»Ê¼Ò»ªÈË

More than four years after it was consulted on, Defra and the devolved governments published a new NAP (National Action Plan) on 21 March. It’s fairly short in length, and doesn’t go into much detail about how the measures it sets out will be supported and delivered.

While the accompanying used sensational and unscientific talk about ‘bee-killing pesticides’, the NAP itself has a more constructive tone.

Encouraging uptake of IPM

Among the 10 actions to promote the uptake of IPM, the main support the government offers agriculture and horticulture on IPM is via SFI actions.

With the SFI scheme now closed for new applications, how the government will support this objective in practice is immediately called into question. While there’s little detail about how government will achieve the NAP IPM actions, the good news is that promoting and delivering IPM is an area where farmers, growers and the wider industry are already very active, particularly through the work of the .

Action 1 – increase awareness and knowledge of IPM strategies through the promotion of decision support and planning tools, practical guidance and access to learning and evidence from research and development.

Action 2 – work with farming advice services to improve the current IPM advice offer, so that it supports increased IPM uptake.

Action 3 – work with training providers to review the IPM offer to identify any gaps and areas of improvement to support IPM uptake.

Action 4 – explore opportunities for IPM facilitation funding for farmer, grower and forester-led networks.

Action 5 – gather more data on IPM and pesticide usage in the amateur and amenity sectors to better understand use, how these contribute to overall pesticide load and potential IPM approaches.

Action 6 – review regulatory barriers to innovation, particularly around precision application technologies. Explore the potential benefits and drawbacks of pesticide application by drones and consider whether rules and guidance need to be amended.

Action 7 – develop an internal evidence-based horizon scanning capability to identify, understand and mitigate pest control gaps.

Action 8 – continue to provide additional support to biopesticide applications.

Action 9 – consider how we can make improvements to the arrangements for GB biopesticides to reduce burdens without compromising environmental and human health standards.

Action 10 – continue to direct funding to facilitate applied research and development on priority areas where alternatives to conventional chemical pesticides are lacking, particularly in major crops.

Support for precision application technologies, horizon scanning to identify critical gaps in pest control practices, and a more efficient regulatory process for biopesticides, are all actions NFU called for the NAP to deliver.

The NAP talks about the availability of biopesticides being an area of growth – but all this growth happened while UK was part of the EU. Since Brexit, the EU has approved 14 new biopesticides, while GB hasn’t approved any.

The fundamental failings here have to be addressed to ensure British farmers have access to a crop protection toolbox similar to that of their EU competitors.

Setting targets and measures to monitor pesticide use

The NAP sets the first national target to reduce risks associated with pesticide use by 10% by 2030 (against a 2018 baseline). This is not to be confused with calls for arbitrary targets to reduce pesticide use.

»Ê¼Ò»ªÈËcalled for the NAP to be science, evidence and risk-based, and this is the approach taken with the target.

The target is based on a PLI (pesticide load indicator), which considers potential pesticide impact on four environmental metrics (such as how quickly a pesticide breaks down) and 16 wildlife metrics (such as the potential impact on bees, birds, earthworms), and combines this with the amount of pesticide used according to pesticide usage survey statistics.

The ‘target explainer’ published with the NAP, states that all bar one of the 20 metrics show a reduction in pesticide load between 2018 and 2022, with 12 of these already exceeding the 10% target. Risk indicators generally show a declining trend in pesticide load and associated risks over time.

Change in the UK PLI between 2018 and 2022

Source:

Importantly, the target is a national level aim for government. There aren’t any mechanisms for it to be applied at a more local or farm level.

The NAP actions on targets, measures and indicators to monitor progress are:

Action 11 – contact organisations responsible for collecting the underlying data behind the indicators included in the previous NAP to determine any potential to update, improve or replace the existing indicators.

Action 12 – all four governments to hold discussions with internal and external partners, for example HSE and UK environmental regulators, to agree an indicator framework, and develop a plan for production of monitoring reports (on who will input, how they will be reviewed and quality assured).

Action 13 – assess progress against the target, reviewing the available evidence to assess whether the minimum target level should be adjusted to maintain a stretching level of ambition.

Action 14 – publish biennial reports on results of the indicator monitoring, including progress against the PLI target.

Strengthening compliance

The third NAP objective is to strengthen compliance to ensure safety and better environmental outcomes.

»Ê¼Ò»ªÈËsupports best practice and responsible use of pesticides, and compliance with regulations, so this part of the NAP is largely about continuing to do what farmers and growers already do well. It’s a shame it fails to mention the world-leading achievements made by industry and championed by the VI under the 2013 NAP – professionalising use through training and equipment testing, improving stewardship, and establishing IPM planning across the UK.

Following the introduction of new pesticide enforcement officer farm visits to check compliance, the NFU called on the government to look at how membership of assurance schemes can be taken into account in focussing farm visits, to avoid duplicate inspections, and this now forms the basis of a NAP action.

Action 15 – commission an evidence project to review where data from a range of indicators and metrics can further inform a risk-based approach to compliance.

Action 16 – review how membership of industry/assurance schemes might be taken into account as part of assessing users’ risk profiles, so inspections are better targeted.

Action 17 – ensure guidance on the use of PPPs, in particular, the ‘Codes of Practice for using plant protection products’ (and the ‘Code of Practice for suppliers of pesticides to agriculture, horticulture and forestry’), are updated to be current, remain clear and easily accessible, support compliance and embed IPM as a key part of our long-term approach to pest control.

Action 18 – engage with online marketplaces to discuss findings of research regarding online sales of professional PPPs, and approaches to increasing visibility of the legal requirements of their use for the general public.

What’s missing and what’s next?

»Ê¼Ò»ªÈËis pleased to see some of its asks delivered in the NAP, including the high level aim of ‘ensuring farmers have the tools they need for food production’, a focus on reducing impacts associated with pesticide use and not simply use of pesticides, and taking into account assurance schemes when targeting inspections.

One of the biggest challenges of the NAP is what is missing from it.

While there’s opportunity for the industry to continue to show the proactive work it is doing, particularly on IPM and professionalising use of pesticides, many of the NAP actions lack detail about what’s involved and how it will be delivered.

The biggest gap is that there are no actions to address the ongoing loss of pesticides, and the government's failure to develop and implement an efficient, fit for purpose GB PPP (plant protection product) regulatory regime that will:

• ensure the availability of necessary plant protection tools
• promote innovation in plant protection technology, and
• enable more sustainable, competitive and productive agriculture and horticulture in the UK.

»Ê¼Ò»ªÈËwill be providing the government with our detailed response to the NAP. We’ll be seeking assurances that the target will not impact competitiveness, and clarification about how government will support IPM uptake, given the closure of the SFI scheme.