Environmental Audit Committee - Pollinators and Pesticides - Minutes of EvidenceHC 668

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Environmental Audit Committee

Insects and Insecticides

Wednesday 27 February 2013

Lord de Mauley, Professor Ian Boyd and DavE Bench

Evidence heard in Public Questions 583-669



This is a corrected transcript of evidence taken in public and reported to the House. The transcript has been placed on the internet on the authority of the Committee, and copies have been made available by the Vote Office for the use of Members and others.


The transcript is an approved formal record of these proceedings. It will be printed in due course.

Oral Evidence

Taken before the Environmental Audit Committee

on Wednesday 27 February 2013

Members present:

Joan Walley (Chair)

Peter Aldous

Martin Caton

Zac Goldsmith

Dr Matthew Offord


Examination of Witnesses

Witnesses: Lord de Mauley, Parliamentary Under-Secretary of State, Department for Environment, Food and Rural Affairs, Professor Ian Boyd, Chief Scientific Adviser, Department for Environment, Food and Rural Affairs and Dave Bench, Director of Science, Engineering, Analysis and Chemicals Regulation, Health and Safety Executive, gave evidence.

Q583 Chair: Order. Minister, I would like to welcome you back to our Environmental Audit Select Committee this afternoon. We appreciate that on your first appearance before us you were just new to your post, so obviously it is a great pleasure for us that you have come back this afternoon obviously equipped to look in some detail at the issues that we have. Also a big thank you to your two colleagues for coming along here this afternoon.

Given that there have been a lot of recent developments of one kind or another, both with the EFSA survey that was done and also with the developments in European Commission, what we want to start by doing is try to get a handle from you, Minister, at the political level, on what is going on in Europe and what was the reason for the scheduled meeting not taking place. But more important politically, just exactly what is the UK Government’s position on neonicotinoids?

Lord de Mauley: Thank you very much indeed.

It might just be worth rehearsing what has happened since we last met, if that is helpful.

Chair: That would be perfectly in order.

Lord de Mauley: In addition to what you referred to going on in Europe, the ACP has been considering a number of pieces of evidence, including the results of our fieldwork, and have recommended further work, which is under way. EFSA, as you say, has done a report, which is still in draft, on the application of new risk assessment to the existing regulatory data. As you mention, the Commission has made a proposal to restrict the use of neonicotinoids, which we are considering.

Q584 Chair: That is the bit I want to try to press you on. Considering: what exactly is considering? Have you not reached a decision on that at the moment?

Lord de Mauley: We have seen a current draft of a proposal but as you know, they postponed the meeting. We have not seen the actual proposal that they will table for the meeting in March.

Q585 Chair: Just so that we are aware and up to date with what is happening, you say that you have seen a copy of the draft of what would have been considered had that meeting taken place. Is it possible to know what was being considered to be voted on and also what the UK Government’s position on that was: how you would have voted on that draft proposal?

Lord de Mauley: The key elements of the draft proposal were a ban on the use of clothianadin, imidacloprid and thiamethoxam on crops attractive to bees and that is a long list, including oilseed rape, maize and spring cereals and a ban on the sale and use of all seeds treated with the three active substances for those crops; both these measures allowing limited exemptions for use in greenhouses and for the production of seed; a complete ban on amateur use; all measures to apply from 1 July 2013; suppliers, being required to compile further scientific data and submit these by 31 December 2014. A recital in the draft regulation commits the Commission to starting a review of these further data early in 2015.

The Commission circulated a draft proposal on 21 February and, as I said, this may change before a vote is taken. As to how we would vote, we are still considering our approach but in discussions we have put the case for a proportionate and evidence-based approach to this whole issue. On the one hand, there are important issues about the protection of pollinators and on the other, there are real economic concerns. Europe should therefore consider this issue urgently but carefully. We have pointed out our new science, which is nearing completion, and have offered to share this to help guide a decision. We have asked the Commission for greater clarity on what is proposed and particularly on the evidence and reasoning behind it and we have asked them for information on economic and agricultural impacts. We await that.

Q586 Chair: Just so that I am absolutely clear, because it is a very technical subject, the draft proposals, which were not discussed because the meeting was cancelled-we will come to that in a minute-the draft decision, if you like, included the option of a temporary suspension of imidacloprid for the two-year period.

Lord de Mauley: For a range of uses. Yes.

Q587 Chair: Had that vote have taken place on the scheduled date, were it not cancelled, what would the UK Government’s position have been?

Lord de Mauley: As I said, we have asked a number of questions and we need the answers to those from the Commission. How to vote is a very difficult decision. As I have said, on the one hand there are real issues for pollinators. On the other, there are real economic issues. They are potentially quite finely balanced. We have asked for more information and we have not yet received it. We have not decided how we would vote.

Q588 Chair: Okay. You have not decided

In your initial response you say that you were having discussions with other people and I wonder if you could perhaps share with us who those discussions were with.

Lord de Mauley: Of course we have spoken to some other countries.

Chair: Could you share with us which ones?

Lord de Mauley: Can I think about that before I answer?

Chair: You may, indeed.

Lord de Mauley: There are a number of other countries with which we are holding discussions to understand their perspectives and to explain our concern that action needs to be evidence-based and proportionate-I think this would be entirely normal for an important issue such as this. Our discussions with those countries have not reached any conclusions because, as I say, we are still waiting for data.

Q589 Chair: Have there been meetings with the industry as well in relation to the European proposals?

Lord de Mauley: I am not sure that I have an answer for that. I don’t know. Do you know?

Professor Boyd: I don’t.

Q590 Chair: Not with yourself, then?

Lord de Mauley: Certainly not with me, no.

Q591 Chair: With officials?

Lord de Mauley: I am not aware of such.

Professor Boyd: Not formal meetings, no, nor meetings with industry.

Dave Bench: It would be normal for companies to ring my colleagues up to ask for clarification as to what is going on so there may have been some contacts of that nature. Not any that I am aware of, but it would be quite normal if there had been. Certainly there have been no formal contacts and no meetings.

Chair: Zac, do you have a question on that specific point?

Q592 Zac Goldsmith: Jut a very quick one. I am interested to know if you are able to identify what is the key information that you are looking for that would give you the confidence to take a decision were the vote to come back. Secondly, when are you like to get that information?

Lord de Mauley: Sorry. Let me just go back. I think one key aspect that we want to be absolutely sure about is that the Commission has thought through both the economic and the agricultural/pollination aspects of this thing and weighed up the balance properly.

Zac Goldsmith: Do you mind if I follow up?

Chair: Not at all.

Q593 Zac Goldsmith: Do you feel that you have enough information on the effects on pollinators? Is it the economic bit that is missing?

