3 Strategy implementation
24. The draft National Pollinator Strategy
sets out a general approach and principles which will guide the
implementation of 'priority actions' (paragraph 3). It states
that "[t]he case for Government intervening to safeguard
our pollinators is based on a market failure"; the market
does not support the provision of such a public good.[50]
Nevertheless, the implementation of the Strategy,
the draft states, will be mostly based on voluntary action:
We do not intend to introduce unnecessary burdens
or regulations; rather our aim is for the priority actions to
be used as a focus and driver for voluntary action by partners
under the Strategy. We want to inspire action at all levels by
all partners.[51]
25. The draft National Pollinator Strategy
states that "the regulatory environment must maintain a balance
of incentivised, voluntary and regulatory activity" and notes
that, should voluntary measures not deliver, the option of mandatory
requirements would be considered.[52]
The voluntary approach to protecting pollinators is reflected
in the Government's policy on agriculture, Integrated Pest Management
and engaging the public, as we discuss below.
Farming
26. Professor Goulson highlighted the significance
of agriculture for pollinators: "The bulk of the countryside
is farmland and unless that is managed in a way that is sympathetic
to pollinators then we will not solve these problems."[53]
Buglife wanted a commitment in the Pollinator Strategy to a "coherent
network of pollinator habitats", including flower-rich meadows
in the countryside.[54]
The 'priority actions' on agriculture in the draft Strategy
include:
· two
voluntary activities for collecting information—securing
a commitment from agricultural advisers to include the 'call to
action' package in information for farmers and a programme of
'pro-pollinator events' delivered by the Campaign for the Farmed
Environment initiative; and
· a commitment
to "ensure pollinators represent a key focus of the ongoing
implementation of CAP reform,"[55]
supplemented by a commitment to distributing information on Integrated
Pest Management (paragraph 32).
27. The reliance on voluntary measures in the draft
National Pollinator Strategy was a cause for concern for
many of our witnesses. Professor Goulson told us that
I cannot see any farmer changing their behaviour
on the basis of a bit of extra advice on the Defra webpage …
and it is very unclear to me how what is in the document is going
to change anything at all in terms of farming.[56]
Friends of the Earth believed that existing schemes—including
the Campaign for the Farmed Environment and the Pesticides Voluntary
Initiative—offered "mere tinkering around the edges"
where a more fundamental transformation (such as, for example,
diversifying crops) was needed.[57]
Wildlife and Countryside Link concluded that:
The [National Pollinator Strategy] is
overly reliant on simply supplying people with information. This
will not be enough to stimulate action in all sectors. Little
focus has been given to how Government can ensure delivery on
the ground, for example by providing incentives or funding, or
enforcing regulation.[58]
The RSPB calculated that half of the targets in the
voluntary Campaign for the Farmed Environment had not been achieved,[59]
and the Women's Institute similarly saw voluntary schemes as "flimsy
vessels for implementing policy".[60]
28. The CLA and NFU, on the other hand, objected
to the prospect of new regulatory measures. The CLA were concerned
that regulatory measures would result in low-quality outcomes
because of a lack of farmers' ownership of the initiatives.[61]
They favoured a mixture of voluntary and incentivised schemes.
