What is the EIP?
Five years ago the government launched the 25 Year Environment Plan (25YEP), and the Environmental Improvement Plan (EIP) 2023 for England is the first revision of the 25 year Environment Plan. It sets out how the Government is going to achieve their manifesto commitment to ‘deliver the most ambitious environmental programme of any country on earth’ – Goal 4 (page 126 -141) is focussed on “Managing exposure to chemicals and pesticides”. Alongside this plan, we need meaningful action.
What is good about the EIP when it comes to pesticides?
It is important to recognise the positive things in the EIP.
We are pleased to see the following:
- “Tackle chemical pollution at source through regulatory action, including banning or restricting the most harmful chemicals”
- “Target the greatest risks with our monitoring programme to understand chemical pathways and exposure in the environment”
- “Now, having left the EU, we have the freedom to consider our approach – so we can phase out the most harmful and persistent pollutants in favour of more sustainable alternatives, make polluters pay, and raise standards around the world.”
- “Minimise the risks and impacts of pesticides to human health and the environment through the greater uptake of IPM across all sectors and the development and introduction of alternative approaches or techniques, to reduce reliance on the use of conventional chemical pesticides.”
It is a positive step that the government has not completely siloed chemicals and pesticides, and have managed to focus on both together in this chapter: this ensures that pesticides are recognised as contributors to the huge problem of chemical pollution, rather than considered separately. Historically, pesticides have been regulated entirely separately from other chemicals. Whereas most chemicals were regulated under EU REACH before Brexit, pesticides were regulated separately under various EU regulations related to plant protection products. Whilst it is important to acknowledge that different uses of chemicals may require different regulatory processes in some cases, this embedded siloed approach has led to the proposal that the UK Chemicals Strategy should not include the domestic use of pesticides within its scope. And yet, in its 25-Year Environment Plan, the Government committed to ensuring that “the levels of harmful chemicals entering the environment (including through agriculture) are significantly reduced”. In 2020, the Government also reported that in England, 40% of the sources of freshwater pollution are agriculture and rural land management. Therefore, it is good news that the EIP has taken this joined-up approach.
In chapter 4, there is also nothing about pesticides being necessary for food security – which is a common narrative used by the pesticide industry to undermine arguments around the need for pesticide reduction. In reality, pesticides pose a huge threat to global food security by causing declines in both pollinator populations and soil health, so it is good news that this misleading claim has not been included.
What’s not so good?
There are also sections of the plan that do not go far enough when it comes to reducing the impact of pesticides on the environment.
The overall framing in the EIP, that sits outside of Goal 4, is not ideal. It focuses on ‘managing’ rather than ‘reducing’ exposure, which is, again, a common tactic of the pesticide industry. While food production is mentioned here it is at least caveated with the word ‘sustainable’:
“We will also need to continue managing exposure to chemicals and pesticides. These are an important part of a productive economy and sustainable food production, but they can place significant pressures on our environment across land and sea.” (Pages 10,11.)
Furthermore, the only place that pesticides are mentioned outside of goal 4 is once in the water chapter (goal 3, page 107). While pesticides are discussed alongside chemicals in goal 4, it’s a shame to see pesticides not mentioned in other relevant chapters. Stringent pesticide regulations, and support for non-chemical alternatives, can help to achieve many of the other goals and policies contained in the Plan. In contrast, failing to regulate pesticides effectively will undermine the achievement of many of the aspirations set out in the Plan and hold back its ability to deliver on its stated goals.
While the wording on goal 4 is generally good – there remains some potentially problematic language when it comes to pesticides:
Page 135 says: “Decisions on the use of pesticides will continue to be based on careful scientific assessment of the risks, with the aim of achieving a high level of protection for people and the environment, while improving agricultural production.”
Furthermore, page 136 says: ‘“The link between pesticide use and biodiversity loss is complex, but there is growing evidence that pesticides have the potential to impact non-target species such as pollinators and soil-dwelling invertebrates, which provide essential services to farmers and growers and are crucial for a thriving natural environment.”
Defra and the UK government should not still be on the fence when it comes to the impacts of pesticides on the environment. The link between pesticide use and biodiversity loss is clear as day. The pesticide industry often uses the term ‘science-based’ to undermine the precautionary principle, and talking about ‘assessing risks’ could be seen as a way of beginning the process to move away from the UK’s current hazard-based approach. The science is already there when it comes to risks, and we need to take action.
So, when it comes to pesticides, the EIP is a huge step forward. While it is a step in the right direction that the government is recognising that pesticides relate to other environmental issues, there is more to do to ensure that this plan results in meaningful action. It is important to give credit where credit is due, and a lot of what is in the EIP demonstrates that the government has come a long way in recent years, and have taken on board a lot of the recommendations that civil society have been campaigning for. To build on this progress, the Pesticide Collaboration urges the government to prioritise implementation, rather than continue publishing warm words wrapped up in official government strategies that, on their own, do not deliver for the environment.
By Amy Heley