Environment Bill

Written Evidence submitted by Pesticide Action Network UK  (EB49)

Environment Bill  


1. Introduction   

1.1. PAN UK is the only UK charity focused on tackling the problems caused by pesticides and promoting safe and sustainable alternatives in agriculture, urban areas, homes and gardens. We have three decades of experience advising governments, parliamentarians and policy makers on how to reduce pesticide-related harms  

1.2. T he Environment Bill is a vital piece of legislation offering an opportunity to maintain high standards around environmental protection with regard to pesticides, but it also presents an opportunity to reduce pesticide-related harms within the UK.   

2. Summary  

2.1. Our evidence concerns two parts of the Bill: Clause 1 and Clause 81.   

2.2. Clause 1: covering environmental targets, where we make the case for a pesticide reduction target being within the scope of a biodiversity target.  

2.3. Clause 81: unless significantly strengthened there is a risk that standards around water quality and chemicals in water could regress.   

3. Clause 1 - target setting framework   

3.1. Setting clearly defined targets for tackling major environmental issues is at the heart of the new Environment Bill. The use of pesticides is one of the major drivers of biodiversity loss and soil and water contamination in the UK. Therefore, setting a target for reducing their use and impact is fully within the scope of the objectives of the Environment Bill.   

3.2. The introduction of a pesticide reduction target would provide an over-arching framework to coordinate the work of multiple stakeholders and ensure that the various measures complement each other and contribute to this common goal.  

3.3. A pesticide reduction target is not a new or novel policy recommendation. A range of countries (including nine EU Member States) already have reduction targets, introduced in response to widespread public concern over the health and environmental impacts of pesticides. ( https://issuu.com/pan-uk/docs/introducing_a_pesticide_reduction_t?fr=sMGUzMTExOTMxNQ )  

3.4. The Government’s 25 Year Environment Plan sets out a clear intention to reduce the impact of pesticides on the environment. In fact, a significant reduction in pesticide use is crucial to the achievement of many of the Plan’s objective. Conversely, a continuation of current levels of pesticide use will hold back the UK’s ability to deliver on many of the Plan’s stated goals. Therefore, creating a mechanism for introducing a pesticide use and impact reduction target within the Environment Bill must be a priority. (P12, 25 Year Environment Plan -  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year-environment-plan.pdf (PAN UK briefing on 25 Year Environment Plan: www.pan-uk.org/25-year-environment-plan/ ),) 

3.5. Numerous models for reduction targets are available and should be considered. However, it is vital that these are paired with effective monitoring systems such as those recommended by former Defra Chief Scientist, Sir Ian Boyd, that would look at the cumulative impacts of pesticide use at a landscape scale. (Toward Pesticidovigilance -  https://science.sciencemag.org/content/357/6357/1232 )  

3.6. PAN UK is recommending that an amendment to Clause 1 Section (3) of the Environment Act be introduced to include a pesticide reduction target as one of the priority areas set out for action.

4. Clause 81- water quality   

4.1. The Government’s 25 Year Environment Plan states an aim to reduce water pollution  but the Environment Bill is yet to reflect this. Clause 81 gives powers to the Secretary of State ( SoS ) to amend water quality laws, but does not state that this would be with the aim of improving water quality.  Clause 81 must be amended to reflect the stated aim to reduce water pollution in the 25 Year Environment Plan.  

4.2. Under the current Environment Bill, specific pesticides (and other chemicals) that are currently subject to strict environmental reporting and monitoring measures under the Water Framework Directive may be amended without appropriate prior consultation with independent scientific experts, civil society or parliament. Note: The pesticides and other pollutants subject to these rules are known as the ‘priority substances list’.   

4.3. To amend  water targets, monitoring and reporting laws or chemical pollutants on the priority substances list, there must be a requirement for the  SoS  to seek scientific advice from the appropriate bodies before doing so .  PAN UK suggests scientific advice is sought from the following bodies: Expert Committee on Pesticides who are an independent body who advise the government on pesticides ( https://www.gov.uk/government/groups/expert-committee-on-pesticides ); UKTAG who have been an independent body consulting on water standards in the WFD ( https://www.wfduk.org/ )  

4.4. To ensure water quality laws are not diminished,  an amendment should be made to the effect that chemical pollutants may be added and targets made more ambitious , but that pollutants cannot be taken off the list of priority substances, nor can standards be weakened (a suggestion also made by NGOs Greener UK and Wildlife & Countryside Link:  https://publications.parliament.uk/pa/cm5801/cmpublic/Environment/memo/EB10.htm )  

4.5. There must also be  parliamentary accountability for any major changes to water quality laws . PAN UK would endorse the insertion of the  ‘super affirmative procedure’ in Clause 81 (9) which would mean that any major changes to water quality standards must be  scrutinised  by the relevant committee- in this case EFRA- as part of the SI process.  

May 2020



Prepared 3rd November 2020