DEFRA originally published an initial draft pollinator strategy for the UK which I reviewed here. The stand-out item in that was a lack of reference to neonicotinoid “super-pesticides”. They have now published the almost-final version and invited feedback.
On starting reading I was optimistic as the tone is positive and the wording implies action and purpose. They now discuss neonics, the value of pollination services and even the indirect (social) values of how pollinators enrich our environment. I intended writing a condensed rundown of key points here so people could give feedback without wading through the whole thing. However, I found it curiously difficult to summarise.
After several attempts I stood back, thought of it as an exercise in logic (boil things down to bare statements) and finally realised why. It doesn’t say anything new. It’s very carefully crafted to leave the reader with the impression there is lots of progressive activity going on, but a typical item is the implementation of an information campaign they name Call To Action. On reflection, I am not sure how much good this will do. The public has been saturated with media messages for the last 2-5 years – I know I’ve had at least 4 mailshots from the FoE Bee Cause campaign; the Garden Show and the Royal Horticultural Society have given pollinator friendly plants a high profile etc. DEFRA rightly laud the actions of groups like LEAF (who promote improved farming) but seem to be rather jumping on a bandwagon here rather than helping in any way.
Perhaps related, in the Supporting document: additional background material (page 3, item 2) they mention that it was agreed to create this policy at the Bee Summit organised by Friends of the Earth in June 2013. So one begins to wonder if this whole document is simply a politically necessary exercise while they get on with what they see as the important growing of the rural economy, which is the first item in their “what we do” statement on their home page.
Here are two key points I did pick up on, buried in the verbiage.
- DEFRA is going to place a lot of reliance on pesticide manufacturers to determine the effects of neonics on pollinators! (Page 7 point 10 – “Lead: pesticide manufacturers; possibly others”; p.30 point 67 – “…data requirements to be addressed by pesticide manufacturers” and point 68 – “The UK did not support the EC proposals [banning neonics] because our assessment of the available evidence was that the risk to bee populations from neonicotinoids was low. The immediate key evidence question is: 1. What are the effects of neonicotinoids on populations of wild and managed pollinators in field conditions (to be addressed by the pesticide manufacturers)?” and p.30 table 3 – “Action – Determine the effects of neonicotinoids on populations of wild and managed pollinators in field conditions. Lead/participants: Pesticide manufacturers. Possible role for others (to be confirmed)” ).
- The document makes great play about the need to gather data on pollinator numbers and distribution, and talks of a network of many thousands of citizen scientists inputting data into a Web based database. But the data gathering seems little more than a way of putting off decisions for at least 2 years. There is no indication of how any data gathered would affect future actions. Also, there is inconsistency in the application of this principle. DEFRA clearly believes the pesticide lobby and wants a return to the simple, cheap days of universal use of neonicotinoids. There is no great evidence hurdle proposed for the pesticide manufacturers to climb – all they have to do is say “we haven’t found anything”, and as detailed in this post that is highly unlikely.
I can’t see DEFRA contributing usefully or taking a lead in anything here. The “strategy” amounts to sitting on their hands and hoping someone else will “solve” the “problems” for them.
Ecosystems are more resilient to interference when they are more complex, which is why we don’t want neonics and monocrops wiping out great swathes of wildlife supporting, ultimately, our own food web. Ironically, just like an old growth forest, it is apparent that DEFRA has become a mature bureaucracy which has accreted layers of self-reinforcing feedback loops. It is very, very difficult to change such systems but they are asking for comments, and like voting, if you don’t say anything they will continue on their current course which is basically “delay until the EU moratorium on neonics expires in 2016, then return to cheap and easy neonic seed coatings”. So even if it seems futile, I urge all UK readers to go to the online feedback form and fill it in before the 2nd May deadline. To help you pre think your comments, here are the questions the form asks:
- Do you have any comments on the vision and aims for pollinators (in Chapter 2, pages 13-15 of the document)? This chapter basically says they will build partnerships, monitor and review the “strategy”, up to around 2024.
- Have we given a fair summary of main areas of concern for pollinators and the available evidence (in Annex 1)? (Pages 34-39. Describes huge gaps in our knowledge base, ignores the fact that we can infer insect numbers from e.g. declines in the numbers of insectivorous birds, wild flowers and similar secondary evidence; there seems to be confused thinking, irrelevant mention of e.g. Asian hornets and and obsession with finding out detail rather than any active management enforced by DEFRA.)
- Do you have any suggestions on the best way to communicate the ‘Call to Action’ (once agreed) to many different audiences (in Chapter 3)?
- Do you agree with the priority actions summarised in Chapter 3?(The Call to Action scheme exhorting others to do something; management of farmland – but no mention of breaking up extensive areas of 2 or 3 crops with other crops to give a spread in flowering season; management of public land in e.g. cities – in my experience this is already being done by local councils; more about extensive monitoring of pollinators.)
- We would welcome any examples of good practices which are already helping pollinators and which we’ve NOT mentioned in the consultation document or the separate supporting document (such as, land management in towns and cities, local authority initiatives particularly in fruit growing areas, management of farmland, and integrated pest management and knowledge sharing networks).
- Have we identified the right priority areas for further research and monitoring (in Chapter 3)? (Obvious gaps: funding truly independent neonicotinoid research by respected academics; legislate for mandatory Integrated Pest Management by farmers instead of prophylactic overuse of pesticides; incentivise farmers to grow a greater variety of crops to avoid gaps in nectar flows.)
- How could you contribute further to priority actions?
- Please provide any comments on related issues which we have not specifically addressed. (Standout items: monocrops, neonic evaluation by independent researchers.)