Sandra Bell25 Jan 2021
Not a happy new year for the bees
Neonicotinoid pesticides (also known as neonics) are banned in the European Union for use on all outdoor crops, because of the high risk to bees and other pollinators. This ban was based on a thorough scientific assessment of the evidence and was backed by the UK government. In 2018, the UK government refused an application for emergency authorisation for use of neonicotinoids on sugar beet, because of the environmental risk and on the advice of its own scientific experts.
Yet now it has decided that temporary use by sugar beet farmers is acceptable. What has changed? The government consistently says that it follows the science on pesticides – but how can this decision be in line with scientific evidence when the evidence of harm has grown since 2018?
Too much secrecy, not enough scrutiny
It’s hard to say whether the decision is based on expert advice because the process is shrouded in secrecy. That’s why Friends of the Earth and our allies are demanding to see all the evidence that the government has relied on to make this decision – and for greater transparency in the future. The same decision could have been made under EU regulations, but now the UK is outside the EU these decisions will have less independent scrutiny, so perhaps such a controversial decision is easier for ministers to make.
Here I explain some of the more worrying aspects of this decision and why we must have access to the evidence behind it.
Banned for a good reason
Three neonicotinoid insecticides were banned in 2013 for a good reason. Independent scientific evidence shows that these chemicals harm bees and other pollinators. Applied as seed treatments, they’re taken up by the whole plant so that bees get a dose of neonicotinoids when they feed on flowering crops. The ban was extended to non-flowering crops like wheat and sugar beet in 2018, following a comprehensive review of the scientific evidence. This concluded that these chemicals contaminate the soil, so that crops grown in the same field and wildflowers grown nearby can take up the chemical. Bees can even get a harmful dose by drinking from sap droplets on a plant. Neonicotinoids also contaminate rivers, posing a threat to aquatic invertebrates, and consumption of treated seeds poses a risk to birds. The evidence against these chemicals is clear. They should have no place in our countryside.
Why has the government allowed banned neonics back on sugar beet?
The National Farmers Union (NFU) and British Sugar applied for the emergency authorisation of neonicotinoid-treated seed, claiming that crop yields would be threatened if farmers couldn’t use these pesticides in 2021. This will mainly affect the East of England where most sugar beet is grown.
Aphids are a threat to sugar beet because they can spread viruses, including beet yellows virus (BYV), which damages the crop. The NFU claims that in 2020 “some farmers” experienced yield reductions of “up to 80%”.
Is the decision justified?
However, in October the farming press was painting a more positive picture. According to Farmers Weekly:
“Early yields from the sugar beet harvest are higher than expected after a tricky growing season hit by a spring drought and aphid-spread virus yellows disease”.
It’s worth remembering there was a similar warning of crop failure from the NFU over the ban on using neonic-treated seeds for oilseed rape. Oilseed rape yields have fluctuated since the 2013 ban, but there’s no clear trend of decline. In fact, there have been some bumper harvests since the ban as well as some poor ones. Hill Farm, which has worked hard to adopt nature-friendly farming techniques, reducing all insecticide use, recently reported its best crop for 5 years.
Like oilseed rape, sugar beet yields are affected by multiple factors. High levels of disease-carrying aphids is one, but weather is another important factor.
Bending the rules?
Demonstrating need is a key requirement for authorisation of emergency use, including that there isn’t an alternative way to control the pest or disease. The Defra statement for the recent decision states that “This protection cannot be provided by any other reasonable means”.
Defra (the Department for Environment, Food and Rural Affairs) states that “The applicant outlined a plan for developing alternative, sustainable approaches to protect crops without the use of neonicotinoid seed treatments. This includes the development of resistant plant varieties, measures to improve seed germination and new practices for growers. The plan is already being delivered”. But due to the secrecy around this application, there’s no detail available on why alternative methods were not considered to be effective.
The use of natural predators is an effective way to control aphids and was already being investigated in 2018 by the industry. It’s unclear whether this was considered as an alternative means of control in this application. A broader question is whether the industry is putting enough effort into helping growers use non-chemical methods. Farming with nature requires a more holistic approach than reaching for a spray or treated seed. For example, natural predators need habitat on the farm. Farmers will need the right kind of advice and support to move away from insecticides. The market is highly concentrated, with British Sugar buying all UK sugar, so it has considerable influence over how crops are grown, making its advice to farmers on alternatives crucial.
Applicants must also demonstrate that the use will be controlled. Defra says the applicant proposed use of a virus-forecasting model to determine whether treatment is needed. Forecasting can be an effective way to reduce the need to apply authorised pesticides. But such a system works best with insecticide sprays rather than seed treatments, which tend to be bought by the farmer before the level of pest or disease threat is known. So it’s unclear how this will work in practice.
Three years of “emergency” applications?
Applicants must also show that there are special circumstances, which mean that the emergency authorisation is not required to be repeated indefinitely. UK guidance states that “It would not generally be expected that there will be requests for emergency authorisations that have been previously granted to be renewed”. Shockingly, in this case it seems that Defra is already anticipating granting further emergency authorisations, Defra states that “The plan anticipates that applications for emergency authorisations for neonicotinoid seed treatments may be needed for three years (2021 to 2023)”.
The government’s advisers on the Expert Committee on Pesticides (ECP) noted in September that “the industry’s strategy to move away from their reliance on emergency authorisations was not clear”. By suggesting that it will consider granting repeated “emergency” uses, the government is sending a perverse signal. This is no incentive for the industry to move away from these toxic chemicals.