Lord de Mauley: Can I ask the Chief Scientific Adviser to talk a bit about that because there are some aspects of our field tests, some work that is still to be done, which impacts on this.

Professor Boyd: Just to respond directly to your question, no, we don’t know enough about pollinators to be sure of making the right decision here. As you are aware we have been involved in carrying out a number of studies, one of which is in a late stage of analysis and I can provide you with details verbally of the outcome of that study if you wish. But the outcome of that kind of study, and other of studies that are currently in train, is important to this decision. One of the problems that we face is that this decision is being made by the European Commission without sight of that evidence. We feel that evidence has a very significant bearing on that decision.

Q594 Zac Goldsmith: In terms of the timing, what are you doing, then, to access the information you need to fill those gaps and how long will that process take?

Professor Boyd: At the moment we have some studies commissioned and some of those studies will take several months at least before they report. We have a study that is coming to a close. I was hoping that it would be published by now but there are some complications associated with that study that require further fairly difficult statistical analyses to be done. That may take several weeks if not a month or two to carry out. We feel it is really important that the European Commission has sight of those studies before it makes a decision.

Chair: I am bringing Mr Caton in on that.

Q595 Martin Caton: I am a little concerned about what you said in explaining why the Government has a dilemma. Forgive me for paraphrasing you, but you seem to be saying that there is evidence of a threat to pollinators on the one hand and obviously clearly we are very worried about that. On the other hand there are the economic interests that we have to take into account. Under the EU regulations, do you have the freedom to balance those two? As I understand it, an active substance shall have no unacceptable effects on the environment having particular regard to a number of considerations. You know we had questions about your letter in response to the Buglife report where you talked about needing overwhelming evidence before you would take action against neonicotinoids. It is worrying that that same sort of attitude seems to prevail in your Department.

Lord de Mauley: The key word, if I may, that you mention is "unacceptable" and the key question is whether the harm is acceptable or unacceptable. It is a matter of a level.

Q596 Martin Caton: And EFSA have said it is unacceptable.

Lord de Mauley: Sorry?

Martin Caton: EFSA have suggested that it is unacceptable, hence their recommendation.

Lord de Mauley: EFSA’s report did not say that. It does not reconcile with their press release, which I agree with you mentions that word. But the report does not say that.

Martin Caton: We had a representative from EFSA here. He certainly did not question the press report that was quoted to him several times.

Lord de Mauley: Are you referring to Mr Fontier: your witness Mr Fontier?

Martin Caton: I think it was. Yes.

Lord de Mauley: If I can quote from his evidence to you in answer to question 523 on 6 February, he said, "I do not think we say they have unacceptable effects" and he went on in similar vein.

Q597 Martin Caton: But they were saying that these particular products should no longer be used on pollinators, hence the nature of their report. That is true, is it not?

Lord de Mauley: That is not what their report says. I agree with you that their press release says that but they do not reconcile with each other.

Martin Caton: I can remember his evidence and it certainly did not contradict the press report. Anyway, perhaps we should proceed.

Lord de Mauley: I can quote you some more from what he said.

Martin Caton: It is all right. I was there. Thank you.

Lord de Mauley: Of course you were there.

Q598 Chair: Just two more quick things, Minister. On the balance that Mr Caton was just referring to between the economic aspects of this and the risk, could you just clarify for us what are the economic considerations that you took into account?

Lord de Mauley: The critical question is the amount by which, in the case of oilseed rape for sake of example, the annual harvest is reduced by such pests as are unable to be dealt with by the pesticide. I have to say that this is an exercise in which there are a lot of variables and they are quite wide variables. I think it is probably too early to go into detailed numbers but it is a fine balance.

Q599 Chair: Has there been work done, either by your own Department or by peers, looking at economic considerations, particularly in respect of the suspension of imidacloprid?

Lord de Mauley: That work is under way, as I understand it.

Chair: On the economic considerations?

Professor Boyd: Yes. The economic analysis that has been done so far suggests that there could be quite a significant economic impact if there was total withdrawal. If neonicotinoids-

Chair: Can you respond specifically about imidacloprid?

Professor Boyd: Because it is used a lot less, the economic impact of imidacloprid would be a lot less.

Lord de Mauley: We talk about the three.

Professor Boyd: In the analysis we have done we have looked at the neonicotinoids in total. We have not divided down between those different neonicotinoids as substances.

Q600 Chair: So there is no work going on in relation to imidacloprid.

Professor Boyd: Not specifically.

Dave Bench: It will include the analysis in relation to imidacloprid as well as the other neonicotinoid active substances.

Professor Boyd: Yes, it does.

Q601 Zac Goldsmith: Once the research is done, will it be possible to distinguish between the impacts of the removal of the individual products? Or would you only be able to assess the potential impact of the removal of the entire class of pesticide?

Dave Bench: You will have some resolution beyond just the totality but the more that you try to drill down, the more speculative you become. As the Minister has quite rightly said, there are some very broad variables involved here and some larger functions that have to be made in order to make these kinds of analyses.

Q602 Chair: Okay. And almost finally from me now: the meeting that was scheduled to take place in Europe was cancelled and we would just really like to know from you what is going on and why it was cancelled.

Lord de Mauley: So would I. I don’t know particularly why it was cancelled. We have been trying to find out. But I have no doubt that there will be a meeting sooner or later. I think there is a meeting in March, isn’t there?

Dave Bench: In March, yes. Mid-March.

Q603 Chair: One of the things that concern us is that I understand that Martin Taylor, the chief executive of Syngenta, described the proposed moratorium as "Brussels shenanigans". He also said that "the French are determined to export their ban" and that "the European Food Safety Authority has been nobbled". I wonder whether or not you think he was right in that.

Lord de Mauley: It is news to me. I have not heard that.

Q604 Chair: Whether or not you have heard it, I have just quoted what he has said. Would you agree with that?

Lord de Mauley: It would not be an assertion I would make, no. No. I think the Commission is thinking very carefully.

Q605 Chair: I am not talking about the Commission’s views: what are your views on it?

Lord de Mauley: You were asking me why has the Commission deferred and has it-it is really the Commission, I think, we are talking about, because EFSA advises the Commission

Q606 Chair: What I am saying is that there have been these comments from Syngenta about this particular cancellation and irrespective of the fact that the meeting was cancelled and will no doubt be re-scheduled, I am asking you whether or not you think that Martin Taylor was right in what he said.

Lord de Mauley: Can you remind me what he said?

Chair: Martin Taylor, the chief executive of Syngenta described the proposed moratorium-this is the proposed moratorium that you said was in the draft proposal-as "Brussels shenanigans". He also said that "the French are determined to export their ban" and that "the European Food Safety Authority has been nobbled".

