Pesticide News - Issue 116 by PAN UK

ISSUE 116

February 2019

ISSN 2514-5770

PESTICIDE NEWS The Journal of Pesticide Action Network UK

An international perspective on the health and environmental effects of pesticides

INSIDE THIS ISSUE Innovative farming with The Small Robot Company An update on the Pesticide-Free Towns Campaign How robust is the new UK Environment Law? Managing a city park without pesticides An insect armageddon - what can be done?

THREE SMALL ROBOTS AND THEIR QUEST TO SAVE THE WORLD By Sam Watson Jones, co-founder of Small Robot Company and fourth generation Shropshire farmer. We’re living on the edge of the greatest change that farming has ever seen. Robotics, artificial intelligence, drones, autonomous vehicles and blockchain: these are all elements which will make up the Digital Farm. And these innovations will be mainstream within ten years. This is a radical change. Ultimately, we’re talking about a fourth agricultural revolution. This could not be more timely. The stark reality today is that farming is not working. Machinery costs are rising, yields are stagnating, and profit suffering. Globally we know that farming is a huge energy user, a huge water user and, unfortunately, the source of a lot of pollution. How we are to feed 9 billion people sustainably by 2050 is one of the most serious questions facing mankind today. Sam Watson Jones. Credit: Small Robot Company

Working on farm, 90% of the effort we put in with soil cultivations, and a significant proportion of the chemicals, is to correct the damage done by tractors. All of this cultivation has an impact on insects and other beneficials that live in the soil, as well as eroding the soil. We may have as a little as 30 to 40 years left before we have effectively eradicated soil fertility. There are also worries about food safety and contamination of the human foodchain. As a farmer, I want the food I grow to be safe to eat, and I want people to be able to trust this. But scientists disagree about safe chemical usage, and there is also confusion on safe toxicity levels. Consumers are unsurprisingly not convinced. As farmers, we also need to face up to the fact that our activities can have a negative impact on beneficial insects. One of the worst things we do is blanket chemical application.

Unfortunately, if you treat the whole field the same, overuse is inevitable. Lately, there have been concerns over farming’s contribution to possible ‘insectageddon’. The stand-out narrative is that of fields drenched in chemicals. Naturally, as a result there has been much agitation against farmers, which is unfair. Despite perceptions to the contrary, farmers are deeply concerned with environmental stewardship. But if we are to find a solution we need to work together to create it. A major theme in my ongoing discussions with farmers is their frustration with their inability to do more to protect the environment. Most do their best, but they are unfortunately very much hampered by the hard limitations of today’s ‘big machinery’ tractor-based model. It’s clear - and deeply felt by farmers - that farming needs urgent change. www.pan-uk.org

In our hands is the future of the soil, and the future of food. A more ecologically harmonious way of farming is vital for the future of our planet. Less impact, and more in line with nature.

Robotics brings a new level of precision which is completely beyond the hard limitations of tractors. This is an entirely new way of farming: making the data point the individual plant, and each square metre of soil, rather than the field as a whole. This will be transformational. Farms that use robotics will reduce chemical usage by up to 95%.

At Small Robot Company, we’re starting from the drawing board to create a new and sustainable farming system that makes the very best use of today’s technology. Our mission is to deliver ecologically harmonious, efficient and sustainable farming.

From a farmer’s perspective, this is very much welcomed. Legislation against chemicals is leaving farmers increasingly short of options. As such, they are very interested in seeing a next generation of precision ‘spot applications’ developed for virulent weeds such as blackgrass. Meanwhile, we are also working on developing non-chemical methods of dealing with weeds such as electricity and lasers. We could see a future without any herbicides necessary in arable farming at all. Non-chemical weeding is the holy grail.

So we are reimagining farming with robots and Artificial Intelligence (AI). Using small robots instead of tractors, we will ‘digitise the field,’ producing an abundance of food with minimal environmental impact. Our three small robots Tom, Dick (pictured on front cover) and Harry will take care of all the feeding, seeding, and weeding autonomously. Working in conjunction with Wilma, the artificial intelligence ‘nervous system’, they will only feed and spray the plants that need it, giving them perfect levels of nutrients and support, with minimal waste.

Andrew Hoad, Partner & Head of the Leckford Estate, Waitrose & Partners, with monitoring robot prototype, Tom (Credit Geoff Pugh)

There’s also of course the matter of the corresponding cost savings to make this even more attractive. Costs could be cut by up to 60% with robotics. This will also almost entirely remove the lingering worries around the application of chemicals on our food.