The NFU told us that the Campaign for the Farmed Environment had
resulted in 677,000 hectares of environmentally-focussed land
measures,[62] but that
on their own voluntary measures would not be sufficient:
Increasing the uptake of measures for pollinators
on farmland through voluntary measures alone is going to be extremely
challenging for the industry. Maintaining existing measures and
creating new measures has a cost. Farming and growing businesses
have limited ability to absorb such additional costs, as they
have limited or no ability to push additional costs further down
the supply chain.[63]
The CLA similarly stated that if more than voluntary
measures were needed, the uptake of pollinator-friendly measures
should be incentivised:
Farmers have a role to play in providing for
pollinators, but in order for this to be possible there must be
sufficient incentives for them to do so. With paid environmental
measures comes an increased level of quality. The design of agri-environment
schemes therefore has a vital role to play, along with the formation
of private methods for paying for biodiversity.[64]
29. The main 'incentives' currently come from the
Common Agricultural Policy (CAP). In our report on Pollinators
and Pesticides, we looked to the then ongoing CAP reform negotiations
to offer an opportunity for more pollinator-friendly programmes.[65]
The recently agreed CAP scheme incorporates, as was envisaged,
direct 'Pillar 1' payments which are partly dependent on the adoption
of 'greening' measures. 'Pillar 2', co-funded by the EU and national
governments, offers additional payments to farmers for initiatives
contributing to rural development, including environmentally friendly
schemes. As a result, payments for pollinator-friendly initiatives
can be for 'Ecological Focus Areas' (EFAs) under Pillar 1[66]
and for 'New Environmental Lands Management Schemes' under Pillar
2. Specific options for EFAs were left to member states to determine,
and in June 2014 Defra announced that these would include:
land lying fallow; buffer strips; 'catch and cover' crops; hedges;
and nitrogen-fixing crops such as peas and beans.[67]
The European Commission has undertaken to review the implementation
and efficacy of EFAs after the first year of operation.[68]
30. Our witnesses were sceptical of the CAP measures'
potential to deliver pollinator-friendly outcomes. The CLA told
us that the dwindling resources of CAP did not guarantee desirable
outcomes, and the NFU considered that the lack of pollinator-specific
measures was a wasted opportunity.[69]
Friends of the Earth told us that "reliance on current measures
proposed in the CAP will not be enough. … The take up of
CAP options, whether [New Environmental Lands Management Schemes]
or Greening, will need to be vigorously encouraged."[70]
31. The CAP reforms were an opportunity for farming
to lead the way in supporting pollinators. The way that Defra
is structuring the environmental schemes within the CAP, however,
risks that opportunity being lost. The Government must review
the aspects of CAP environmental schemes which are open to national
decision-making to ensure that pollinator protection is a priority
driver rather than an optional rationale. It should also ensure
that the European Commission's review of the implementation and
efficacy of Ecological Focus Areas after their first year of operation
applies a similar test.
Pollinators and Integrated Pest
Management
32. The draft National Pollinator Strategy
contains three 'priority actions' aimed at increasing the uptake
of Integrated Pest Management (IPM) among farmers. It explains
that:
Increased uptake of IPM would help achieve a
more targeted and risk-based approach to managing pests, weeds
and diseases, with potential benefits for pollinators and other
wildlife.[71]
In the draft Strategy, the definition of IPM
is based on the Sustainable Use of Pesticides Directive:
the careful consideration of all available plant
protection methods, and subsequent integration of appropriate
measures that discourage the development of populations of harmful
organisms and keep the use of plant protection products and other
forms of intervention to levels that are economically and ecologically
justified and reduce or minimise risks to human health and the
environment. 'Integrated pest management' emphasises the growth
of a healthy crop with the least possible disruption to agro-ecosystems
and encourages natural pest control mechanisms.[72]
The draft Strategy explains that:
Integrated pest management does not prohibit
pesticide use but draws on a full range of tools and techniques
to control pests, weeds and diseases and to ensure targeted use
of pesticides to minimise risks to the environment. It is a toolkit
for combining effective crop protection with a full awareness
of potential environmental impacts.[73]
33. This differed from the apparently more pesticide-averse
perspective of the UN Food and Agriculture Organisation, which
describes "specific and targeted application of pesticides
as a last resort".[74]
The Worldwide Integrated Assessment review of past studies
on pesticides concluded that "the present scale of use of
neonicotinoids is not a sustainable pest management approach …
[because] the current practice of seed treatment … applies
chemicals as the first resort".[75]
Our witnesses highlighted particular problems in the UK: there
was little consensus about what constituted IPM, and that allowed
a range of views on the appropriate emphasis that should be placed
on reducing pesticide use.[76]
Friends of the Earth wanted Defra to provide greater clarity:
There needs to be a much clearer commitment in
the final National Pollinator Strategy to develop specific
IPM crop protocols—starting with crops attractive to pollinators.