Lord de Mauley: I would not associate myself with those remarks. No.

Chair: You would not. All right. Thank you very much.

Q607 Peter Aldous: I draw attention to the Register of Members’ Interests. I am a partner in a family farm where oilseed rape is grown.

Minister, what weight do you attach to EFSA’s revised risk assessments here for neonicotinoids?

Lord de Mauley: EFSA has done what the Commission has asked them to do. As I have explained earlier in answer to Mr Caton, we do have an issue with their press release, which goes much further than their actual conclusions. They have used draft guidance, which is still under development, and have applied it to existing regulatory data. Their conclusions therefore should not come as a surprise. In some cases they were unable to reach a conclusion because there is insufficient data or no agreed method for doing the assessment. In others they have reached a conclusion that there is a possible risk on the basis of the risk-assessment scheme used. I don’t know whether either of my colleagues would like to add to that.

Professor Boyd: That is fine.

Dave Bench: No.

Q608 Peter Aldous: In reaching Defra’s view on EFSA’s revised risk assessments, how much have you relied on ACP advice?

Lord de Mauley: We rely very much on the ACP’s advice. In reaching that conclusion I do not know that we specifically rely on the ACP advice.

Q609 Peter Aldous: Did the ACP issue you and other Ministers with unequivocal advice on EFSA’s revised risk assessments?

Lord de Mauley: No. In fact the ACP advice to us has principally been on evidence they have themselves been examining and indeed it is not as yet complete. They have asked us to get more work done.

Q610 Peter Aldous: Were you aware, or are you aware, from the minutes of the ACP meeting on 29 January, that the ACP was split on EFSA’s risk assessments with some ACP members favouring the introduction of a moratorium?

Lord de Mauley: Two members gave an alternative view. Yes, I am aware of that.

Q611 Peter Aldous: Was Defra happy about this difference?

Lord de Mauley: I beg your pardon. I do not think they were members. They were attending a meeting, anyway. Two people attending a meeting had an alternative view. I am so sorry.

Q612 Chair: Were they not members, then?

Lord de Mauley: I believe that is right.

Dave Bench: They were two former members.

Chair: So two?

Dave Bench: Former members.

Q613 Chair: Two former members. Were they members at the time?

Lord de Mauley: No.

Dave Bench: No. They had attended because it was the first meeting attended by the new members appointed to those positions. They attended for the sake of continuity of seeing through this issue.

Q614 Chair: Can we just have the names of those two members, please?

Dave Bench: It was Peter Mathiessen and Colin Brown, who you received evidence from at a previous evidence session here.

Chair: Thank you.

Q615 Peter Aldous: Were you concerned at all that there appeared to be differences of opinion among ACP members, whether it is existing members or those just carrying on in an advisory role?

Lord de Mauley: Yes, of course. We take notice of both views, and all views are considered.

Professor Boyd: I had the pleasure of attending that meeting and I think that in any of these meetings one of the functions is to distil down a common view from a number of sometimes opposing views. It is quite normal to record the minority view in those cases. But I have to reflect the fact that the two individuals involved were not members of the committee and the committee took a collective view at the end of the day, which was roughly similar to the previous view but informed by some additional evidence. They asked for some additional work to be done as well.

Q616 Peter Aldous: As I understand it, that ACP advice to Ministers is not in the public domain at present. Would we be able to have a copy of that advice so as to inform our own deliberations?

Lord de Mauley: Yes, of course you can.

Chair: That is very helpful.

Peter Aldous: That’s great.

Lord de Mauley: I should say for the sake of this meeting, it is pretty well encapsulated in the minutes, in fact. But of course we will supply it to you.

Q617 Peter Aldous: You would consider publishing that advice, given the high level of public interest in this matter?

Lord de Mauley: We would consider that. I think normally the publication is at the next meeting.

Dave Bench: Yes. And normally the tenor of the advice is encapsulated by the publication of the minutes. It is not normal to publish the separate advice direct to Ministers except on specific occasions. But there is no reason why we cannot do that.

Q618 Chair: This could be one of those specific occasions.

Lord de Mauley: We will certainly provide it to you. Can we consider publication? I do not see any reason why not but I would like to consider it.

Chair: Thank you.

Peter Aldous: Thank you.

Q619 Martin Caton: At our 12 December evidence session the ACP and Defra both highlighted that the results of two Food and Environment Research Agency research projects on bumblebees and on bee health and pesticide usage would be available in January and that those studies would fill key evidence-gaps on neonicotinoids. Were the results of those studies worth waiting for? Have those evidence gaps been filled?

Lord de Mauley: Can I ask the Chief Scientific Adviser to answer that question?

Professor Boyd: I think the results of those studies are probably worth waiting for. The problem we have at the moment, particularly with the bumblebee study, is that it is incomplete. The other honeybee study is ongoing and will take some time to complete. I can give you a verbal update on the bumblebee study if you wish but it might take a little while and it is quite technical. But you may be interested in it.

Q620 Martin Caton: Could you let us have a written note on that if it is going to be that sort of length of time?

Professor Boyd: I can certainly do that. I could give you a very quick update on the outcome if that would help. It is entirely up to the Chair.

Martin Caton: If you are quick.

Professor Boyd: Okay. Basically the study involved putting bumblebee colonies next to three different sites, one of which was a control site with no treatment. This is oilseed rape I am talking about. Another one was treated with clothianidin and the other one was with imidacloprid. In very quick summary, there was no difference at all in the performance of the bumblebee colonies between the control site and the clothianidin site. There was a difference in the growth rate of the colonies in the imidacloprid site. But there was no difference across all of the sites in terms of the number of queens that were produced. So the two end points were growth and the number of queens that were produced. The number of queens represents the reproductive output. The problems with the study are first of all that at the control site there were residues of a neonicotinoid in the pollen and the nectar at that site. So the bees were foraging on other fields in the district that had been treated with neonicotinoids. The second problem is that in the imidacloprid site, where the growth was not so high, the study was started later and the overall temperature at the site was lower than in the other sites. It was also started with colonies at a lower weight. All of these things have to be taken into consideration in subsequent analysis and may well account for the differences that we have seen.

Q621 Martin Caton: Is part of what you said in that answer the fact that the control site was contaminated?

Professor Boyd: The control site was contaminated. This is the nature of field studies, unfortunately. You cannot control for everything.

Q622 Martin Caton: Particularly with the widespread use of neonicotinoids-

Professor Boyd: Absolutely.

Martin Caton: That brings me to this: we took expert evidence from someone who told us that a meaningful field study on bumblebees would cost £20 million and take 10 years, just because of the level of the use of neonicotinoids and therefore the fact that they are everywhere.

