WRITTEN EVIDENCE FROM CROP PROTECTION ASSOCIATION

 

  1. The Crop Protection Association (CPA) welcomes the opportunity to respond to the Environment, Food and Rural Affairs Committee inquiry into Food Security. The CPA is a key voice of the UK Plant Science Industry, promoting the role of modern plant science in safeguarding our food supply from seed to shelf. The Association represents companies in the UK engaged in the development and manufacture of a range of plant science technologies including crop protection products, or pesticides. We have 23 member companies, covering around 95% of the UK pesticide market. A full list of Members can be found at: http://www.cropprotection.org.uk/members.aspx

 

  1. The debate around food security in the UK, Europe and across the globe has been well-rehearsed over recent years, and we do not intend, in this submission, to dwell on the arguments and evidence demonstrating that global demand for food will continue to increase in the coming decades. Suffice to say that the CPA recognises that there are a number of issues to be addressed if supply is to meet this growing demand, including a reduction in food waste, a change in consumer habits, and a focus on a sustainable increase in production.

 

  1. As the UK voice of the crop protection industry, this submission will focus on the last of these, increasing production in a sustainable way. Used in this context, crop protection is about the effective management of pests, diseases and weeds to protect and enhance crop yields, and is primarily achieved through the application of chemical controls, or pesticides, which include insecticides, fungicides and herbicides.

 

The role of crop protection products in achieving food security

 

  1. The CPA believes that, even with improvements in reducing food waste, and assuming some changes to consumer diets that favour more sustainable production models (something that may be hard to achieve in practice), agricultural production will need to increase its global output in future. The challenge of increasing production, while minimising the environmental impact in doing so, will be the crucial element in achieving adequate global food security. As the Government’s Foresight Report on Global Food and Farming Futures stated, “…there is wide agreement that feeding the global population in 2050 will require the continued achievement of historical agricultural growth rates. Given limitations in land available for crops in the future, such growth must be largely based on increases in yields.” The same report notes that in 2009, the Food and Agriculture Organisation of the UN (FAO) estimated that to meet global demand, food production would have to increase by 70% in the period 2000–2050.

 

  1. However, it is widely acknowledged that in much of the developed world, including the UK and Europe, increases in average yields of major food crops are not being maintained, and while major advances in crop productivity were witnessed for many years after the Second World War, there has in general been very little improvement in yields over the last two decades. For instance, analysis by the Home Grown Cereals Authority shows that the period from the 1940s to the 1990s saw national average yields rising from 2.7 t/ha to 7.6 t/ha. Since then farm wheat yields have stalled, varying between 7.0 and 8.0 t/ha but with no rising trend. The reasons for these yield plateaus are not well understood, but it is clear that unless yield increases can be kick-started farmers will struggle to keep up with increased global demand for food.

 

  1. Crop protection products form a key part of a farmer’s armoury. The ability to effectively control insect, disease and weed pressures throughout the year is crucial to maintaining or improving yields.  CPA research has shown that without protection, farmers would lose on average more than 40% of crop yield pre-harvest and a further 10% post-harvest.

 

  1. Furthermore, a meta-analysis from McGill University in Montreal, comparing organic yields with those in conventional systems across a range of crops, found that, while yield differences depend on system and site characteristics, averages range from 5% lower organic yields for rain-fed legumes and perennials on weak-acidic to weak-alkaline soils to 34% lower yields when the conventional and organic systems are most comparable.

 

  1. It is important to note that according to a recent Humboldt study even a 5% reduction in EU agriculture would result in a deficit in food production for some 50 million people, a deficit that would have to be made up by extra production in countries outside of the EU. A 34% reduction would therefore likely be catastrophic.

 

  1. It should be noted that the CPA recognises that organic farming can play an important role providing evidence of the effectiveness of a range of techniques in controlling pests. Nevertheless, it is clear that managing pests with pesticides is an important element in protecting crop yields, and hence in enabling farmers to meet demand for food. The best approach to effective pest management combines chemical and non-chemical control methods, often referred to as integrated pest management.

 

Pesticides and sustainable production

 

  1. Pesticides are amongst the most heavily-regulated products in Europe, and it currently takes around a decade, costing over £150m, to bring an active ingredient to market. A large proportion of this time and cost is dedicated to research required under the regulatory system to achieve registration. This regulatory process, involving rigorous scrutiny by independent scientific experts, ensures plant protection products are safe for consumers, for the people who use them and for the environment.

 

  1. Furthermore, the Voluntary Initiative, the industry-led scheme of which the CPA is a key member, ensures that pesticides are used responsibly out in the field. This includes training for farmers, through continuous professional development, so that they use pesticides safely, and testing of equipment used for applying pesticides to ensure it is fit for purpose.

 

  1. Pesticides are, therefore, an integral part of a modern, productive farming system which aims to minimise pest damage and improve yields, while contributing to a sustainable system that protects the environment. By focusing on approaches that aim to maximise yields on a given area of land, conventional agriculture optimises both the productivity of cultivated land and the availability of non-cultivated land for other purposes. This includes land used for conservation and wildlife benefits, such as un-cropped headlands and field corners, often managed under current agri-environment schemes under the CAP. Lower-yield agriculture, for instance under low-input or organic systems, would inevitably put pressure on bringing currently un-cropped land back into production if yield levels are to be maintained or increased, with clear consequences for wildlife and the environment.