This would benefit farmers adjusting to the restrictions on neonicotinoids
as well as targeting crops visited by insect pollinators. The
National Pollinator Strategy overly focusses on the temporary
restrictions on some neonicotinoids. It would do better to start
supporting researchers to find and farmers and growers to use
alternatives to these insecticides.[77]
34. The Government's National Action Plan for
the Sustainable Use of Pesticides, adopted in February 2013
to fulfil the requirements of the EU's Sustainable Use Directive,
reflects "the priorities of the Government, particularly
in reducing the burdens on business and reducing the costs, and,
where appropriate, the activities of Government".[78]
It accordingly focuses on voluntary measures, including the Voluntary
Initiative for pesticides and the Amenity Forum. The Action
Plan does not contain an explicit commitment to reducing the
use of pesticides, but rather "reducing risks of pesticide
use" and "encouraging" the development of non-chemical
alternatives.[79] The
EU Sustainable Use of Pesticides Directive requires that "states
should promote low pesticide-input pest management",[80]
and Friends of the Earth wanted the National Pollinator Strategy
to include targets for reducing pesticide use.[81]
35. While Integrated Pest Management does not
mean an end to the use of pesticides, it offers a way to reduce
their application and the risks they present to pollinators. Defra
should present in the finalised Pollinator Strategy a clear view
of what Integrated Pest Management includes and excludes, and
ensure its interpretation of IPM reflects best practice elsewhere,
including the UN guidance. The Strategy should also set out how
potential targets for IPM, including for reduced pesticide use,
could build on a research-led, evolving understanding of the factors
affecting pollinators.
Engaging the public
36. The draft National Pollinator Strategy
envisages members of the public having an important role to play
in supporting pollinators. Defra told us that it was "keen
to engage the public on the call to action". It set out a
dual approach to engagement: a combination of identifying simple
actions that individuals could undertake and providing detailed
guidance tailored to different types of land use.[82]
The intended advice for the public identified in the draft National
Pollinator Strategy was based on three major initiatives:
growing more pollen- and nectar-providing plants; leaving patches
of land growing wild; and careful consideration of pesticide use
in private gardens and amenities.[83]
In its subsequent oral evidence to our inquiry, Defra officials
explained how this had been fleshed out as a result of the consultation
process for the Strategy.[84]
37. Professor Goulson was sceptical about this aspect
of the Strategy: "There have been umpteen calls for action
on pollinators already. … The public knows about pollinator
declines. I do not see what extra we can easily add."[85]
Pesticide Action Network, on the other hand, saw the Strategy
as a "golden opportunity" to promote non-chemical methods
as the first choice for home and garden use.[86]
In our earlier report, we concluded that there was little need
for the use of pesticides in private gardens, although our recommendation
that Defra ban the use of neonicotinoid pesticides in non-agricultural
surroundings was rejected.[87]
We welcome the Strategy's emphasis on public engagement in
protecting pollinators. It will tap an invaluable and committed
resource, and help lock in continuing pressure on Government to
maintain pro-pollinator initiatives. We welcome Defra's declaration
that the final National Pollinator Strategy will advise the public
to consider alternative, non-pesticide, pest control methods.[88]
Finalising the Pollinator Strategy
38. The publication of the final version of the Strategy
this autumn (paragraph 5) will be followed by a detailed "delivery
plan" within six months.[89]
The finalised Strategy and the 'delivery package' to take it
forward should set out the Government's intended approach in the
areas we have examined in this report: ensuring agriculture plays
a full part in protecting pollinators; the role of Integrated
Pest Management; and how public engagement will be sustained.
