Introduction
1. In 1999, ECOTEC completed a study for DETR on the design of a tax or charge scheme for pesticides and the Treasury issued an invitation to comment on a number of specific issues raised by the report. Following the consultation, the Government concluded that a tax could, in conjunction with other measures, be a useful tool in addressing the environmental impacts of pesticides but decided to explore with the agrochemical industry whether its objectives could be better achieved through a partnership approach.
2. The British Agrochemicals Association (BAA, now the Crop Protection Association) was invited to submit proposals for minimising the environmental impact of pesticides through a package of voluntary measures. These were published on their website on 20 April 2000 and DETR invited over 300 organisations and individuals to express their views on the proposed measures and their likely effectiveness. We targeted those who were consulted on the ECOTEC report and those who have expressed interest in being kept informed of Pesticides Forum activities. In addition, we placed an open invitation to comment on the Pesticides Forum website. Farming and environmental groups, as well as the Association itself, gave publicity to the exercise. Responses were also received from individuals via their MPs. The following analysis includes all replies received up to the end of September 2000.
Specific points for consideration
3. We indicated that the Government's overarching objective is to reduce the environmental impacts of pesticide use*. A number of more specific objectives were identified as components of the main objective:
- to secure reductions in pesticide usage;
- to achieve substitution either by less harmful pesticides or by alternative techniques;
- to increase the efficiency in usage by improved targetting;
- to provide incentives for environmental protection measures to reduce the impact of pesticides in different media.
4. We asked those responding to bear these in mind when commenting on the proposals and to offer views on the likely environmental performance, practicality, and cost effectiveness of each proposal and the package as a whole and the appropriateness of the timescales given.
Responses
Category of respondent
5. We have received 281 responses from the organisations and individuals listed at Annex A. Of these 64 were from those who had been contacted directly. Nearly half came from RSPB members who had been asked to write to their MPs and a further 46 from farms. Thirty responses came from agrochemical companies, distributors and advisors and 17 from environmental and conservation bodies. The detailed breakdown is given in Annex B, Table 1.
Regional distribution of responses
6. For 206 of the responses it was possible to identify the location of the writer. Most of the remainder were from bodies operating at a national level. The breakdown is shown in Annex B, Table 2. Responses from farming related interests were concentrated in the eastern counties, but there was a more even distribution among RSPB members. Six percent of the 206 replies came from Scotland and Northern Ireland (but none from Wales).
Type of response
7. These are summarised in Annex B, Table 3. The largest group of responses (135) came from RSPB members who were supporting the Society's line that the Government should reject the Crop Protection Association's proposals in their proposed form as unlikely to make sufficient difference to pesticide use to benefit wildlife.
8. Thirty six responses (mostly from farmers) made no reference at all to the Association's proposals. They were keen to stress that because of the present economic crisis they could not afford to use more pesticide than was necessary, and that there was a risk of pesticide reductions leading to problems. It was pointed out that ICM has led to very positive environmental benefits and argued that management of pesticides, not use per se, is the issue. The farming industry felt it was responsible and already working to high environmental standards and that the use of pesticides is a key requirement for sustainable production of good quality and affordable food.
9. Fifty one respondents (of whom 21 were employed by pesticide manufacturers and distributors) welcomed the Association's package and gave it fairly unconditional support. A further 21 supported the proposals but suggested there was room for improvement and scope for additional action. In 38 cases the comments included some element of criticism (of which 12 were almost entirely critical). Typical criticisms noted are set out in Annex C under the headings mentioned in paragraph 4 above.
10. A range of additional or alternative measures were proposed by the 59 respondents in the latter two categories mentioned in para 9. These included alternative packages from some of the environmental bodies. Annex D lists over a hundred of the measures suggested, under six main categories. Where more than one respondent suggested the same or a similar measure, it has been entered once only.
*Budget Report 2000 gives the Government's objective as to minimise the environmental impact of pesticides, consistent with adequate crop protection.
Published 8 November 2000
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