This post is by Matt Shardlow, chief executive of Buglife. It is an extract of a longer piece published by Buglife.
Last Friday, just when journalists were clocking off and the Saturday papers were being compiled for print, Defra announced it would allow farmers to once again use environmentally destructive neonicotinoid seed treatments on sugar beet. This small administrative decision has huge environmental repercussions. It is seen by the public as a bellwether environmental issue, and also highlights profound inadequacies in pesticide decision making. No wonder the announcement was made at the most muffled moment in the government’s weekly media diary.
The clandestine nature of pesticide regulation is a story. George Monbiot recently publicly revealed communications from the NFU urging its members to lobby politicians to secure the temporary use of neonics, but to refrain from “making the letter public” or “sharing on social media”, while keeping it “out of the public domain”.
The process encourages secretive lobbying, the application to use a banned pesticide is secret, along with the associated information purporting to assess the environmental risks and proposed methods for reducing environmental harm. These shady processes now include a big responsibility for pesticide approval, previously done by the European Commission and the European Food Safety Authority. Now is a good time to ask if our regulatory capacity and procedures are up to the task of protecting us and the environment from pesticide harm?
A problem that needs a better solution
Neonics have been shown to contaminate wildflowers growing in field margins, hedgerows and adjacent meadows where they poison bees and other insects. They‘ve caused many bee species to disappear from large areas of the countryside. In addition, there are concerns that birds and mammals will be poisoned if they eat treated seeds. Perhaps most pertinently this particular chemical, when last used on sugar beet, ended up in rivers and streams, causing severe pollution, and exceeding levels that trigger acute and chronic harm to aquatic life.
While these pesticides damage the environment, they do protect sugar beet from aphid transmitted viruses. Problems with the 2020 harvest, when neonics weren’t used, were caused by ineffective aphid control at a crucial point in the spring growth of beet. There is enough science in the public domain to assure us that this is a problem needing a solution.
We can, of course, sympathise with farmers and the sugar processing industry whose yields are being affected. Unfortunately, many now want to fix the problem quickly using a chemical they trust but which scientists know damages the environment.
The environmental impacts are endorsed by Defra
The Expert Committee on Pesticides advised the minister in 2018 that, if use of this insecticide on sugar beet was approved, there would be unacceptable environmental impacts. The application from 2018 is secret, so it is not possible to see if it contained attempts to reduce environmental damage, but there were proposals for environmental mitigation in the 2020 application, that are now apparently endorsed by Defra.
The first of these proposals is for a predictive tool to calculate future virus transmission risks; if the risk is low then seeds will not be treated. If feasible, this would be a reasonable safeguard against completely unnecessary environmental harm. However, as recently as September last year, the Expert Committee on Pesticides recorded that they had “not yet seen evidence that it was predictive”.
Second, there will be a reduced rate of application of the chemical to each seed, the exact reduction does not appear to have been made public, so little can be speculated.
Third, farmers will spray wildflowers “in and around the crop” with herbicides so that their nectar cannot poison insects. If this results in more herbicide use, particularly on field margins, then this habitat destruction will, as noted by the Expert Committee, increase the risk to insects. In fact, if it does not result in a large additional reduction in wildflowers near sugar beet fields, then it cannot reduce the risk posed by the neonicotinoids.
Fourth, farmers will not be allowed to plant flowering crops for the following two years or to plant oilseed rape in the following three years. Neonics can persist in soil and be taken up by subsequent crops and wildflowers. As up to 97 per cent of the neonicotinoids in pollen foraged by honeybees comes through wildflowers, this restriction will reduce exposure of pollinators, but only to a very small degree.
Conspicuously absent from these measures is any hint at how to protect freshwater life. The decision by Defra is not that there will be no environmental impacts from using these pesticides on sugar beet, but that that they consider the environmental impacts to be ‘acceptable’. To protect growers and the processing industry, a decision has therefore been taken to cause environmental harm.
To be fair, this permission is being hailed as a temporary measure, despite the Expert Committee saying in September that the “the industry’s strategy to move away from their reliance on emergency authorisations was not clear”. Defra’s announcement states that a plan is being delivered to develop resistant plant varieties, improve seed germination and introduce new practices for growers. Furthermore, it “anticipates that applications for emergency authorisations for neonicotinoid seed treatments may be needed for three years (2021 to 2023)”.
Fears about secrecy and the influence of the pesticide industry
Without a drive to invest in other solutions, there is a risk that the use of emergency authorisations becomes habitualised. While such decisions by member states are scrutinised by the European Commission and considerable peer pressure is brought to bear, there are no checks or balances here in the UK. The HSE and the Executive Committee on Pesticides are all appointed by Defra, there is no-one to whom a challenge to the legitimacy of an approval decision can be taken. All likely looking bodies for this will have either advised on the decision or have taken the decision. While UK pesticide regulation has been freed from the hands of the EU, the fear is that it will fall behind a curtain of secrecy and into the hands of the pesticide industry.
A neonicotinoid seed treatment is not the only possible answer to the industry’s problem. There are alternative control measures that could potentially manage the problem of viruses, without increasing environmental damage. This includes using improved crop hygiene, crop rotations and natural predators to control virus levels. But none of these options have been proposed, and nor was the option of licencing the emergency use of a less persistent insecticide suggested.
The ExpertCommittee concluded “that there was insufficient evidence and no methodology available to make a judgement” on the costs and benefits of potentially viable “alternative control programmes”. Alternative measures have no sponsor or stake in the pesticide regulation process.
Farmers increasingly want to avoid causing environmental harm, so my first practical suggestion is for the NFU: in future situations like this, start by talking to environmental experts and work out with them if it is possible to first consider non-chemical approaches, that would genuinely minimise environmental harm to a level they would find acceptable. Even if that proves impossible, it could result in measures to mitigate harm that would not otherwise have been considered, and would hopefully avoid situations such as the current one where there are no plans to reduce or manage the harm to rivers. Why, for instance, are there no restrictions proposed on using the insecticide on fields next to water courses?
We don’t know enough about the alternatives
Just two years into the ban, we do not know enough about growing sugar beet without neonics to conclude that we can’t do it. We produced a perfectly decent crop in 2019. Perhaps the government should have announced an experimental approach to improving management of the crop to understand what practices are effective at reducing the viruses? Economic impacts can be managed by economic measures, if we trust a better solution will be found, then why not find a temporary way to economically support the industry, rather than making bees and the environment pay?
Finally, the UK’s secretive pesticide management processes are not fit for purpose. The Aarhus Convention, of which the UK is a signatory, guarantees public access to environmental decisions. But there was no access in this instance. The process should be overhauled and redesigned to be open, transparent, with genuinely independent advice and an appeal process.
Neonicotinoids are yesterday’s technology, known to cause profound environmental harm. This sad decision will damage British pollinating insects and rivers. We can only hope, despite the attempt to bury this news, that its exposure draws attention to an opaque regulatory process that excludes the public from important decisions about environmental protection.