 

  1. Furthermore, direct application of pesticides on land set aside for conservation can help ensure that land is properly managed to provide maximum benefit. Some of the best examples of conservation farming in the UK take a conventional approach, both to growing crops and to managing land for biodiversity and the environment. This approach often sees environmental measures considered a crop like any other – managed with the same time, effort and expense, and under the same agronomic principles as the rest of the farm. This may, for example, mean headlands cultivated to produce a strip of pollen-rich flowers are treated with herbicides to manage weeds, so producing a habitat more attractive to pollinators and other beneficial invertebrates. Not only does this have a widespread positive impact on wildlife, but the presence of beneficial insects on field margins provides additional pest control in neighbouring crops, reducing the need to apply insecticides later in the year.

 

The political landscape for technological responses to the food security challenge

 

  1. It is clear, through practices such as this, that pesticides are part of the solution and not the problem with regard to sustainable production and food security. However, European policy makers have increasingly taken a policy approach that restricts the availability of technological solutions to increasing food production. Recent developments in pesticides policy are a case in point.

 

  1. The recent moratorium on using neonicotioid insecticides, in response to theoretical concerns about the potential sub-lethal effects of these products on pollinators, showed a worrying disregard for the regulatory system which had approved the products, and apparently ignored the damaging impact on crop yields and pollinator habitats that such a move will bring about. The decision is currently subject to legal challenges in Europe by CPA members. There are further changes to the regulatory system in Europe currently underway which will likely result in fewer crop protection products being made available to farmers, with very real implications for agricultural production across the continent.

 

  1. This not only hampers farmers’ ability to produce food, and certainly hinders attempts to break out of current crop yield plateaus, but also puts increasing pressures on remaining products to control pests. Put simply, fewer products being used increases the tendency for weeds, diseases and insects to develop resistance, exacerbating the problem.

 

  1. Furthermore, there appears to be a general approach in Europe that equates pesticides with environmental harm. This approach seeks to prohibit pesticide use from schemes and areas which are intended to benefit wildlife or the environment, for instance Environmental Focus Areas under the new Pillar 1 of the recently reformed CAP. Such an approach ignores the fact that pesticides can be, and are, used in providing wildlife-friendly habitats, and sends a misleading and simplistic message that the use of pesticides is incompatible with sustainable production. Quite simply, the reverse is just as likely to be true; without the use of pesticides, the tradeoff between food production and wildlife promotion would become increasingly stark.

 

  1. It should be noted that the UK government in recent years has taken a far more rational and balanced approach to these issues, recognising the vital role crop protection products play in farming, as well as other technologies which might assist productivity such as GMOs. However, it is crucial that the UK government, whatever its political make-up, maintains a science-based, rational and balanced approach, and vigorously promotes the same with other EU member states and institutions.

 

  1. The impact of Europe’s obstructive approach to modern farming methods can be seen in recent research into R&D investment on crop protection in Europe. Conducted by consultants Phillips McDougall, it showed that the share of crop protection R&D investment attributable to products being developed for the European market, as a proportion of global investment, has fallen from 33.3% in the 1980s to 7.7% in the 2005-14 period.

 

  1. The upshot is that European farmers have far less new technology to drive agricultural production than their competitors in other regions of the world. This is particularly important as not only does Europe have one of the highest levels of potential agricultural productivity in the world, but climate change projections show that it will become even more favourable for production compared to most other regions over the next 50 years.

 

  1. Despite this obvious justification for Europe playing a leading role in supporting agricultural productivity to feed a growing global population, current European policy seems instead content for European farming to stagnate, instead hoping to rely on the rest of the world to provide its own food as well as Europe’s. At a time when many developing countries struggle to manage their own food security, and with climate change only likely to exacerbate those struggles, this appears to be an alarmingly short-sighted and conceited approach. It also carries with it the very real risk that, even if policy makers wish in future to stimulate an increase in European production, the technology, techniques and resources simply won’t be available to do so.

 

  1. The CPA recognises that in order to ensure adequate future supply of food across the globe a wide range of issues need to be addressed, including food waste, consumer diets and barriers to trade. Nevertheless, increases in production form a crucial element in responding to this challenge, and it is vital, if we are to bolster our resilience to demand increases, that we provide the right incentives within a constructive policy environment to enable farmers to produce more.

 

  1. EU policy makers must retain an open-mind to the potential for technology to support this aim. The CPA would like European policy-makers to foster conditions and a business environment that incentivise investment in research and development (R&D). To make this happen, the EU must promote a better integration of science and policy-making, moving away from hazard-based legislation, and instead favour policy based on robust science and a risk-benefit approach.

 

  1. This should mean (1) a formal role for the Commission’s Chief Scientific Adviser (CSA) for the EU institutions to review the use of scientific evidence in risk management legislation, regulation or administrative decisions, and require further scientific assessment where appropriate; (2) Supporting the EU CSA with a network of  Scientific Advisers in all Commission Services and in all Member States; (3) Creating a more inclusive model for scientific assessment that relies on full use of scientific evidence and expertise in risk evaluation and decision-making, including input from academia, the public and the private sector (industry scientists); (4) Enhancing public understanding of science through improved education and communication.

 

  1. We also believe there should be a common institutional understanding of the Precautionary Principle, thereby enabling decision-makers to better balance the benefits, risks and uncertainties of policy decisions. Considering precaution in a broader framework with proportionality and innovation will provide a basis for balanced decision-making.

 

  1. Policy-makers should make better use of impact assessments to understand the potential impact of their political, legislative and regulatory decisions in social, economic and environmental terms, including innovation. Impact assessments should be carried out independently in a participatory and transparent way to better inform decision-makers for all policy and legislative initiatives.

 

  1. Finally, the EU would benefit from a regulatory fitness check for the Crop Protection Sector, carried out by examining the ever-increasing regulatory burdens for their practicability, efficiency, and impact on innovation, and taking into account both primary and secondary legislation and their interaction. The lessons learned should form the basis of a proportional, efficient, cost-effective and innovation-friendly regulatory framework.

 

December 2013