Agency, examined. 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." "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 no 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 per cent 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 targets, that there is a target of 30 per cent reduction, which I think you are on the record as saying that we should not be complacent about that 30 per cent, if the Voluntary Initiative could produce a 30 per cent 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 per cent 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 per cent target conditional on not having extreme weather conditions in the next couple of years. Q206 Mr Wiggin: 50 per cent on which base year? Dr Croxford: It will be a 50 per cent compared with the mean from 1998 to 2002. Q207 Paddy Tipping: So not another 50 per cent? Dr Croxford: No, not another 50 per cent. 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 £122m; I have seen the figure of £100m; I am told there is a parliamentary question that says it is only £1m. What is the real cost? Dr Croxford: The £120m 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 per cent tax on pesticides which we were told would lead to a 20 per cent 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 per cent drop in pesticide levels and water, so that was the proposal prior to the Voluntary Initiative that the pesticides tax could deliver a 30 per cent reduction in pesticide levels in rivers and that was part of the reason why the target was originally set at 30 per cent 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 Lindanum, 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, 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. Ms Aldridge: 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. Q220 Chairman: You describe catchments. My recollection of previous evidence, unless I am wrong, is that about 600 farmers were involved in one of these intensive operations and we were told there is something like 160,000 farmers. We do not seem to have hard enough targets, we do not seem to have targets that are being met, necessarily; we have plans which could be just tick boxes and only a relatively small number of all of the operators actually involved, et cetera, et cetera, et cetera. I just feel that we are not at all clear about the way forward. Dr Croxford: We view this in terms of where are we trying to get. So what are the environmental outcomes we want to achieve? How much do we want to reduce pesticides in water and by when? We then need to think about how we are going to get there. What is the most effective way of getting there? But without being clear about where we are trying to get to it is actually quite difficult to be able to tell you today that we think we should go and measure X because we are not too sure where the government wants to get to with this. What is their final objective? So the idea of mandatory training and certification of sprayers and the testing of spray machinery seem good ideas to us, but we would want to see them considered as part of a broader look at this. Another area that we would be concerned about is --- Q221 Chairman: Let me just interrupt you. Should not the Environment Agency, which advises the government, know where you, the Environment Agency, wants to get to for the sake of British farming, the British, our food and all the rest of it and our environment? Should you not know where we want to get? Dr Croxford: Clearly we have a view on that but we are only one part of government. We can happily state where we think we want to get to on this. We know where we need to get to in terms of the Water Framework Directive, in terms of meeting the good ecological status of the Water Framework Directive, so there are some givens and we can provide a view on where we think we should get in terms of other issues as well. Q222 Mr Wiggin: How well placed is the UK to meet the requirements of the EU Thematic Strategy on the Sustainable Use of Pesticides? Ms Aldridge: There is a question! Q223 Mr Wiggin: I have hardly started. Dr Croxford: Some of the things the Thematic Strategy calls for, introduction of a National Action Plan, so we have heard about that, we are developing an Action Plan. Q224 Mr Wiggin: So we do not have one yet? Dr Croxford: We do not have one yet. The mandatory training of users and to the maintenance of sprayers. So we have talked about that. The promotion of alternative pest control techniques as a part of the Thematic Strategy. Now, that is an area where we do need to do more work. Q225 Mr Wiggin: Can I come back? You said the mandatory training? Dr Croxford: Yes. Q226 Mr Wiggin: And that is what has to be brought in, according to the EU, is that right? Dr Croxford: The Thematic Strategy proposes that. Q227 Mr Wiggin: Sorry to interrupt, I just wanted to clarify that. Dr Croxford: The promotion of alternative pest control techniques is something that we would certainly support and where there is clear need for more work to be done. And the Pesticide Safety Directorate has been putting in place a pilot scheme to try to fast track non-chemical methods of pest control, or non-conventional chemical methods of control. Q228 Mr Wiggin: So in your view how will the Voluntary Initiative fit within the National Pesticide Strategy? Dr Croxford: It would form an element of that but not the whole. Q229 Mr Wiggin: Because I have a list here of your proposals of what you would like to see within the National Pesticide Strategy, and I will not read them out but they are all pretty much the things we have discussed. Which of these do you think holds the most promising for minimising the environmental impact of pesticide use? So of all the things you want in your wish list, which are the big ones? Do you want me to read them out? Dr Croxford: No, I can remember most of them, I think. Certainly the training and the sprayer testing would be big ones for us. Also - and this was something that was raised earlier - that there is still some unnecessary use of pesticides that goes on in terms of insurance policy type spraying. So, for instance, the spraying of aphids on cereals in the autumn is still quite a common practice because people are concerned about their cereals contracting a virus that the aphids carry and so they will spray whether the aphids are there or not as an insurance policy. Another example is that cereal varieties vary in how resistant they are to diseases. Some are much more susceptible than others. But the pesticide use on those cereals does not vary. You would expect less pesticide to be used on the more resistant varieties. Q230 Mr Wiggin: You would probably have planted more resistant varieties so that you could cut your pesticide costs, that sort of goes hand in hand. But it is not happening? Dr Croxford: It is not happening. Q231 Mr Wiggin: It does strike me from what you have told us, that it is the National Pesticide Strategy and the government body responsible for producing this that is the real weak link. We have the Voluntary Initiative doing, as you have said, part of the job; you have things that the EU is demanding, and yet there is nothing from government. Is that fair? Dr Croxford: We are very disappointed at the progress with the National Pesticide Strategy but we do understand that apparently it is with the Minister now for issuing as a public