Professor Boyd: It may well take that amount of time and that amount of resource to do an absolutely complete study on bumblebees. But I would point to the fact that some of those studies have been done on honeybees in the past and came up with no direct effect in the field.

Q623 Martin Caton: Again, we have taken evidence during this inquiry where scientists have told us that the evidence is looking like honeybees are far more robust than a lot of other pollinators, including bumblebees. So I do not think we can just say because we have comparatively lots of evidence on honeybees, we should be complacent about what is happening to bumblebees. With the rate of decline of pollinators in our country it has to be suggested that perhaps the precautionary principle should kick in here.

Professor Boyd: You are absolutely right and there is certainly no complacency. However I think we have to be clear that we cannot test all pollinators to the same extent as honeybees have been tested in the past. The bumblebee studies are difficult to do. I think at my last evidence I said that one of the biggest problems was in translating what has been done in the laboratory into the field. One of the important outputs from the study that was done on bumblebees was that the residue levels in bumblebees in the field were round about one tenth to one hundredth of the dose levels that were being used in laboratory studies. I think that tells us something about the realism of the laboratory studies that are tending to drive the logic with respect to the impact on bumblebees. The reality is that we do need to carry out these field studies. Whether they are over a 20-year period and cost £20 million is a complication but we do need to carry out these studies if we want to come up with definitive outputs.

Q624 Martin Caton: This is my last question. You said at the beginning of responding to this question that the bumblebee study was incomplete. But if we know the control site was contaminated, it is not just incomplete, it is inconclusive and you have to start again, haven’t you?

Professor Boyd: The information is there, the problem is that we have to re-analyse it using a different hypothesis from the one that was originally intended, because of the contamination of the control site. There are methods for doing that but they are post hoc methods and as a result of that the statistical power and the inference you can draw from the study is not as great. But there are methods for doing it and that is what is being applied at the moment.

Martin Caton: Thank you.

Q625 Dr Offord: Good afternoon, gentlemen. When we met back on 12 December I asked some question about the UK National Action Plan on the sustainable use of pesticides. During that evidence session I asked the Minister why the Action Plan had not been published at that point. Reading back through the minutes, the Minister said, "We are finalising our consideration of the responses to the consultation and the UK plan will be published shortly". I am aware that the Department published the plan yesterday. Could you please tell us why there was a delay of two and a half months?

Lord de Mauley: The important thing was to ensure that the National Action Plan clearly sets out our position and that it meets the requirements of the directive. It is a record of measures and intentions and so I think it is fair to say that a hiatus in completing it does not mean a hiatus in action on pesticides.

I think it is also fair to say that work on the National Action Plan could have proceeded more rapidly if it had not also been necessary to deal with the important issues raised on neonicotinoids. We took the view that the neonicotinoid work had the priority.

Q626 Dr Offord: My recollection is the description of the word neonicotinoids does not appear at all in the Action Plan.

Lord de Mauley: The safety of neonicotinoids is firstly an issue for the authorisation system: should these chemicals be permitted? The National Action Plan is about how to minimise impacts from the use of authorised products. A number of initiatives under the plan will be relevant, of course, to neonicotinoids as well as to other products.

Q627 Dr Offord: Perhaps you could illustrate to us what the substantive differences are between the plan that was published yesterday and the draft plan that went out for consultation

Lord de Mauley: Is either of you in a position to do that?

Professor Boyd: No, I think we need-

Lord de Mauley: May we respond in writing to that?

Q628 Chair: Given that we have already extended our inquiry by a couple of weeks in order to be able to take further evidence and we were expecting this plan to be published, I think by 26 November, it would be a little bit difficult for us to be able to take account of your response if we delayed further because we have a report to produce. The three of you together perhaps might find a way to answer Dr Offord’s question.

Dave Bench: I will answer, if you like.

Chair: Thank you. Very kind.

Dave Bench: The Action Plan that you have seen published contains broadly the same content as the draft had a little while ago. What we have done in the intervening time is make sure that in relation to the responses we got from the consultation-you can see some of that in the response to the consultation-we have clarified some of the wording in a number of places, not least in the section on integrated pest management, to make it clearer what we need. So in terms of substantive content, is there anything radically different in this draft to what we would have had in draft prior to the Christmas period? No, there is not anything radically different. There are some clarifications, some changes in the wording, to try to meet some of those points that were raised by the consultation responses. The main reason, which the Minister has already raised, is that we have a very small team working on policy in relation to pesticides and they have been almost entirely working on neonicotinoids issues over that period.

Q629 Dr Offord: If there are no substantive differences, as you mentioned, are you concerned that perhaps the consultation was not as effective as it could have been?

Dave Bench: No, I do not think so. I do not think I would accept that contention.

Q630 Dr Offord: Thinking specifically about the content of the UK plan and the directive itself, the directive says. "Member states shall adopt national action plans to set out their quantitative objectives, targets, measures and timetables to reduce risks and impacts of pesticide use". Can you identify any quantitative targets in the plan that you believe will change the use of pesticides in the UK?

Dave Bench: Our position has been for some time that we are not in favour of quantitative reduction targets of that kind of nature because they are generally fairly meaningless. What we are interested in is a range of different activities that encourage, as the UK Government has done for many years, an approach aimed at the minimisation of use of pesticides and their use only when it is appropriate .

Q631 Dr Offord: You kind of promote two further questions. Are you convinced that a UK plan does meet the directive’s requirements then-

Dave Bench: Yes, absolutely, so. Yes.

Dr Offord: -because it explicitly says that it wants to see objective targets and measures?

Dave Bench: One of the things that we do do is make reference to a large number of indicators that we use to track usage progress in relation to risk in general. Some of those measures are proxies for risk. We are very keen to do that and continue to do that.

Another thing that is important to remember about our actions in relation to the National Action Plan is that this is an extension of a national pesticide strategy that we have had in place for many years and that is intended to look at many of the areas that are covered by the directive now. The directive’s main intention is to bring up the standards across Europe as a whole. If you do an assessment of where the UK is in relation to all other member states, we are right at the top of that table and therefore it would not make a great deal of sense for us to be trying to write in very prescriptive targets to improve standards further when we already have among the highest standards in Europe.

Q632 Dr Offord: It is interesting you say that. As a supplementary, one of the things that the UK plan does include is improved training for those who apply pesticides but we already have a relatively strong record in that area, so why did you feel that you needed to increase that directive burden?

Dave Bench: We have not. What we have done about the requirements in relation to training is simply change our existing national requirements to meet the very slightly different requirements in the directive. But in large measure what we have attempted to do is to recognise that there has been a very effective training mechanism and arrangements in the UK for a long time and to build on that rather than to rip it apart.

