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    Scientific evidence supports both the case for, and against, the moratorium on neonicotinoids.  Usually, there are more questions than answers but for this subject there are more answers than questions. 

    Controversially, the EU Commission proposes restricting use of the three neonicotinoids for seed treatment, soil application (granules) and foliar treatment on plants attractive to bees and on cereals from 1 December 2013.  This decision will be reviewed over the following two years as evidence is gathered.  Sugar beet is not affected by the moratorium.

    EFSA (European Food Safety Authority) published its conclusions to a review of independent scientific evidence on the use of neonicotinoids in January 2013.  It concluded:

    • Neonicotinoids should only be used on crops that were not attractive to bees
    • There was a risk to bees from the exposure to neonicotinoid dust from the seed coatings (emitted by air drills)
    • For one neonicotinoid, field studies showed that there was a risk to honey bees from guttation (the oozing of sap from leaf margins) from treated maize.

    EFSA faces opposition either way
    For the EFSA it’s a case of a ‘double edged sword’. It is usually pilloried for supporting scientific assessments against the political wishes of member states. A good example was its declaration that genetically modified plants submitted to the approvals system are safe for use, in contrast to their political masters and majority of the population in Europe.  This time the opinion was attacked for not being sufficiently scientific.  

    On 15th March, EU member states failed to reach a qualified majority to restrict or permit the use of three neonicotinoids.  On appeal (29th April) the situation was still inconclusive, although a majority of countries were in favour of the moratorium  and the proposal was returned to the Commission to make a decision.  (On the first vote the UK abstained and on the second opposed the moratorium). 

    Meanwhile, the (UK) House of Commons Environmental Audit Committee held an inquiry reviewing the evidence for the neonicotinoid moratorium and agreed with EFSA’s conclusion.  It also suggested that EFSA should be given more power to act on the scientific evidence and not just make recommendations. 

    Defra supports view that current usage poses low risk to bee populations
    However, the official DEFRA line, following a separate review, was that while it could not exclude the possibility that neonicotinoids might damage bees on rare occasions, they would not damage bees in normal use. “Consequently, it [Defra] supports the view that the risk to bee populations from neonicotinoids, as they are currently used, is low”.

    It is also of note that the British Beekeeping Association did not lobby for a ban and supported their use.  Nonetheless, according to a bee keeper forum, beekeepers are now being asked by some farmers to remove hives from their farms.

    All parties seem to agree that:

    • Bee (and other pollinator) populations are at historically low levels
      Neonicotinoids can damage bee survival, even at sub lethal levels
    • There are more important damaging environmental factors (such as habitat loss and varroa mite)
    • The trials data is not conclusive.

    While the cost of a ban is greater – implementation possibly easier than the alternative
    The debate on neonicotinoids is to do with balances:  How does the very small possibility of bees and other pollinators being  lost together with those foods requiring pollination if they are used balance  against a more certain reduction in food production if they are not used?
    Action should have been taken long ago to incentivise the production of pollen and nectar mixes in Environmental Stewardship.  Maybe it is also time to adopt refuge areas (leaving some seed untreated).  This would also reduce the risk of some of the target pests developing resistance although it would not safeguard bees.  In all probability the cost of the ban will prove greater than the more conclusive alternative action to increase pollinators although the ban is easier to implement.


    Key contacts

    Andrew Wraith

    Andrew Wraith

    Food & Farming

    Savills Lincoln

    +44 (0) 1522 508 973

    +44 (0) 1522 508 973