Environmental Audit Committee - Pollinators and PesticidesWritten evidence submitted by the Royal Society for the Protection of Birds

Executive Summary

The aim of pesticide policy decisions must be to improve the overall sustainability of pest control. Any actions taken to address current concerns over neonicotinoids must be set in this broader context.

The RSPB is highly concerned by emerging evidence of the impacts of neonicotinoids on pollinating insects. We further believe that the possible environmental impacts of a ban on neonicotinoids must play a key part in any decision to suspend approvals. It is imperative that any regulatory action does not drive farmers to resort to pesticides that are more environmentally damaging overall.

We therefore feel that Government and industry should place a high priority on developing and promoting environmentally-benign alternative means of pest control (both chemical and non-chemical) to replace the use of neonicotinoids. At the same time, research must continue to clarify the impacts on neonicotinoids on pollinators, and to understand how farmer practice might change if these chemicals were banned.

Pesticide usage in the UK is monitored and reported in terms of weight of active substance applied. There is a clear need to develop more direct and realistic ways of assessing pesticide impacts in the field. Lack of evidence does not necessarily imply lack of impacts.

The RSPB believes that the UK policy response to date has been inadequate to address the known environmental risks from pesticide use and does not follow the precautionary principle. The Sustainable Use Directive sets out a clear framework for Member States to reduce the risks of pesticide use by applying an Integrated Pest Management approach (IPM). However, the UK government has failed to take this opportunity to increase support for IPM approaches in the UK.

Introduction

1. The RSPB’s agriculture vision is for sustainable systems of farming that produce adequate supplies of safe, healthy food; protect the natural resources of soil, air and water that farming depends on; help to protect and enhance wildlife and habitats; provide jobs in rural areas and contribute to a diverse rural economy. The RSPB strives to achieve this vision by engaging with agriculture in a variety of ways. Our long-standing science programme includes monitoring farmland bird populations, researching causes of declines and testing solutions. We work with farmers to develop and promote farm management that benefits biodiversity, and with government to develop agricultural policies that support more sustainable farming. We have first-hand experience of the challenges of farming through ownership and running of Hope Farm, a conventional arable farm in Cambridgeshire.

2. The RSPB recognises pesticides as one of a range of tools in both agriculture and conservation land management, but one which must be used appropriately and sparingly due to the associated risks and negative environmental impacts. RSPB believes that the aim of pesticides policy must to be to continually improve the sustainability of pest control. The approvals processes in place at EU and UK level must stringently assess the risks of active substances before allowing them to be used, applying the precautionary principle where data are lacking. Substances that are found to have negative impacts on non-target organisms must be actively phased out according to appropriate timescales, while less harmful alternatives are developed. Pesticides policies must also ensure responsible pesticide use. This includes protecting the most vulnerable sites and habitats (for example sensitive waterbodies, SSSIs) from negative effects of pesticides; and promoting an “Integrated Pest Management” approach in all sectors,1 with reduced reliance on chemical control and incorporation of measures beneficial for biodiversity. We urge that any actions taken to address current concerns over neonicotinoids should be set in this broader context.

3. The RSPB has not undertaken an assessment of Defra’s recent analysis and we are therefore not equipped to comment on the use of evidence in this particular case, for setting policy and regulations on pesticides. However, we would like to comment more generally on current policies on neonicotinoids, as well as the broader questions posed by the Committee on monitoring of pesticide use and alternative methods of pest control.

Policy on Neonicotinoids

4. The RSPB is highly concerned by emerging evidence of the impacts of neonicotinoids on pollinating insects. Such impacts include lethal effects; in particular direct poisoning during drilling of treated seeds;2 and chronic effects of exposure via pollen and nectar of treated plants.3 Researchers have also detected neonicotinoids in non-crop plants growing in the margins of treated fields at concentrations high enough to kill herbivorous insects.4 However, the evidence for population-level impacts on pollinators is still equivocal.5

5. There is an urgent need to fill the gaps in scientific knowledge to understand the impacts of neonicotinoids on pollinators. Nevertheless, the RSPB believes that the current evidence is strong enough that the Government and industry should place a high priority on developing and promoting environmentally-benign alternative means of pest control (both chemical and non-chemical) to replace the use of neonicotinoids.

6. The RSPB believes that the possible environmental impacts of a ban on neonicotinoids must play a key part in any decision to suspend approvals. Current alternatives, such as broad spectrum insecticide sprays, may be equally or more harmful to non-target organisms. It is imperative that any regulatory action does not drive farmers to resort to pesticides that are more environmentally damaging overall. Before changing the rules on neonicotinoids, it is therefore necessary to a) understand how farmer practice would change if neonicotinoids were banned, and the environmental implications of this; and b) actively work towards replacing neonicotinoids with pest management strategies that are known to be less environmentally damaging.

7. The RSPB is supportive of the activities at UK and EU level to carry out further research on neonicotinoids and to review the risk assessment process for bees. We urge the authorities to push forward with these processes and to fully implement any recommendations that arise, as well as continuing to follow closely the research being produced by independent scientists. We suggest that the UK government should also review experiences in other EU countries (France, Germany, Italy and Slovenia) where regulatory action on neonicotinoids has already been taken.