Q633 Dr Offord: My second point from the previous question was that we mentioned particularly alternative use to pesticides. Again, specifically considering the EU directive and its statement that the National Action Plans should encourage the development and introduction of integrated pest management but in the UK plan it simply says, "We will consider what more might be done to help and encourage users in this area". So how will the plan bring about the increased use of integrated pest management in the UK?

Dave Bench: Of course integrated pest management is about much more than just the pesticides legislation, the pesticides strategy. It links into a wide range of policy areas that are the responsibility of Defra. So what we are trying to recognise in relation to this specific plan is that there are these many broader links and we can think about how much more we can do in relation to the pesticides area specifically but there are all sorts of other issues that are both Government-led in relation to agri-environment schemes, for example, or indeed a whole range of industry-led initiatives, not least the various assurance schemes that place a high premium on the use of IPM or ICM, integrated crop management, in the production of produce and livestock.

Q634 Dr Offord: You still have a great deal of influence upon those different stakeholders.

Dave Bench: Yes, we do, and we work with them on a regular basis and will continue to do so, not least through the Pesticides Forum, which is our main regular stakeholder forum on pesticides.

Dr Offord: Okay. Thank you.

Q635 Chair: Minister, can I just go back to the National Action Plan and the lack of timetable and targets in that? Your officials mentioned indicators. But really it is the case, is it not, that indicators are not quantitative targets and that the European directive specifically says that there should be a timetable and that there should be targets? How are the two compatible?

Lord de Mauley: Can I ask you to answer that, Dave?

Dave Bench: Sure. Again, under the way that the directive is set up, it requires us to have a national action plan.

Q636 Chair: Is that an optional?

Dave Bench: No: it says that we have to have a national action plan. So the obligation is to have a national action plan. It suggests a range of different things that member states can put into that national action plan. Now we believe, and have checked with our lawyers, that what we have put into the National Action Plan-which of course is intended to be an ongoing, developing document; not static-is compliant with the requirements of the directive.

Q637 Chair: I cannot help but think in view of that response, Minister-it was the phrase, "having checked with our lawyers"-that it sounds as though you are trying to get by with the lowest common denominator.

Dave Bench: Absolutely not. As I have said, in relation to many of the areas covered by the directive and indeed beyond the areas of the directive, the UK has amongst the highest standards in Europe already. What we are intending to do within the plan, as in previous national pesticide strategies, is to reflect those activities and the way that the statutory and non-statutory initiatives fit together.

Q638 Martin Caton: Mr Bench, you are saying that the directive says that you can use various tools within the action plan, but from our reading-and Dr Offord has made this point perfectly clear-the directive absolutely says that the action plan should include quantitative objectives, targets, measures, and timetables. It says on the integrated pest management that the National Action Plans should encourage the development and introduction of integrated pest management. You just seem to be cherry picking things that are not suggestions or possibilities; they are things that the directive wants to see.

Dave Bench: Directives of course are purposive, they are drafted in a way that sets out what the Commission intends; the Government policy is to implement directives as they are required, not to go beyond the requirements of directives. We, in this area, very much had the intent of building within the National Action Plan the various initiatives that we already had in place; we didn’t want to change things for the sake of changing things, where we have good mechanisms that work well. We have added in new mechanisms where the directive has required those, although those are relatively few and far between. What we have done is take the opportunity to bring all of those initiatives into one document. But it is in essence an overview of a whole range of initiatives and all of the detail of those initiatives does not appear in the document itself, and nor did we intend it to.

Q639 Martin Caton: So does the action plan explain why the UK Government has decided not to follow the approach that the directive wanted to see?

Dave Bench: We believe we have followed the requirements of the directive. We believe that it is compliant.

Q640 Chair: I think it is just raising more questions as we receive the responses. Just going back to the National Action Plan, where it says that more work is needed in terms of integrated pest control, I just wonder what it is that is missing and why that work could not have been done in time for when the National Action Plan was actually published. I am talking about pages 25 and 26, paragraph 16.2.

Lord de Mauley: Mr Bench did explain that this is a working, onmoving, iterative process. Did you want to say more about that?

Dave Bench: Yes. That is exactly right. The point that I made was that what we are intending to do here is to give a flavour of the current position and where there is likely to be further work to do. As I explained specifically in relation to IPM, this is an area where there is some locus in relation to pesticide policy and the usage of the pesticides regulatory regime, but there are a much wider range of Defra policies that tie in to the way in which you might promote and encourage the use of IPM or ICM, or however you want to define it. Much of that is linked to incentivisation through the use of agri-environment schemes, for example, or other guidance in other areas of agricultural policy that is not specifically about pesticides policy.

Q641 Chair: Just finally from me now on this, could I just say in that respect, given that the plan was due on November 26, as Dr Offord reminded us, it was published late just before our meeting today. Does this mean, in view of what you have just said about the continuing work, the integrated pest control, that the plan is incomplete?

Dave Bench: No, I don’t believe it is an incomplete plan.

Chair: It is complete, although it needs more done?

Dave Bench: It was never intended to be a document that would be published and then fixed at that point in time. It has always been intended to provide a snapshot of how we see the position at this point in time and then for it to be developed on an ongoing basis in future.

Q642 Martin Caton: So an action plan is not a plan for action?

Dave Bench: The terminology of an action plan is that which is used in the directive, and that is reflected here. If you wanted to use a different definition of plan, then that would be okay, but it is called National Action Plan because that is what the directive requires and the contents within are the things that are covered by the directive.

Q643 Chair: Did you consult your lawyers about that?

Dave Bench: No.

Q644 Zac Goldsmith: Just before I come to the question I was going to ask, can I go back to the point that Peter Aldous was asking about, the ACP and its advice. I think, Professor Boyd, you said the two people whose advice differed with the majority were the former members. Is it therefore the case that all the existing members took a unanimous position? Was there unanimity there in terms of their view or was it also split among existing members?

Professor Boyd: I think it is probably for the ACP to answer that, not me. I was there simply as an observer because I wanted to learn about their processes. Because of the way the meeting worked, it is not done on a majority voting system, it is done on a consensus system, what I would say is that the rest of the committee seemed to come to a consensus about their view and agree that view.

Q645 Zac Goldsmith: But if that is the case, how do you record the fact that the two former members took a different view, and rejected the consensus of the members? How is that formally recorded?

Professor Boyd: The Chair agreed to formally record those views of those individuals.

Q646 Zac Goldsmith: So among existing members there were no requests for formal recognition of differences of opinions?

Professor Boyd: Not that I saw.