We are also not going to tell farmers how to farm. Rather we will work with them, to ensure that this new way of farming is the best and easiest way. Our technology will be applicable for all arable farms - from organic farms to conventional, from smallholdings to large-scale industrial. Mass-market adoption could have a tremendously beneficial impact. Robotics is kinder to the soil, kinder to the environment, protects biodiversity, and enables permaculture at scale. It’s the ultimate sustainable farming model.

It’s important to stress that our ethos is ‘by farmers, for farmers’. Much of our thinking has come directly from farmers telling us about the problems they are facing and the things that they think are important. To have maximum beneficial impact on the environment this needs to work for farmers.

It’s potentially game-changing, and it feels very exciting to be on our way to making history, changing the way we farm forever. Small is for the Future.

We are therefore working closely with farmers, on farm, to develop our technology. We’re currently in field trials with our early prototypes in 20 farms across the UK, including Waitrose and the National Trust. We’re also working with industry bodies such as the National Farmers Union and Nature Friendly Farming Network, as well as a selection of industry partners.

Find out more at: www.smallrobotcompany.com

Tom, monitoring robot prototypes are currently in field trials at 20 farms across the UK (Credit Small Robot Company)

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PESTICIDE-FREE TOWNS CAMPAIGN - AN UPDATE It has been a busy and very positive few months for the Pesticide-Free Towns campaign across the UK. The following is a brief update on some of the recent progress made by campaigners, councils and PAN UK.

to follow, is the establishment of a pesticide task force. The aim of the task force is to bring together other key land managers from across the city to work together to find sustainable non-chemical solutions to dealing with weeds and pests. In this way they can share experiences, problems and perhaps most importantly costs.

In London the appetite to go pesticide-free has grown. In fact, London might already be using less pesticides than initially thought! In December, Croydon Councillor, Stuart Collins, declared that as of February 2019, they would use the opportunity of taking the grounds contract back in-house to end the use of glyphosate in all of its public parks and green spaces. He also stated that they plan to train staff in new techniques and explore feasible non-chemical options. In perhaps the most heartening part of his statement, he said that this is something that Croydon Council is committed to delivering regardless of the cost.

Back in London, there is news from Camden where a cross-party Motion, along similar lines to that adopted by Bristol, has been put forward for discussion twice so far this year. Sadly both times, due to other pressing council business, time ran out for the Motion to be debated. However, there is a strong pesticide-free campaign in Camden and they will keep pushing for the debate to happen. In Manchester, the Whalley Rangers have been pioneering a community initiative in partnership with Manchester Council to stop the use of herbicides and draw the local community in to helping make this happen. Their Streets Without Herbicides Campaign which is due to officially start in April will see an end to the use of herbicides throughout the Whalley Range area of Manchester. They have six events planned for this year that will involve locals in hand weeding, bulb planting and a host of activities for children too. This is a hugely inspiring initiative and one that PAN UK whole-heartedly supports.

In other great news, albeit a little late, PAN UK was informed that Lambeth Council stopped the use of pesticides in its parks and green spaces back in 2016. This really is something for them to be proud of and so we are shouting about it now on their behalf. We are also working with Incredible Edible Lambeth to try and persuade the council to go the extra mile and stop all pesticide use in the Borough. In other developments, Bristol, following a long campaign by the Pesticide Safe Bristol Alliance, finally adopted a motion to phase out pesticides throughout the city in the next three years. This is a really positive step and is fully supported by the elected Mayor of Bristol, Marvin Rees. What is particularly interesting, and a model for other councils

Together we can make the towns and cities of the UK pesticide-free!

By Nick Mole, Policy Officer, PAN UK 5

HOW ROBUST IS THE NEW UK ENVIRONMENT LAW? By William Wilson, Barrister & Director, Wyeside Consulting Ltd.