consultation. Mr Wiggin: That is all right then! Q232 Paddy Tipping: As a draft, do you mean? Dr Croxford: As a draft. Q233 Paddy Tipping: Have you seen it? Ms Aldridge: No. Dr Croxford: We have not seen a recent draft, no; it was probably six months ago the draft that we have seen. Q234 Paddy Tipping: You have contributed to it? Dr Croxford: Yes, as have many other organisations. Q235 Mr Wiggin: You have added your wishes to it, presumably? Is that the sort of thing you have done? Dr Croxford: Yes, we have said what sort of things we think should go into a National Pesticide Strategy as have many other organisations and government departments. Q236 Paddy Tipping: When is it going to be published? Dr Croxford: I do not know that. That is up to the Minister. Q237 Mr Wiggin: Surely there must be a dovetailing between the ending of the Voluntary Initiative in 2006 and joined-up government that we were promised, surely? No? Maybe not. No surprises there then. Dr Croxford: One of the difficulties I would have is that there is going to be this gap between the end of the VI and whatever comes after it and we have to get the National Pesticide Strategy in place now to be able to be up and running with it by the end of the Voluntary Initiative. Q238 Mr Wiggin: Just one little question. The domestic users are out of the loop on nearly all of this. What percentage of the problem do they contribute to it? Dr Croxford: They use a fair proportion of the amount of pesticides used. It is not tiny; I cannot remember the exact figures but it may be ten per cent, perhaps. It is quite a lot. Q239 Mr Wiggin: That is quite a lot. Dr Croxford: In terms of the problem that is quite a difficult question to answer because most of the pesticides that are used in the garden are also used in agriculture and in amenity use. So if we monitor the environment and we find a pesticide we cannot be sure, in many places, where it is coming from. Q240 Mr Wiggin: A ten per cent cut would be quite significant, so are there any plans afoot to perhaps allow domestic users to use different types, so that you at least could monitor them, or just ignore the whole thing? Dr Croxford: There are moves afoot to provide them only in ready to use formulations, so that reduces the disposal issue, and also to provide sensible pack sizes so that you are only provided with enough to use for one season, and you do not have a pesticide that you buy and then you keep it in your shed for the next ten years or whatever. Mr Wiggin: It depends on the size of your garden as well! One of the areas that matters of course is the biodiversity element and gardeners do now represent quite a lot of biodiversity in the UK, and it seems as though the Environment Agency is doing what was criticised earlier, which is picking on the easy targets - and in this case that will be the farmers - and missing ten per cent of the whole problem, which is the domestic thing, which is why I wanted to cover that with you. Q241 Chairman: The amenities sector is also very significant, so we know that a lot is being missed actually. I just wonder, if you were sitting on this side of the table what you would expect this Committee to conclude? I am tempting you to answer! Are we in a mess? Dr Croxford: I know you have been critical of this approach already, but I would like to start out with a clean sheet of paper, list our problems, where do we want to get to, what are our options, how effective are each of those options, how much do each of them cost, what is our most cost effective strategy to get from where we are to where we want to get to? That is our package. That sounds a very simple thing to do in the three sentences and obviously is a very complex thing to do, but if we want to have a strategy that is really strategic that is what we need to do, rather than just cherry pick things which seem like good ideas. Q242 Mr Wiggin: And we could have a proposal that we could be discussing and pulling to pieces and criticising and trying to be constructive about, but at the moment we just have nothing, and that makes it very difficult, does it not? Ms Aldridge: I think we have bits of a jigsaw and what you are hearing, we are painting pictures of different parts of it and we desperately need that overall package that we could then pull apart or criticise and say, "That is great, we will move forward that way." Chairman: I think David Drew just wanted to come in at the end. Q243 Mr Drew: Just as a final afterthought. Is part of the problem with this in as much as there is a bigger agenda, which is the whole issue to do with chemicals? We have the arguments going over the directive in Europe, we have an increasing concern being voiced by some elements in the general public that they are not very happy about what they eat with regard to chemicals, which is the pesticide side. But also some of the issues about chemicals in the air and so on, and, dare I say, NGOs seem to be able to pump out - not necessarily things into the atmosphere but the cards to us about peoples concern, and I noticed in the pack of stuff that I have had today that there is a new chemicals campaign being launched by Friends of the Earth. Where are we in terms of pesticide in that whole gamut of activities with regard to chemicals? Or is this distinct? Is this something that can be separated and put on the side, and deal with pesticides and the rest of the chemical debate another day? Dr Croxford: In October 2003 we launched our chemical strategy which includes pesticides but which goes across the board, across all chemicals. Part of that work, as I mentioned earlier, includes our prioritisation of which chemicals we should be most concerned about, pesticides included. But there are many other chemicals that we are concerned about, industrial chemicals that we are concerned about. So we are trying to take a broader sweep at this and not just single out pesticides because they have their own regulatory system and because there is a lot of machinery in place to allow us to target pesticides. We are trying to take a broader approach to chemicals. Q244 Mr Drew: But that is a good answer for not doing anything immediately. For a politician occasionally they want an early, easy hit, which is pesticides. They are not going to sort out the rest of the chemicals in the environment. That is a wholly subjective and, dare I say, quite a difficult debate in terms of the scientific rationale. But pesticides could be resolved satisfactorily. We have seen that there is some common basis for that today - not a lot with the industry, but the industry, I think, could be brought to heel. Do you not see something to be driving forward here? Dr Croxford: I was trying to paint the broader picture of how pesticides are part of a broader debate on chemicals, but clearly we can push forward on pesticides and we are pushing forward on pesticides as we are with other types of chemicals. Ms Aldridge: I do not think we should use the fact that it is part of a bigger picture to stop any work until we know how that whole system works, because we will never move forward. Chairman: I think we might conclude that ourselves. Thank you very much indeed, Environment Agency, for your evidence. As usual I say to you, if on reflection you want to add anything or amend anything that you have said to us, please feel free to write to us. Thank you very much for coming. |