Guest blog – The case against the EU by Richard Wayre

Screen Shot 2015-03-09 at 09.58.07After twenty-some years pursuing a career in marketing and management consultancy I jumped ship and returned to academia, initially to study Countryside Management and then moving on to read for a degree in Ecology. The marriage of my old world and new is not a comfortable one. From the dual perspectives of environment and economy, the forthcoming election promises to be an interesting one; perhaps not for producing an earth-shattering result domestically, but with potential ramifications on a wider front.

What does the United Kingdom’s membership of the EU mean to you? Ease of travel for a summer holiday? Freedom to work anywhere within its bounds? The longest period of political stability in history? Or monetary instability, uncontrolled immigration and bureaucratic wastage? To many reading Mark’s blog on a regular basis it might mean something else; environmental protection. Much of the UK’s environmental legislation (actually, I must be cautious with unqualified statements – the constituent nations of the UK can adopt different solutions to legislation, so from here I’ll refer specifically to the situation for England) stems from EU treaties. In particular, the Birds and Habitats Directives commit nations to implement protective measures, but it remains the responsibility of each individual nation to enact those commitments, which inevitably means there is variation in interpretation of the requirement. Ostensibly though, we defer to Europe in respect of the protection afforded our habitats and species.

So let’s jump forward to late 2017. The Conservatives, having been returned to power, honoured the promise of a referendum on continued membership of the EU and Britain voted to leave. Should the badgers (a bad example, I agree!) and foxes pack their bags and emigrate whilst they still have time? Is every ancient woodland in the land about to be grubbed to make way for houses or high speed rail? Is our environment doomed by the impending loss of its EU protection? I think not.

I am not ashamed to admit I’m a firm Eurosceptic. But, until recently, I’ve predominantly viewed Europe with my ‘economics-graduate’ hat on. Are BMW going to stop selling cars to us post-‘BRexit’? No! Is London still going to be a financial hub in the global economy? Yes! Will we still be able to head off on a beano to Paris or Rome or Madrid whenever we feel like it? Of course we will! But, now, an ecology-(under)graduate hat hangs on the peg alongside the economics, and I confess to a niggle and a waver as to whether we risk too much natural capital by leaving the EU. But, after much deliberation, I’m coming to the conclusion that we can do without Europe ecologically as well as economically.

First, and this is largely a matter of opinion rather than hard fact, so you might choose to disregard this point, the EU is, first and foremost, a political environment administered by political animals. Economic prosperity will be the primary driver of decision-making and environmental policy will likely be ever more compromised where and when it suits politicians. This is already appearing to manifest itself in the current administration and a quick Google search on the terms “Junckers”, “EU” and “Environment” will result in a plethora of documents, some of more robust provenance than others, opining that the new EU President is less than sympathetic to the natural world (for example, his appointment to the role of Commissioner for Climate Action has links to the oil industry, and the UK press reported his willingness to soften environmental instruments to win support from David Cameron, his chief opposor to election. EU political will to protect may not be as strong as we would like to believe it to be.

Secondly, legislation. As I mentioned a moment ago, the acts that convey protection are implemented not by Europe, but by the English legislature. The directives merely impose a requirement on member nations to achieve a particular objective. It is often contended that the Wildlife and Countryside Act 1981 and the convolution of legislation supplementing it actually impose far greater protection than the EU Directives ultimately require; ‘gold plating’ for want of a familiar expression. Furthermore, as signatories to the UN Convention on Biological Diversity, the UK is committed at (arguably) an even higher level of governance to meet certain objectives, namely a reversal of biodiversity loss by 2020, so substantial erosion of protective measures is not, necessarily, a simple step for government to take. Of course, we should be under no illusions that politicians of most persuasions would happily dilute the existing laws if it helps them promote short-term well-being of their voters (unfortunately our cost-benefit approach to conservation discounts future generations far too aggressively for politicians to consider what true sustainability means). However, the fact is, today, our local legal protection is pretty good and I’m not convinced EU rules add anything to planning or court room decisions on whether to conserve or destroy.

Finally, there is the bugger’s-muddle of operational reality in the EU. George Monbiot (@GeorgeMonbiot) has written several interesting pieces for his column in The Guardian over the past year or two (for example, this, and this). Whilst I enjoy reading Mr. Monbiot’s column I don’t suggest that we should blindly take his every word as gospel, but the general point he makes is an interesting one: that whilst the EU might fund much in the way of restorative projects, it’s EU policy and EU money that often stimulates activity that creates or exacerbates the problems in the first place. And, of course, when I say EU money, I mean OUR money…£9.4bn net in 2015/16 to be precise. Is that really how we want our countryside managed – with such flagrant inefficiency and contradiction?