Image by Tom Cunliffe, Pixabay

On 19 December 2018, the government published draft Clauses of an Environment (Principles and Governance) Bill. These are supposed to address the arrangements for the enforcement of environmental laws, and the application of environmental principles, in England after Brexit, when enforcement by the European Commission and the Court of Justice of the European Union will no longer be available. Examples of environmental principles are the precautionary principle, the polluter pays principle, and the principle of sustainable development. These have a significant influence on EU environmental law and how it is interpreted by the courts – the Bill proposes ways to apply them in English law.

heart of the issue of whether, and if so how, environmental laws which deliver essential protections will be made to work. Responsibility for the environment is devolved, and Scotland, Wales and Northern Ireland will adapt and apply these provisions differently. Scotland has published its own proposals: Wales is likely to follow suit. Environmental law in Northern Ireland is held back by a lack of political interest, and of a government. In the event of a ‘no deal’ Brexit, the government’s legislative timetable will be overcrowded, with key primary legislation still working its way through Parliament, and a backlog of several hundred statutory instruments yet to be drafted and introduced. The Environment Bill presently has a place in the Parliamentary programme, but British politics is rather volatile at the moment. Having comparable environmental regulation is also not just a matter of UK interest, but will be a significant factor in any trade deal between the UK, the EU, and other jurisdictions.

The Bill is intended to be part of a wider Environment Bill to be introduced in 2019, covering air quality, protection and enhancement of landscapes, wildlife and habitats, more efficient handling of resources and waste and better management of surface, ground and waste water. The Bill therefore goes straight to the

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The Environment (Principles and Governance) Bill provides for the Secretary of State to issue a Policy Statement of the Environmental Principles to which other Ministers of the Crown must have regard. It establishes a framework for Environmental Improvement Plans, the first of which is to be Defra’s current 25 year plan. It would establish an Office for Environmental Protection (‘OEP’), which is supposed to “scrutinise environmental law and the government’s environmental improvement plan, investigate complaints on environmental law (and) take enforcement action on environmental law.”

In May 2018, the Secretary of State for the Environment, Food & Rural Affairs, Michael Gove, declared that – “Our new Environmental Principles and Governance Bill is designed to create a new, world-leading, independent watchdog to hold government to account on our environmental ambitions once we have left the EU. The role which has been played in the past by the EU Commission and courts should be filled now by a UK body embedded in the UK’s parliamentary democracy.” However in place of the robustly independent body, accountable to Parliament, that was initially proposed by Defra, the OEP would under these clauses be appointed, and funded, by the same Secretary of State. This does not provide sufficient independence for a body required to call government to account, and there needs to be more of a role for Parliament in delivering that.

After Brexit, EU Treaty obligations reinforcing environmental laws will no longer apply. For example Article 191 of the Treaty for European Union requires Union policy on the environment to contribute to preserving, protecting and improving the environment, protecting human health, prudent and rational utilisation of natural resources, promoting measures at the international level to deal with worldwide environmental problems such as climate change, and it must “aim at a high level of protection” of the environment. This aspirational language, which helps ‘set the compass’, needs to be written back into the Bill instead of simply being discarded.

The OEP would be able to issue an Information Notice, a Decision Notice, and eventually to make a “review application” to the High Court, and maybe to make a public statement about breaches of environmental law, but these are slow moving procedures to bring non-compliance with environmental laws to an end, and there is no intention within government of replicating the EU Court’s powers to levy fines. It would be worthwhile including provisions requiring a Minister and Permanent Secretary of a government department, or the Chairman and Chief Executive of a public authority, found to be in continuing breach of environmental laws to come and explain that in person and in public to a Parliamentary committee.

EU environmental law is enforced against Member States by the European Commission, and by the Court of Justice of the European Union, which has the ultimate sanction of being able to fine Member States for continued non compliance. EU law also places legal requirements on governments to have penalties for breaches that are “effective, proportionate and dissuasive”, and individuals have the right to activate enforcement of environmental laws, at no cost, through complaints to the European Commission. As these provisions fall away, the question will be whether the Bill offers adequate alternatives.

Image by Hans, Pixabay

The draft Clauses apply the environmental principles to the actions of Ministers and public authorities through the Secretary of State’s Policy Statement. This allows much scope for Ministerial lobbying against enforcement action, and for re-interpretation of which principles should apply and how, instead of applying the principles directly to the discharge of functions by public bodies. The Policy Statement is also subject to very wide exceptions. It “…may not deal with policies relating to— 1. the armed forces, defence or national security, 2. taxation, spending or the allocation of resources within government, or 3. any other matter specified in regulations made by the Secretary of State”. These exemptions are unjustified, unnecessary when applying broad principles, and inconsistent with EU environmental law (which the government has promised to transpose into national law). The same restrictive approach is taken in the way the Bill defines environmental laws, and excludes parts of the environment from its scope, such as indoor air.

principle. The Court’s press release about these judgements declared – “…where there is scientific uncertainty as to the existence or extent of risks to human health or to the environment, this principle allows the institutions to take protective measures without having to wait until the reality and seriousness of those risks becomes fully apparent or until adverse health effects materialise. The precautionary principle, moreover, gives precedence to the requirement relating to the protection of public health, safety and the environment over economic interests.” The precautionary principle is not all that complicated. Essentially the Court is saying that you don’t have to wait until all the bees are dead before being required to apply controls on pesticides to prevent that from happening. The precautionary principle matters more than ever, when Defra’s own Chief Scientist is reported as saying in 2017 that the assumption by regulators around the world that it is safe to use pesticides at industrial scale across landscapes is false; and that the lack of any limit on the total amount of pesticides used and the virtual absence of monitoring of their effects on the environment means it can take years for the impacts to become apparent.