It should explain and justify the logic of the predominantly voluntary
approach of the measures in the draft Strategy and identify the
tests for judging if a mandatory or incentivised approach would
be required. The final Strategy should provide a coherent narrative
of how all relevant Government policies will contribute to pollinator
protection—not just other environmental policies within
Defra's remit but those of other departments such as the well-being
agenda[90] and
development planning[91]—and
set out a process for the Strategy to be continually updated as
further research is undertaken and policy developed. In the meantime,
we are undertaking a separate inquiry on an Environmental Scorecard
which seeks to address that wider environmental perspective.
39. Defra should also use the final Strategy to
draw a line under the neonicotinoid ban by making it clear that
the UK accepts the European risk assessments underpinning the
ban, that it supports the ban and will not seek to end it when
a European review is possible in 2015, or otherwise to circumvent
it. Defra should make it clear that applications to continue using
neonicotinoids, like Syngenta's (paragraph 18), would constitute
an attempt to by-pass the precautionary principle rationale behind
the ban and as such will not be contemplated.
50 A consultation on the National Pollinator Strategy: for bees and other pollinators in England,
op cit, para 11 Back
51
Ibid, para 27 Back
52
Ibid, paras 35, 37 Back
53
Q8 Back
54
Q9 Back
55
A consultation on the National Pollinator Strategy: for bees and other pollinators in England,
op cit, para 36 Back
56
Q8 Back
57
Q58 Back
58
Wildlife and Countryside Link (NPS0018), para 3 Back
59
RSPB (NPS0026), para 1 Back
60
Q59 Back
61
CLA (NPS0011), para 13 Back
62
Ibid, paras 13-15; NFU (NPS0007), p2 Back
63
NFU (NPS0007), para 27 Back
64
CLA (NPS0011), para 16 Back
65
Pollinators and Pesticides, op citI, paras 89-91 Back
66
The EFA scheme requires farmers with more than 15 hectares of
arable land to maintain 5% of that land as an Ecological Focus
Area; this will account for 30% of the farmers' subsidy. Back
67
HC Deb, 10 June 2014, col42-43WS Back
68
European Commission, 'Commission Declaration on Delegated Acts of CAP Reform'
(2 April 2014) Back
69
CLA (NPS0011), p2; NFU (NPS0007), paras 22-25 Back
70
Friends of the Earth (NPS0016), p4 Back
71
A consultation on the National Pollinator Strategy: for bees and other pollinators in England,
op cit, para 12 Back
72
Ibid, para 39 Back
73
Ibid, para 40; Directive 2009/128/EC/ of the European Parliament and of the Council: establishing a framework for Community action to achieve the sustainable use of pesticides,
(October 2009), Article 3, para 6 Back
74
Food and Agriculture Organization of the United Nations, More about IPM,
accessed 01 July 2014 Back
75
Van der Sluijs, Goulson et al, Conclusions of the Worldwide Integrated Assessment on the risks of neonicotinoids and fipronil to biodiversity and ecosystem functioning Back
76
Friends of the Earth (NPS0016), para 4; Pesticide Action Network
(NPS0005), para 11 Back
77
Friends of the Earth (NPS0016), p8 Back
78
Department for Food, Environment and Rural Affairs, UK National Action Plan for the Sustainable Use of Pesticides
(February 2013), para 4.1 Back
79
Ibid, para 7.1 Back
80
European Commission, Directive 2009/128/EC/ of the European Parliament and of the Council,
Preamble, para 18 Back
81
Q78 Back
82
Q63 Back
83
A consultation on the National Pollinator Strategy: for bees and other pollinators in England,
op cit, Table 2, p7; Q64 Back
84
Q63 Back
85
Q8 Back
86
Pesticide Action Network (NPS0005), para 7 Back
87
Pollinators and Pesticides, op cit, paras 82-84 Back
88
Q64 Back
89
Defra (NPS0030), para 1 Back
90
Environmental Audit Committee, Fifteenth Report of Session 2013-14,
Well-being, HC59-I Back
91
Environmental Audit Committee, Session 2010-12, Sustainable Development in the National Planning Policy Framework. Oral and Written Evidence,
HC 1480 Back
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