Last Friday afternoon, just when journalists were clocking off and the Saturday papers were being compiled for the printers, Defra announced that they would be allowing farmers to once again use environmentally destructive neonicotinoid seed treatments on Sugar beet. This superficially small administrative decision has huge environmental repercussions, is seen by the public as a bellwether environmental issue, and also highlights profound inadequacies in our pesticide decision making process. No wonder its announcement was aimed at the most muffled moment in the Government’s weekly media diary.
The clandestine nature of pesticide regulation has become a key part of the story, after George Monbiot publicly revealed communications from the NFU hierarchy urging its members to lobby politicians to try to secure a derogation to use neonics but to refrain from “making the letter public” or “sharing on social media”, while keeping it “out of the public domain”.
Secretive lobbying is encouraged by the process, the application to use a banned pesticide is itself secret, along with the associated information purporting to assess the environmental risks and the proposed methods for reducing harm to the environment: so if you are careful no-one might notice your plans, they certainly won’t know what is coming before it hits them. These shaky and secretive processes, that few understand, have just swallowed a big area of pesticide approval responsibility that was previously done at a cost of more than £80M/yr 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 the public from pesticide harm.
The neonicotinoids have been shown to contaminate wildflowers growing in field margins, hedgerows and adjacent meadows where they poison bees and other insects visiting the flowers, causing 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 in rivers such as the Waveney.
While many farmers have not come to terms with just how environmentally damaging neonicotinoid insecticides have been, in this instance the science does not form the basis of the contention. Everyone agrees that neonicotinoids can protect Sugar beet from aphid transmitted viruses, everyone agrees that problems with the 2020 harvest are likely to be linked to there being no effective control of aphids at the crucial point in the spring growth of the beet. For once there is enough science in the public domain to assure us that this is a problem needing a solution. It would appear from the comments made by Defra and their Expert Committee on Pesticides about the derogation application that NFU/British Sugar also acknowledge the harm neonics can cause, otherwise why propose action to reduce harm to pollinators?
We can of course all sympathise with farmers and the associated sugar processing industry, following the ban in 2018 they have had a good year and then a very bad year in terms of yields. Many want to fix the problem quickly using a chemical they trust is effective but that scientists know damages the environment.
The main harms to consider were summarised by the (minister appointed) Expert Committee on Pesticides when they advised the minister in 2018 that, were he to approve such a derogation, there would be unacceptable environmental impacts on:
1) “bees in following crops and flowering plants in field margins”,
2) “Birds and mammals eating seedlings from treated seed and birds consuming pelleted seed” and
3) “populations of aquatic insects” in surface waters.
The 2018 application is also secret, so it is not possible to see if it contained a paucity of attempts to reduce the environmental damage. There were proposals for environmental mitigation in the 2020 derogation application, that are now apparently endorsed by Defra.
Firstly, a predictive tool will be used to calculate future virus risks; if the virus risk is low then the seeds will not be treated. If feasible this would be a reasonable safeguard against completely unnecessary environmental harm. However, it is concerning that as recently as September this year the Expert Committee on Pesticides minuted that they had “not yet seen evidence that it was predictive”.
Secondly, 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.
Thirdly, 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 on Pesticides, increase the risk to insects. If it does not result in more abundant and widespread use of herbicides, then it won’t reduce the risk posed by the neonicotinoids!
Fourthly, farmers will not be allowed to plant flowering crops for the following two years or to plant oilseed rape in the following three years. Neonicotinoids can persist in soil for years and be taken up by subsequent crops and wildflowers, up to 97% of the neonicotinoids in pollen foraged by honeybees comes through the wildflowers, so this restriction will reduce exposure of pollinators to neonicotinoids, but only to a small degree.
Conspicuously absent from the revealed mitigation measures is any hint at how the harm to freshwater life will be avoided. The answer seems to be that it won’t be avoided. Commenting in November on the HSE risk assessment of the application the Expert Committee noted that – “Surface water concentrations may exceed PNEC values established under water quality legislation”, “The risk from following crops has not been shown to be acceptable” and “The risks to birds from consuming treated seeds had not been demonstrated to be acceptable.”