To take pesticides and the precautionary principle as one example. The judgements of the Court of Justice of the European Union on neonicotinoid pesticides contained a very strong re-statement of the precautionary

Image by Eurolive, Pixabay

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Yet under this Bill as drafted, the precautionary principle is one of a limited list of such ‘environmental principles’ that would need to be applied in a policy statement from the Secretary of State in order to have legal effect. It need only be applied “proportionately”, if the Secretary of State considers it relevant to particular policies, and not if he or she considers that it would have no significant environmental benefit. It must not be applied to the armed forces, defence, national security, taxation, spending, the allocation of resources within government, or “any other matter specified in regulations made by the Secretary of State”.

to be effective, and the prospect of it real. There should be a duty in English law on all public bodies to contribute to a high level of protection of the environment, and where relevant to their responsibilities, to secure the effective enforcement of environmental laws. Although enforcement arrangements will not be the same after Brexit, the real test for this part of the Environment Bill will be whether it reflects the will and determination to enforce environmental laws effectively. Even with all the machinery of EU environmental laws available to us, this will is sometimes missing, in areas such as Volkswagen’s diesel cars, successive UK governments’ defiance of EU air quality legislation and a tolerance of illegal waste sites.

These are some of the ways in which the Bill needs to be improved. The Office for Environmental Protection needs to be robustly independent and to have that independence protected by Parliament, not to be a creature of the Secretary of State. Environmental principles need to apply to actions of all Ministers and public authorities directly, not to be filtered through a Policy Statement from just one Minister. Some important environmental principles need retrieving from the EU Treaty provisions, and re-enacting. The current exemptions where the principles would not apply are unjustified and should be removed. Enforcement needs

As we leave the EU and cease to apply EU environmental laws, it is essential to the protection of both the environment and public health that we find effective new ways to ensure that environmental laws are enforced. A link to William Wilson's evidence on this Bill to the House of Commons EFRA Committee is at: https://parliamentlive. tvevent/index/5a6ae1ab-a102-4bff-859f9311130617fe

MANAGING A CITY PARK WITHOUT PESTICIDES By Stephen Peters, Garden Manager, The Level Park, Brighton.

The Level Park is situated in the centre of Brighton and is completely pesticidefree. The park’s complete restoration using Heritage Lottery, Big Lottery Fund and other funding sources in 2013 provided the catalyst to create and develop this important community and destination park as an environmental and conservation centre of excellence. The project aspiration conservation of the park’s natural (plus built and social) heritage – was put into practice from the start, aiming to provide pollinators and other wildlife with a home in the city.

grow. And extra bonus is that it also gives culinary delight to the onsite café.

Every part of the park is its own miniature, unique ecosystem with its own combination of plants, trees, shrubs, soil conditions, insects, microorganisms and microclimate.

In 2016, we created a butterfly bed. The plants that we have selected are Echinops (Globe thistle), Verbena bonariensis, Verbena hastata, Nepeta (Cat mint), Mullein, Centaurea montana, Hemp agrimony, buddleja, as well as some clumps of stinging nettle.

A ‘bee bed’ was established in the north west corner of the park, as part of ongoing collaboration with the Brighton & Lewes Downs Biosphere programme to improve urban green spaces. This also demonstrates the attractive garden plants that people can grow at home to benefit a variety of pollinators, an initiative with the University of Sussex’s Laboratory of Apiculture and Social Insects (LASI).

To circumvent funding, manpower and other resource limitations these habitats have been introduced in a phased approach over the years. A herb rock garden was created to provide habitat for insects due to its diverse planting, such as basil, chives, tarragon, thyme, mint, rosemary, oregano, marjoram, coriander and sage. The rocks also provide a place for insects to hide and for lichens to

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In 2017/18, we planted two beds near the cafĂŠ with drought tolerant plants to demonstrate to the public the changing effects of our climate, and that we need to make better plant choices for the future. The success of the new planting in these areas helped increase food for pollinators by 20%, due to fact that, some plants have a longer flowering period than others.