So, on balance, my Eurosceptic-heart prevails. I see some risk in abandoning Europe; the Government could espy an opportunity to overhaul (and weaken) our existing legislation and set the developers loose. But, withdrawal will mean the politicians have their hands full sorting out all manner of other issues so my hunch is they’ll not worry too much about Wildlife and Countryside Act et al. Anyhow, Junckers is just as likely to strip protections and I’d see a greater chance of the public and the NGO’s swaying the UK government to our position than the behemoth that is the EU. And the upside of ‘BRexit’ in terms of reduced bureaucracy, improved land management resulting from abandonment of some damaging practices and subsidies, and less pressure from a rapidly growing UK population COULD actually be of long-term benefit the natural world.

As a final word, by way of illustration, permit me to cite three examples of European law singularly failing to protect the environment; one local to me, one national, and the third European.

(1) Expansion of Lydd airport, to enable B737-size aircraft to fly in and out, directly adjacent to SAC designated land bordering RSPB Dungeness was approved on appeal by Rt. Hon. Mr. E. Pickles MP last year despite vociferous objection from RSPB, Kent Wildlife Trust and the local community. Particularly galling about this failure to protect was the subsequent decision, within days, to close Manston Airport, just twenty miles away in north Kent.
(2) HS2, the route of which will crash headlong through numerous important habitats. Ultimately, the government, with support from Labour, was able to ignore all environmental objections on the basis of a perceived economic benefit.
(3) Brought to public attention by Chris Packham (@ChrisGPackham) so effectively last year, the annual slaughter of migratory birds, specifically banned under the Birds Directive, transiting Malta (yes, an EU member state).
(And if you haven’t had enough of George… see here)


42 Replies to “Guest blog – The case against the EU by Richard Wayre”

  1. I am afraid I do not agree at all that this country is better off outside the EU. One of the main reasons that the Common Market was established after the second world war was to help to prevent a third Eurpoean war and to that end it has been pretty successful. By each member country being prepared to relinquish a little of its sovereignty, members states would all benifit much more that each one acting in its own interests. This was one of the main causes of the first and second world wars and something the UK still finds very hard to do.
    No one is suggesting that the current EU is very good, it isn’t and there are many things wrong with it, but one of the UK roles must be to help correct these deficiencies from WITHIN the organisation and that includes all the deficiencies affecting our wildlife and nature as a whole. Nature and wildlfe does not recognise boarders. Therefore if anyone thinks that we can right the current wildlife wrongs, and others, by leaving the “field” and sitting on the side lines while enjoying much improved biodiversity in the UK under a government that withdraws this country from the EU, they must be very much mistaken.
    It is tough going at present but when the going gets tough, the tough get going. There is much to do but lets get on and do it and not sit and moan as a nation on the side lines as we are doing at present.

  2. we do indeed have our own legislation. which is there because europe requires it. one of the main drivers for an exit from europe. is the desire to get rid of the green crap.
    so that we can return to victorian methods of environmental protection.
    once membership of the Eu no longer requires such legislation. there is absolutely nothing to stop a repeal of the WCA being rammed through

    1. There’s a great deal to stop a repeal of the W&C act being rammed through – it would be very bad politics. Better by far, from a politician’s point of view, to neuter it by further cuts to NE, even more restrictions on its remit, and an even more “liberal” interpretation of planning policy and national priorities. And politicians can do that inside or outside Europe – as we have seen, being inside Europe hasn’t stopped them doing so already.

      1. Remember “A Muzzled Watchdog” (1997)?

        Poor NE have already been so savagely neutered they are perhaps better put out of their misery & euthanised as they are currently acting as an aide to development through such options as DAS and by grant aiding any potential dissent through PR projects?

        At one time of day there were NCC / EN / NE staff who would try to do the right thing and would collaborate with conservationists, sadly an extremely rare species these days?

    2. Hi! Jason…thanks for your comment. I do agree that there is a risk of dilution to our laws, and I hope I made that clear. I would reiterate two points though: first, that we are committed to CBD obligations to halt biodiversity loss so repeal would not be straightforward; and, secondly, M. Junckers has made overtones suggesting he is equally likely to advocate reducing environmental protection in favour of economic stimulii.

      Bill’s reply to you is probably expressed more eloquently than I managed and I agree with him. Reductions in NE budgets present a more realistic threat but, as we’ve seen over the past five years, such cuts are administered irrespective of EU Directives.

      1. I agree that a very real threat to UK biodiversity is a further weakening of the government conservation agencies which would reduce their ability to look after SSSIs. Currently the EU is a factor that reduces this threat because it can take action against the UK government if SACs or SPAs are damaged (huge fines). Already we are seeing that SACs and SPAs are better protected than SSSIs that do not carry the extra designation because government (and therefore the agencies) wish to avoid these fines. Walshaw (Wuthering Moors) may turn out to be an example of this….had there been no EU, there would have been no-one to complain to.

        Individual governments will always be tempted from time to time to sacrifice the odd SSSI here and there to make a bit of money or gain a few jobs or dare I say it, please the odd party donor. We need higher level safeguards (where in effect European countries keep a bit of an eye on what others are doing) so that governments are less likely to give into temptation.