Q647 Zac Goldsmith: That wasn’t the question I was going to ask, I just wanted clarity on that. A question for the Minister. On 12 December when we had our last session with you, we talked about home gardeners and whether or not they need access to neonicotinoid pesticides; since then Wickes and B&Q have both voluntarily removed these products from their shelves. I am just interested to know whether or not you welcome that move and whether you would like to see other retailers follow suit?

Lord de Mauley: I think it is not really for me specifically to welcome or otherwise. I am aware they have done it. As we discussed at the last meeting, in fact the pesticides that are authorised for sale to home users are considerably less powerful anyway, they contain clear instructions on their use and they pass the necessary regulatory tests.

Q648 Zac Goldsmith: Do you think therefore that they have over-reacted?

Lord de Mauley: I think that would not be for me to comment.

Q649 Zac Goldsmith: When you gave evidence in December, I just want to quote what you said about the precautionary principle. You said, "Defra fully accepts that the precautionary principle applies to decisions on the regulation of pesticides". In this case, you have two big retailers who have exercised the precautionary principle themselves; I am just interested to hear from you why it is such a stretch then for Defra to adopt a similar position, to take the precautionary principle as seriously as some of these front-line retailers are managing to do?

Lord de Mauley: As I said before, we accept the precautionary principle; perhaps it is a question of how you interpret it. We think that steps must be taken that are proportionate.

Q650 Zac Goldsmith: Does that mean, therefore, that you think the retailers-given that they are dealing with products on a lower level of toxicity-have exceeded the precautionary principle, that their action has not been proportionate?

Lord de Mauley: As I say, that is a matter for them.

Q651 Zac Goldsmith: Did the ACP’s advice to Ministers on neonicotinoids cover domestic gardening? I think Mr Bench said it was going to.

Dave Bench: Yes. What I said when we gave evidence back in December was that previous discussions within the ACP on neonicotinoids had included discussions in relation to amateur use. That did not turn out to be a specific focus of the discussion in January, and the key area of discussion ended up being the two new studies from the Food and Environment Research Agency and the implications of those. It was on that there was this difference of opinion, which wasn’t a difference of opinion in terms of the potential implications of the studies; it was in terms of the potential timing of any action in relation to the conclusions. That was the alternative view that the two former members were posing. The majority of the discussion was around that area and there was no separate discrete discussion in relation to amateur products.

Q652 Zac Goldsmith: So was there no relevant conclusion at all drawn by the ACP in relation to amateur users?

Dave Bench: Except in so far as in the documents that they had available to them had an analysis in relation to the different existing uses, which mostly, of course, focused on the agricultural uses, and they homed in on the fact that where there are areas of concern, and should the possible concerns highlighted by the FERA work be borne out by further analysis, that their areas of concern related to large scale crops attractive to bees, and that they would not be recommending action in relation to smaller scale crops or, obviously, crops not attractive to bees. I would have to go back and check whether it was explicit there, but implicit within that part of the discussion was the fact that I do not believe that they were as concerned for amateur crops as they were for bee attractive large scale crops, like oil seed rape.

Q653 Zac Goldsmith: It has been suggested by a number of people that if neonicotinoids were entirely withdrawn, either compulsorily or voluntarily, from the amateur market, you would be creating very large areas that are highly neonicotinoid free. Given the discussion, as with Mr Caton, about the problems you have with the control groups in the FERA study, you would therefore be creating an opportunity to have much purer analysis of the effect of neonicotinoids or the lack of neonicotinoids on pollinators. From an experimental point of view, in terms of filling in some of the gaps that you began the session by talking about, is that not something that would be of enormous value?

Dave Bench: Ian may well wish to comment in terms of experimental design, but I think what you are essentially proposing is a very different kind of experiment from one that would look at whether wide-scale agricultural use on bee attractive crops is of any serious risk to bees, be that honeybees, bumblebees or solitary bees.

Q654 Zac Goldsmith: I would love to have your answer, just from the scientific point of view, but it is not just scientific. I don’t think anyone doubts that there are risks at the very least associated with the use of neonicotinoids, that there is some impact on the pollinators, that is the nature of the pesticide in any case, so there must be some impact. I understand the point you made earlier on, Minister, about balancing those risks with the economic risks of removing the product. That tension would not exist among amateur users; it is hard to imagine what economic downside there would be to withdrawing the neonicotinoids from amateur users. That tension, therefore, doesn’t obviously exist. I wonder whether therefore, for now at least, you would consider a two-tier approach; one which allows you to take into account the very real threats with the use of neonicotinoids and the damage it does to pollinators, by starting in urban areas, for example. Creating these very large areas that would be entirely neonicotinoid free. Is there any argument against that?

Professor Boyd: Can I say that the argument against that is an evidential one. There actually is no strong evidence to support the hypothesis that the use of neonicotinoids in those circumstances is significantly detrimental to bees.

Zac Goldsmith: Generally speaking?

Professor Boyd: Generally speaking. You are absolutely correct to say that because these are toxic chemicals, they will affect bees in some way or other. The question is whether that is significant at the population level. We do not have evidence to support that hypothesis as it stands at the moment.

Q655 Zac Goldsmith: I find that puzzling. We have had stacks of evidence and other Governments have seen enough evidence to convince them to apply the precautionary principle. There are stacks of evidence that there is a detrimental impact on pollinators. I understood the issue to be a question of balancing that against the economic risks of removal. I don’t think anyone doubts that the risk is there; therefore it ought to be much easier, much less cumbersome for Ministers to make a decision in favour of the precautionary principle, where you don’t have that tension. It seems to me that the threshold that Defra wants to apply in relation to the precautionary principle is so high that it can almost never be reached. Where there is no economic tension, surely that threshold can be lowered. Maybe it is a political question.

Professor Boyd: I cannot comment on the economic tension, but I can comment on the evidence that is available and I would dispute what you said about stacks of evidence. There is a lot of evidence from laboratory studies that show that these neurotoxic chemicals for insects are harmful to bees when delivered in doses that are higher than we measure in the field, as far as we can see so far. That is not surprising. The real question is: are they toxic to bees in the field at the kind of doses that bees actually experience? The evidence to date does not support that. So I have to be absolutely clear about this. If we see evidence that supports that, then I am sure the Minister will act on that very quickly. But at the moment we do not see that evidence. It is not without having looked for it, as well.

Q656 Chair: Before we move on, Professor Boyd, could you just say in terms of what you have just said, the evidence that you are referring to, are you talking to evidence in the UK, or are you talking to evidence worldwide?

Professor Boyd: I am talking to the totality of the evidence that we have available to us; the scientifically verifiable evidence that we have available to us.

Chair: I was just trying to check exactly what evidence you were referring to, and that would include evidence that has come from France?