What harm will be caused by this decision?
In 2018, a similar application for emergency authorisation was rejected on the grounds that the risks to bees and the wider environment were too great, including:
Risk to bees from residues in soils taken up in subsequent crops and wildflowers.
Risks to birds and mammals eating seedlings and birds eating treated seeds.
The potential for concentrations of neonicotinoids in surface waters to be at levels that could harm populations of aquatic insects.
The statement from Defra does not make a convincing case that the new application has addressed these risks, especially now there’s increasing evidence of harm from these chemicals.
In September 2020 the ECP, commenting on the new application for emergency use, noted that “the scientific evidence for harmful environmental effects had grown”. It repeated its warning in November, advising that published literature indicates potentially significant risks to a range of wildlife that includes, but is not restricted to, pollinators and that “It was not possible to identify how the key risk associated with the use of this product could be further mitigated”.
Despite these warnings from its own advisers, the government decided that the risks would be managed by mitigation measures. The secrecy involved in this process means that we haven’t been able to see the full advice received, but there are certainly plenty of questions to ask about the conditions imposed.
Will the mitigation measures work?
Reducing the rate of application
Defra’s statement says that there will be a reduced application rate for the seed treatment. But there are no details of what this reduced rate will be and how that specifically reduces the risks of harm listed in the previous application.
In 2018, Defra said that future applications must address impacts on aquatic invertebrates. Neonicotinoids used at normal rates on sugar beet in 2016 caused the River Waveney to be chronically and acutely polluted with thiamethoxam. Yet in the 2021 authorisation, Defra simply states that the risks to aquatic invertebrates are “considered to be acceptable”. The government must provide more information to back up such a statement, including what it deems to be an “acceptable” risk and why, the details of the reduced application rate and the evidence that this sufficiently reduces the risk to aquatic life.
Destroying flowering weeds
The 2018 ban that was backed by the UK government, and the refusal of an emergency application in 2018, both pointed to the risk from neonicotinoids being taken up by wildflowers. In the 2021 authorisation, Defra says “The applicant recognised that risks could be posed to bees from flowering weeds in and around the crop and proposed to address this with the use of industry-recommended herbicide programmes to minimise the number of flowering weeds in treated sugar beet crops”.
It’s perverse logic to protect bees by wiping out a key source of pollen nectar and shelter in the form of wildflowers in and around the crop. It’s not even clear whether Defra assessed the negative impacts of removing flowering weeds. The ECP has raised concerns about the risk to non-target invertebrates.
It’s certainly an indication of just how toxic and persistent these chemicals are that such a measure is necessary to allowing their temporary use.
Avoid planting flowering crops for over 2 years after treated sugar beet
The risk to bees from succeeding flowering crops in soil containing neonicotinoid residues is one of the reasons for the neonic ban being extended to sugar beet (a non-flowering crop), and this specific issue was also flagged in the 2018 decision for future applications to address.
The Defra statement for 2021 says that, to address this, conditions applied to the authorisation include “no flowering crops are planted as following crops for a period of at least 22 months, with an extended period of exclusion for oilseed rape (of 32 months), to minimise the risk to bees”. Again, it’s an indication of just how toxic these chemicals are that such a long period of time is needed before a flowering crop can be grown.
However, Defra does not address the risk from maize being grown subsequently – the risk would be due to bees drinking sap water – and according to minutes of an ECP meeting in November, this was specifically raised as a concern by the Health and Safety Executive.
Has this happened because we’ve left the EU?
The decision to grant emergency authorisation has not necessarily been facilitated by the UK’s departure from the EU. Emergency authorisations have been a problem across the EU, so much so that the European Commission has asked for an independent scientific review of those granted so far. The European Food Safety Authority is currently scrutinising these decisions and expects to report in 2021.
Of course, the UK decision will not be included in this review – raising the question of whether scrutiny of such decisions will be robust outside the EU.
The wrong direction for farming
The decision to allow a harmful pesticide to be used, albeit on a temporary basis, is symptomatic of a wider failure to invest in the support farmers need to reduce reliance on chemicals and pursue nature-friendly farming practices. It’s widely recognised that healthy functioning ecosystems are essential to food production and that future food production could be undermined by damage to biodiversity.
The government is currently consulting on a draft National Action Plan for the sustainable use of pesticides. The draft plan commits to setting targets to reduce the harm from pesticides, but is weak on how it will support farmers to adopt non-chemical farming practices. It’s essential that the government sets out ambitious targets that cut the use and impacts of pesticides and help farmers get off the chemical treadmill.
What is Friends of the Earth doing?
We consider the lack of transparency in this process to be unacceptable for a decision that has considerable public interest and high stakes in terms of environmental damage. Sadly we’re not surprised. Friends of the Earth has regularly had to use Freedom of Information legislation to force the government to publish information about neonicotinoids that should rightly be in the public domain. The lack of transparency in this process means that stakeholders, including independent scientists and civil society, are unable to scrutinise the decision.
Friends of the Earth along with many other civil society organisations is demanding to see the key documents behind this decision. And we're supporting an amendment to the Environment Bill that would ensure greater transparency in future decisions.
We’re also campaigning for a strong National Action Plan that includes ambitious targets to reduce the use and impacts of pesticides, a commitment not to bring banned bee-harming chemicals back into use, and much better support to help farmers adopt nature-friendly methods of farming.
Please join with Friends of the Earth and others to keep up the pressure on the government to reduce unnecessary pesticide use.