Monitoring of actual levels of pesticide usage, and the extent to which that influences policy on pesticides

8. The Pesticide Forum annual reports6 bring together monitoring information on pesticide use and impacts. Pesticide use is reported in terms of estimated annual usage in tonnes of active substance applied and average inputs per crop (again in kg active substance applied per hectare). The draft National Action Plan on pesticides published by Defra in July 20127 also includes data on the total area treated with pesticides in Great Britain (an indicator which is a multiple of the area of crop grown and the number of times it is treated). However, these metrics are of limited use in assessing the changes in environmental impact of pesticide use over time, because different active substances have different characteristics (for example toxicity to different taxa and persistence in the environment).8

9. There is a clear need to develop more direct and realistic ways of assessing pesticide impacts in the field. A promising new approach using ecological modelling is being pioneered by researchers at the University of Reading.9

10. The indicators of environmental impact reported by the Pesticides Forum include water quality monitoring and population trends in selected bird species. Monitoring shows that pesticides continue to be a major cause of water pollution, with implications for both the aquatic environment and the cost to water companies (and therefore to water customers) of supplying safe drinking water. Populations of birds that depend on farmland habitats continue to decline. Scientific evidence10 implicates the indirect effects of pesticides in the declines of some farmland birds including yellowhammer and corn bunting which have declined by 55% and 89% respectively. However, it is difficult to quantify the link between bird declines and pesticide use, since birds are affected by many other factors as well as pesticides. Most pesticide impacts on birds are indirect, by altering food chains. It would be valuable to also consider data for other taxa (such as certain insect or plant groups) that are more directly affected by pesticide use.

11. The RSPB believes that the UK policy response to date has been inadequate to address the known environmental risks from pesticide use and does not follow the precautionary principle. The precautionary principle allows for a decisive policy response in situations where possible risks are high but evidence is lacking to quantify these risks. The RSPB believes that such evidence as is available on the impacts of pesticides on the environment points to a high level of risk. A lack of quantitative evidence on impacts may point to a lack of research rather than lack of a problem. Although it is vital for policy to be evidence-led, policy makers must be aware of situations where policy can be evidence-limited.

12. The government’s insistence on “no gold plating”11 in its implementation of the Sustainable Use Directive12 has resulted in a missed opportunity to put pest control in the UK on a more sustainable footing. Government’s draft National Action Plan on the sustainable use of pesticides does not propose any new measures nor set any targets or timetables to reduce the negative impacts of pesticides. The RSPB calls for a more proactive implementation of the Sustainable Use Directive that is in keeping with the intention of this Directive to promote a shift to more sustainable pest control practices in farming.

What alternative pest-control measures should be used?

13. The Sustainable Use Directive sets out a clear framework for Member States to reduce the risks of pesticide use by applying an Integrated Pest Management approach (IPM). IPM has the potential to simultaneously improve pest control while helping farming to become more sustainable and resilient overall. From the point of view of individual farmers, it may help them to reduce their costs and avoid or overcome problems of pesticide resistance.13 Some IPM measures can also contribute to biodiversity objectives, for example providing habitat for beneficial insects.14

14. IPM describes an overall approach to pest control and cannot be achieved by implementation of one or two measures in isolation. However, one important set of measures that may be included in a successful IPM strategy is creating and managing habitat for the natural enemies of pest species. Evidence on the success of such approaches was reviewed by Natural England in their recent report on ecosystem services delivered by Environmental Stewardship.15

15. Organic farming aims to avoid the need for pesticides16 through maintaining healthy crops and soil and promoting natural control of pests, and has clear benefits for biodiversity.17 The RSPB wishes to see increased funding for organic farming and more research into organic techniques as part of the strategy for more sustainable farming in the UK. Techniques used in organic farming to minimise chemical use should be incorporated into the IPM toolkit used by conventional farmers.

16. The draft UK National Action Plan states that many users adopt practices that are in line with the principles of IPM. A 2009 report by the Rural Economy and Land Use Programme18 supports the assertion that some measures are widely adopted, but also highlights a lack of uptake of a truly integrated approach making use of the full range of techniques. Effective IPM cannot be delivered by uptake of one or two techniques in isolation.

17. The RSPB calls on government to develop a clear definition of IPM that builds on the principles set out in the Sustainable Use Directive;19 develop crop and sector-specific IPM protocols; and provide extension and outreach services to assist farmers in implementing IPM. The IPM plan currently under development represents an opportunity to achieve many of these outcomes. The plan should offer farmers a clear benchmark for their current performance, along with recommendations to improve and links to the resources available to help with this.

Hope Farm Example

18. The RSPB owns and manages a 181 hectare arable farm in Cambridgeshire,20 known as Hope Farm. Our aim at Hope Farm is to develop, test and demonstrate farming techniques that produce food cost-effectively and benefit wildlife within a conventional arable system. Management of the farm is a continuous process of learning and improvement—we do not claim to have all the answers. We have taken some steps towards IPM on the farm and we intend to develop this approach further.

19. The RSPB has had significant success in increasing levels of biodiversity on the farm since we took over management in 1999. Farmland birds, the most systematically monitored group, have more than doubled in number. Our focus has been on creating sufficient habitat to support sustainable bird populations within the farmed landscape. This includes refuges for insects—margins, hedgerows, beetle banks etc—which should mitigate the negative effects of pesticides and help improve natural pest control.

20. We employ an agronomist to help us decide on the most appropriate pesticides to use, we follow best practice in terms of when and how we apply chemicals, and we minimise our use of pesticides as far as possible within this conventional farming system. For example some years ago we changed our variety of wheat to one that is orange blossom midge resistant, considerably reducing the likelihood of needing to spray insecticides on our wheat crops within the bird breeding season.

21. Data from Hope Farm is being used to develop a model to assess the risks that pesticides pose to skylark populations21 (see also paragraph 9 above). Skylark is a useful indicator species of the effects of pesticides because of it is field-dwelling and therefore vulnerable to agricultural practice such as pesticide application. This makes it a key species for regulatory risk assessments but at present there is no way to fully assess the risks that pesticides pose to skylark populations.

9 November 2012