The decision by Defra is not that there will be no environmental impacts from using thiamethoxam on Sugar beet, but that that they consider the environmental impacts to be ‘acceptable’.
To protect Sugar beet growers and the processing industry a decision has been taken to cause environmental harm.
The question is what other options were available, and could any have had lower environmental impacts?
It is fair to note that the derogation is being hailed as a temporary measure, this despite the ECP 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 (secret) plan is already being delivered to develop resistant plant varieties, improve seed germination and introduce new practices for growers. Furthermore “The plan anticipates that applications for emergency authorisations for neonicotinoid seed treatments may be needed for three years (2021 to 2023)”.
In lieu of other operational solutions, there is a risk that the use of a neonicotinoid derogation becomes habitualised and the economic driver for alternatives becomes less attractive to investors. While derogation decisions by Member States are scrutinised by the European Commission and considerable peer pressure brought to play the game properly, this will not happen with this derogation. When asked how the UK would be replicating the EC’s decision reviewing role in pesticide regulation, a Health and Safety Executive officer responded that “those with overall responsibility for the regime are actively engaged in it, unlike the Commission as regards the EU. A separate review of UK authorisations along the lines of the EU review by EFSA is therefore considered unnecessary”. There are no checks or balances here, Defra, HSE and ECP are all appointed by the Defra decisionmakers, there is no-one to whom a challenge to the legitimacy of a derogation can be taken, all likely looking bodies will have either advised on the decision or taken the decision.
There is no doubt that the issue of neonicotinoids and attempts to reduce the harm to wild bees from pesticides continues to trouble EU pesticide regulation, and it would be naive to believe the EC will quickly succeed in making its ban comprehensive, several member states have active derogations at the moment. In the EU there is a huge tension between the Commission and Parliament about how to strengthen the pesticide regulation process to protect bees, but the UK has not yet committed to strengthen the protection of bees in the regulation process. While UK pesticide regulation has been freed from the hands of the EC and Council, the fear is that it just falls behind a curtain of secrecy and into the hands of the pesticide industry.
A neonicotinoid seed treatment is not the only possible answer to this problem. There are alternative control measures supported by evidence that could potentially manage the problem of viruses, without increasing environmental damage. This would include using improved crop hygiene, crop rotations and natural predators to control virus levels. But none of these options were proposed as solutions, and nor was the option of licencing the emergency use of a less persistent insecticide spray considered.
The ECP 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 control measures have no sponsor or stake in the pesticide regulation process. When it works, this regulation can prevent or halt the environmental harm from a pesticide hammer, but it can only approve hammers. It can only say yes or no to proposals that are brought to the process, those proposals are to use pesticides and in this case not only are pesticides the proposed solution to the virus in the beet, they were also being touted as the solution to prevent bees from being poisoned by contaminated wildflowers.
Farmers increasingly want to avoid causing environmental harm, so the 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 develop a plan that that will have a first recourse to non-chemical approaches, and that would genuinely minimise environmental harm from any derogation to a level they would find acceptable. Even if that proves impossible it could result in the identification of 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?
After just two years 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 could instead have set out an experimental approach to improving the management of the crop to understand what practices are effective at reducing the occurrence of the viruses? Economic impacts can be managed by economic measures, if the problem is temporary and we trust a better solution will soon be available, then why not find a temporary way to economically support the industry, rather than paying with environmental damage?
Finally, our secretive pesticide management processes are not fit for purpose, the Aarhus Convention, to which the UK is a signatory, should guarantee the public access to environmental decisions, there was no access in this instance, the process should be overhauled and redesigned to be open, transparent, and engaging, with genuinely independent advice and an appeal process.
Neonicotinoids continue to be yesterday’s technology, a promising approach, now known to cause profound environmental harm. This is a sad decision that will damage British pollinating insects and rivers. We can only hope that, despite the attempt to bury this news, such poor decisions continue to draw attention to an opaque regulatory process that produces chemical answers and that excludes the public from decisions about environmental protection.
Buglife was the first environmental NGO in Europe to call for a ban in neonicotinoid pesticides and continues to explain the issues and work towards long-term solutions to the damage that pesticides are causing the natural world.