Professor Boyd: Yes.

Chair: You would take that into account?

Professor Boyd: Yes, absolutely.

Q657 Zac Goldsmith: Nevertheless, and this is probably not the time to argue about the evidence, but there are plenty of scientific studies out that point to problems-enough problems that EFSA issued the guidance that it did, that France has taken the position it did, that a great many scientists are calling for moratorium. I don’t think there can be argument about that. The question really is for the Minister, given that we are facing a crisis in terms of the collapse of pollinators-that is also undeniable-the trends, if they continue, head in a very unpleasant direction. Given that neonicotinoids at the moment are a culprit, a potential culprit, and there is a lot of evidence to suggest that it is a very significant culprit, my question to you then is: does it not make sense, at least within the context of amateur users, within the context of large urban areas, to pull the plug on neonicotinoids to enable you to gather the science that you need and potentially also to create a safe haven for some of our pollinators? Does the precautionary principle not justify that at this stage?

Lord de Mauley: Clearly, we consider all these issues extremely carefully. As I am advised by the scientists who advise me, we do not consider that neonicotinoids are the major pressure on bees and pollinators. There are a number of other things that they have to contend with and which make their lives very difficult. My advice is that it is a finely balanced judgment, but the political position we take is that we don’t regulate until it is appropriate to do so, and we do not yet consider it is appropriate to do so.

Q658 Zac Goldsmith: Last question. What I am interested in is why you would use the same language to describe the tension between the pros and the cons of implementing a moratorium in relation to urban environments, amateur users, as you would to conventional users. We can all recognise that there is a very significant economic question mark over the implications of removing neonicotinoids from commercial agriculture. It is very hard to see the economic downside of removing neonicotinoids from amateur users, and therefore if it is finely balanced-the decision you have to take in relation to the conventional use of neonicotinoids-surely that balance tips very much more heavily in favour of the precautionary principle in the context of amateur users given that you don’t have such a strong economic case? If it is finely balanced in relation to the former, necessarily it cannot be finely balanced in relation to the urban environment.

Lord de Mauley: I don’t know that I would accept that contention. I have to say, I have not spent a lot of time considering that specific point, but it may well be that there are some economic issues in urban use.

Professor Boyd: If I can just add to what the Minister said, I think there are some economic downsides from the point of view of the horticultural industry. If you were including the horticultural industry in what you are saying there, then from the point of view of managing pests within garden centres and places like that, there are probably some economic downsides. It is difficult to estimate those, but they probably exist.

Zac Goldsmith: Just for the record, I am not suggesting there are no economic downsides, but I am suggesting they cannot be that significant given that the two big retail players in this field have voluntarily removed them from the shelves. They would not do that if they were unable to provide consumers with some kind of alternative.

Professor Boyd: Again, it is a matter of assessing what the cost benefit trade-offs are here. What we don’t know is how important gardens and garden centres are for bees. They may be very important, they may not be important. It is a matter of getting those cost benefit trade-offs correct, and we don’t have that information, I’m afraid.

Zac Goldsmith: Okay, thank you.

Q659 Peter Aldous: If we could just look at a little detail on the soil accumulation tests on imidacloprid, which led to its approval as an active substance in the EU. I think I am directing these questions at Professor Boyd and Mr Bench. You were kind enough to write to us after the 12 December evidence session, setting out Defra’s view on how imidacloprid was approved for use in the European Union. In that letter you pointed out the UK soil accumulation study, which indicated that imidacloprid has a half-life in soil of 1300 days, which was a worst case scenario, because it involved material being reincorporated into the ground, rather than being harvested. Approximately 50% of stem and leaf material produced by oil seed rape cannot be harvested, and is normally ploughed back into the ground. With that point in mind, would you still maintain that the UK trial was a worst case scenario?

Professor Boyd: Certainly at the time it was done, it was probably a worst case scenario for barley-I think that was the crop that it was applied to. It is perfectly possible that some of those studies need to be repeated, but I would also point out that imidacloprid is used very little now in the UK. There would again be a cost benefit trade-off about doing those studies, because to be honest it is used very little. It may become more of a moot point than a practical one as to whether one wants to really get a final definition of what the soil accumulation rates are for that chemical.

Q660 Peter Aldous: Your letter also asserted that imidacloprid met the requirements of the EC directive 91/414/EEC, which was enforced in the 1990s and which has since been superseded, your letter omitted to mention that the regulation included a catchall provision that approved substances should have "no unacceptable influence on the environment". Do you therefore think that the half-life in soil of 1,300 days is environmentally acceptable?

Dave Bench: What I would say is that I think we have become a little bogged down in this one study giving you a half-life value of that, and I think that the Bayer person who gave evidence to you at a recent session indicated that at the time that study was initiated in the early 1990s, these studies were not well developed, the ways in which the studies were done were not well developed, so different methodologies were being tried to see what happened to develop standard tests. Certainly, the way that barley study was done in the 1990s would not be recognised now as a standard method of deriving a half-life in soil. What is also true is if you look at the range of different accumulation and dissipation studies for imidacloprid and other neonicotinoids, you do end up with a range of different half-life values derived. Many of them are in the hundreds of days, and you would describe a compound that has a half-life of hundreds of days as somewhat persistent or moderately persistent-it certainly has persistent as part of its profile. The question then is having established that there is that persistence for a compound, is given the other aspects of its profile is that then considered to be an acceptable risk profile in the way that it is used, and it would be expected to degrade or you accumulate and plateau in any particular agricultural situation. Those issues were considered both through the European process and will be considered again when imidacloprid products are re-registered in the next year or so. Also, they were discussed by the ACP when imidacloprid was considered on a national basis prior to the consideration of the European process.

This issue of persistence has been fully known and acknowledged for both imidacloprid and the other neonicotinoids as the active substances have been considered both at European and national level, and that has been taken into account in the risk assessment and risk management approaches.

Q661 Chair: Just on that, you referred a response to Mr Aldous’ question to one study, but in fact there were two studies, weren’t there? The fact that there were two studies is important because they actually formed the basis of the regulatory authorisation for the use of neonicotinoids in the first instance. That is surely why these two studies are so important, because that was part of the authorisation process.

Dave Bench: They certainly formed the basis of that initial consideration and of course EFSA, when they did their assessment, have considered the persistence issue. When imidacloprid was first considered, of course what they pointed out was that there were some elements in which they could not complete the risk assessment at that point in time and said that member states would need to be aware of that and take that into account when reaching decisions. Ultimately, the Commission decision also said the same thing.

Chair: All right.

Q662 Peter Aldous: Looking at it more widely and more globally, are you confident that a regulatory system, or regime, that entails conducting trials, identifying concerns and then actually doing nothing about those concerns, as happened in the case of imidacloprid, is fit for purpose?