Good plant diversity, such as a wide range of perennials, shrubs and wild flowers, create a healthier ecosystem for pollinating insects, as well as other beneficial insects. Some species of plants, such as stinging nettles, chicory and Achilleas, have beneficial effects on neighbouring plants. Commonly known as Dynamic Accumulators, or 'mining plants', they can mine sodium, sulphur, nitrogen, calcium, potassium, iron and copper which improve the neighbouring plants defences against pests and disease.

HOW DO WE MANAGE WITHOUT PESTICIDES?

By planting flower beds to capacity, there are less areas for weeds to grow. Also, good soil management results in healthier plants that are more resilient to pests and diseases. No peat-based materials are used (organic material only) such as autumn leaves, grass trimmings, spent coffee grounds; wood ash, and tea leaves. Over 95% of our green waste is recycled on site. This in turn provides a home for a number of environmental heroes, including microbes, earthworms, woodlice and fungi.

We have our own seed bank and propagate 50-60% of our own plants. By using propagated plants and seed from on site, we are better guaranteed that the plants will of good stock and free from any pesticide contamination. We also use Neem oil for controlling pests and diseases, such as greenfly or blackspot. We have a number of local citizens that volunteer their time each week to helping with some of the more physical aspects of keeping the park running smoothly. The park has won a number of awards for its environmental standards. It is also a Green Flag park.

Designated areas, such as the perimeter of the park, have been left to grow. These habitats also increase the biodiversity of the park.

Stephen Peters, Garden Manager, The Level Park

AN INSECT ARMAGEDDON deemed to be the most harmful. Mr Gove and his department were rightly congratulated for adopting this position, but it followed years of opposing the ban. Years in which both the Conservative and Labour parties felt that the scientific evidence of harm to bees was insufficient to warrant a ban, years in which instead of paying attention to the overwhelming body of robust science they instead listened to the pesticide industry and their cheerleaders.

We are angry, the public are angry and the insects are dying.

Yet our politicians are sitting on their hands, as they have done for years, hoping that this inconvenient truth will disappear. It is clear that we are facing a crisis – the sixth mass extinction – evidenced by the most recent report on the alarming decline in insect numbers published last week. This is not the first report to point out that insect populations are declining at an alarming rate and if we do nothing to address this problem they are taking us with them.

Despite some fine words put forward in the 25 Year Environment Plan and in regard to the impending post-Brexit Agriculture Bill there is, to date, no positive evidence that the politicians put in charge of looking after the environment and people of the UK are prepared to make the hard choices necessary if we are to see an end, or even a significant reduction, in the harm that pesticide use is having on our biodiversity and health.

What is driving these declines? The report identifies habitat loss, intensive agriculture and, most significantly, pesticides as the key drivers. It’s great to see such a high profile study pointing out what we have known for decades– from the publication of Silent Spring in 1962 to the neonicotinoid bee loss crisis and now to these latest reports of severe declines, we have known that pesticides are not good for our insects. And yet nothing is done about it – this is not merely careless, it shows a reckless disregard for the well-being of people and planet.

What can be done? There are some glimmers of light, not from the UK but from our neighbours in France and Germany. France has become the first country in Europe to ban all five of the neonicotinoids from use in agriculture – going beyond the minimum legal requirement due to their concern about the health of bees and insects. Meanwhile, Germany is apparently planning to introduce an insect protection law to slash the use of pesticides and pump tens of millions of euros into research. A bold move that both acknowledges the importance of invertebrates and the role that pesticides are playing in their decline.

In terms of who is responsible, it isn’t just the fault of the pesticide manufacturers, the people that pervert science, intimidate independent scientists who disagree with them and push dangerous pesticides on developing nations. The fault also rests with our politicians and regulators, locally, nationally and globally. They are the ones that have known about the harmful impacts of pesticides since 1962 and yet have failed to act, failed to legislate or take anything other than short-term, self-serving decisions, while continuing to deny the very real problems associated with pesticide use. There are too many examples to mention but we might point to the recent sea change in the position of Defra to beetoxic neonicotinoids, which made a complete U-turn to support a ban on the three that are

What we need now is for our politicians to be less like invertebrates, show some backbone and make the decisions that will ensure our insects do not die out and take us with them! While they may lose the love of the agrochemical industry in the process, the general public and nature as a whole will thank them for it.