Question 27 in the draft NAP invites the public to add any further comments about the use of pesticides in the UK - this is the part of the consultation you are responding to.
Insects pollinate a third of all our food crops. Much of our wildlife relies on them for food - be it birds, bats, reptiles, amphibians, small mammals or fish. But 41% of the Earth's remaining insect species are threatened with extinction**. In the UK alone we've lost at least 50% of our insects since 1970.
So we really want the draft NAP to:
- Commit to seeing a reduction in the environmental impacts of pesticide use
While the UK Government had previously set out this aim in 2018 (via the 25 Year Plan) the draft NAP only commits to “establishing a clear set of targets for reducing the risks associated with pesticide use”. This could arguably be achieved by (for example) increasing regulatory visits to farms or introducing stricter disposal measures... but that wouldn't be enough to reverse wildlife declines. The NAP is not meant to be about 'reducing the risks associated', but reducing the impacts of pesticides overall.
- Commit to phasing out pesticides use in certain areas, or to phasing out pesticides known to harm wildlife and human health
The NAP identifies the need to reduce the risks to wildlife and humans posed by pesticide use, yet it doesn't set out how to phase out pesticides in our towns, our cities, our homes and our gardens; or how to phase out chemicals known to have significant environmental and human health risks; nor commit to regulate the use of pesticides where the risks are unknown.
- Do much more to support Integrated Pest Management
Integrated Pest Management (IPM) is an approach to managing pests, diseases, or weeds in which chemical pesticides are used only as a last resort, if at all. IPM practices focus on farming practices where farmers work with nature to control unwanted ‘pests’ which is good for their business and vital for nature’s recovery. One of the goals for the NAP is to ‘promote the uptake of IPM’ - so it needs to make it clear that IPM is expected to be the norm.
- Be more specific about how current protections will be maintained, and the basis on which decisions around authorised pesticide use will be made
All regulatory decisions on pesticides are now the responsibility of Defra, the Welsh Government, and the Scottish Government. The NAP commits to: (a) maintaining current protections; (b) basing regulation on the best available scientific knowledge; (c) following the precautionary principle where there is uncertainty over levels of risk. But the lack of detail around how these will be guaranteed (especially in light of Defra’s recent lift of the ban on a dangerous neonicotinoid for sugar beet) undermines all three commitments.