Dave Bench: I don’t accept the contention that nothing happened in relation to those studies. The conclusions that EFSA reached in relation to those studies were published and known; the Commission understood and knew of that assessment when they made their first inclusion decision proposal. The inclusion decision, in the way the system works, was for a protected use and that allowed inclusion on annexe 1 of the then directive, and then further uses are then for member states to consider, but taking into account what is known and making sure that they consider any of those outstanding issues in considering authorisation to the different uses. I don’t accept the contention that the information was either not known or not acted upon.

Chair: Professor Boyd, would you like to comment?

Professor Boyd: I would agree with Dave Bench.

Q663 Dr Offord: Minister, I particularly want to ask you this question, there are certain factors that are considered, or we should consider, in the continuing use of neonicotinoids-economic issues, agriculture issues-and also a concern that an alternative pesticide may cause more environmental damage than possibly neonicotinoids might. But are there any other considerations that we should consider or arguments in favour of continued use of neonicotinoids?

Lord de Mauley: Those are the principal ones that I can think of, can you think of additional ones?

Professor Boyd: I can think of a very general one, which is that neonicotinoids represent a very significant technological solution to a significant agricultural problem, not just in the UK, but around the world. We have to be very careful about throwing away those technologies. They take many hundreds of millions of pounds to develop; the companies that develop them are simply not going to develop alternatives and invest in those alternatives if we decide on a whim to ban their use. We may be faced, if we are not careful, with a market failure with respect to this, in that we may not have alternatives. I think it is well known that our agricultural systems are highly dependent on these types of inputs-fertilisers, herbicides, pesticides, of various different types. So we have to be extraordinarily careful in not inducing a response which is one that we would not have expected in the long run as a result of regulating without very good and strong evidence.

Q664 Dr Offord: Thank you, that is very useful. Both Bayer and ACP told us that the use of imidacloprid in the UK has declined rapidly in recent years, particularly as farmers have started to use alternative pesticides. Given the concerns about the use of the chemical, and the fact that it has a limited usage and a decline in economic and agricultural value, would you consider withdrawal of the use of that chemical, and what would the time frame be on that?

Lord de Mauley: It is part of all the consideration that is going on; we haven’t got there yet. We consider these things very carefully.

Professor Boyd: I think it would be fair to say, again, that withdrawal of that chemical would really only be done on an evidential basis, and it might be fair to say that the cost benefit trade-off associated with the withdrawal of that particular chemical would be more favourable than for some of the other chemicals. But one still needs to base that, in my view-and I am a scientist-on evidence and overall I think we have, at best, equivocal evidence, even for that chemical.

Dr Offord: I think that answers my questions.

Q665 Martin Caton: Professor Boyd, you seem to have just said that an important factor we should take into consideration when considering whether we allow the continued use of, say, neonicotinoids, but I suspect it would apply to other things, is its impact on the agrochemical industry and its preparedness to continue to do research and develop new products. Surely that should not be taken into account. Surely that is against the spirit, and probably the word, of the directives applicable in these sorts of case.

Professor Boyd: I don’t think it is taken into account explicitly. What I am saying, I am giving you the benefit of my advice as a scientist looking in on this problem, is that because of the need for the world to grow more food in future, which is evidentially the case, evidentially true, we need to use all the technologies we have in the toolbox. As a result of that, we have to be very careful about the kind of decisions we make and make sure they are based upon good evidence. I am not saying that if the evidence is there we should not act, we should act, and I am not saying you put that into the cost benefit trade-off, but I am saying that we need to take a very precautionary overall view of the kind of approach we take to this and not react too quickly to circumstantial evidence.

Q666 Martin Caton: Those words suggest that you apply the precautionary principle to defend the economic interests of agricultures and the agrochemical industry, instead of applying it as it should be applied to protect the environment.

Professor Boyd: I’m not protecting the economic interests of the agrochemical industry. I want to absolutely refute that in the strongest possible way. What I am doing is trying to protect the long term agricultural productivity of this country and elsewhere as well. If we take these sorts of decisions without good evidence, then we will eventually reduce the productivity of our agriculture, and that is not a good thing for us.

Q667 Chair: I would like to ask one final question, if I may, because the National Action Pesticide Plan talks about a greater range of new techniques. In view of what has just been said about the need to get this toolkit for future use, I just wonder how much consideration is being given to funding for other ways of doing that, other than through the companies that you have just referred to, given what you have just said and the comments you have just made. It seems that you have put all your eggs in one basket and that you are not looking at integrated pest control.

Lord de Mauley: I would say that we are pursuing integrated pest management with great keenness. In fact, pesticide users are going to be required to use it from 1 January 2014, and all pesticide users soon will be required to be trained in it, it includes integrated approaches. Of course, many farmers and growers already are familiar with IPM and adopt practices in line with it, but it is certainly something that we are extremely focused on.

Professor Boyd: I would just say that integrated pest management is the future. We have to move in that direction and we have to move as quickly as possible.

Dave Bench: I would also add that within Defra’s crop protection research programme, a very substantial proportion of that for many years has been given over to funding projects looking at alternatives-alternatives in the broadest sense, both in terms of alternatives to chemicals in control of specific problems, but also alternatives in terms of methods of farming or cultivation. Typically, over many years we have spent about a third of the programme funding in that area.

Q668 Chair: In view of the work that the Government is doing on natural capital and the work that the Government is doing to go beyond GDP, and to look at valuing ecosystem services, I just think it would be really helpful to know what work you have done to make sure that the value of bees as pollinators is included in that study and ongoing work at the highest level in Government in that cross cutting way?

Lord de Mauley: I am not sure I can specifically relate it to bees.

Chair: Or pollinators.

Lord de Mauley: The national ecosystem assessment is one initiative that is addressing the matter by, for example, putting a value on pollinators. The gist of this is that a proper appreciation of the value of nature will encourage us all in a responsible approach to drawing on natural capital. I don’t know that I am able to say more than that at the moment.

Q669 Chair: You have taken great pains to talk about the economic value that you assessed of the industry, and I was just interested to know how much you have fed in to that work that is currently going on inside Government on the whole issue of pollinators. Can you let us have details of it in writing if it is not instantly to hand?

Lord de Mauley: Yes, of course I will. I can just say briefly that integral to the economic assessment is the balance between the natural capital value we attribute through the ecosystem-the national ecosystem assessment-to pollinators and the economic value of what might or might not be lost from the crops. It is absolutely integral to the process. Of course I will put something in writing.

Chair: Thank you. Thank you all very much indeed for coming along this afternoon.

Prepared 4th April 2013