        The EU has also, so far, been more willing to regulate the use of damaging pesticides than our own government. I believe the threat from certain pesticides (e.g. neonicotinoids) is widely underestimated. If anyone is to take on the might of the international agrochemical companies, it surely has to be a group of countries standing together.

        That’s not to say the EU is perfect; CAP is a huge environmental disaster long overdue for serious reform…and there have indeed been worrying signs that there are plans to water down the environmental directives. However, I am not yet ready to throw the baby out with the bathwater.

  3. I’m not equipped to touch the economical or ecological arguments.

    But reading through, I had an adrenalin rush, not of the welcome type – a reaction that seems to go hand-in-hand with the concept of Euroscepticism.

    For just two reasons, and they are:

    1) A Eurosceptic, be it from the UK or my native Finland, or probably the same in any other member state, tends to sound arrogant. It’s “us good people” against the unsavoury EUans (synonym to aliens or something?). A Eurosceptic is the one paying into the piggy bank, whereas others just put their grubby little hands in to extract. A Eurosceptic sees the rest of the EU, the other member states, as a political entity, as if the EU was only the Commission, Brussels, subsidies.

    2) How would the problems listed go away by leaving the union? Granted, you might be happy minding your own business on your island, but do you think the problems elsewhere go away? Like the Maltese probleme for example? (Absolutely all credit to Chris Packham btw, but a German organization, Committee Against Bird Slaughter, has been fighting the problem long and hard.)
    Wouldn’t the problems possibly get worse if you weren’t there to argue about them, to take a stand against?

    How is it not better to work to improve the EU from within?

    How does the dirt of politics (or economics) in Brussels differ from that in London, Helsinki, Rome? Except that when we’re together, we have a say in joint matters. Not together, no s(w)ay. Or?

    How were the three examples supposed to make me turn against the EU? How would they not harden my resolve to stick together? I’m not a Brit but it’s not that difficult for me to stand in your shoes, for a bunch of reasons, so even if this piece was from a UK/England perspective to a UK/English audience, the same shit goes on in the other member states. I see the same attack on our wildlife and natural environment in my country (our fresh new legalisation of wolf hunting is a poignant example), and the same hardening in the EU.

    How are we not better together?

    I am EU. Not the Commission or the junckers.

    Riding the adrenalin rush, I might come off a little acerbic 🙂

    1. You put this very well and comprehensively, Minna.
      I agree wholly – sorry to have to write, but I seem to have lost the ‘like’ function.

  4. The problem with a referendum on the EU is that no one is offered any advice on what we would do outside it. Yes, BMW cars will still be sold here but there is no guarantee that our exports would be sold on. The greatest benefit to the EU is that it offers trade opportunities as part of a greater trade bloc. For example, can you imagine the USA, the former Commonwealth countries and the Asian markets trading with us when there are no onward opportunities? It is debatable whether we really produce anything the rest of the world actually wants and certainly nothing that is produced elsewhere.

    However, the idea that departure from the EU would provide better protection against policies like the ones outlined does not really work. All that would happen is that the UK would continue to ignore its commitments but without anyone having to reference back to a greater piece of legislation. The Malta situation is actually a good example because there is a clear point of reference whereas the Maltese hunters would simple use the ‘it’s none of your business’ argument more often if they pulled out. I do not think we should ignore this point of reference idea because it is not dissimilar to the independent trade argument.

  5. I’m afraid there are plenty of cases of member states, including the UK, failing to properly implement EU nature directives, and action having to be taken at the wider EU level to get the government to do the right thing. Take Lappel Bank, for example – illegally excluded by our government from the wider SPA and subsequently destroyed to make way for a car park. EU infraction proceedings eventually forced the government to provide compensation. And up until very recently our government felt that Appropriate Assessments (under Article 6(3) of the Habitats Directive) were not required of local plans – only a decision in the European courts forced the government to change its stance. And elsewhere, the horrendous Via Baltica scheme in Poland would have trashed a string of EU-protected wildlife sites had the EU not again threatened infraction proceedings and the European Courts of Justice not issued stop notices. Basically, the EU membership provides a means to go beyond the interests of individual member states and consider a bigger context – European wildlife sites are, after all, of international, not merely national, importance.

    1. Hi! Steve…the scenarios you cite are precisely what does occasionally have me wavering on whether the devil we know is preferable to exit. On balance, at the moment, the similar examples where the EU has not stepped in combined with the evidence that much of the damage we inflict is caused by bad EU policy i.e. CAP, Fisheries etc. leads me to the conclusion that we could have something better (that’s not to say I think the current administration will do the right thing without considerable pressure).

      What I would like to see is a better EU model, economically and ecologically. But I fear we won’t get that, for all Cameron’s determination to renegotiate Europe. That being the case, I think a referendum will inevitably lead to exit because the majority of the population will vote on a single issue: immigration. So we, at least, need to plan for a future without the EU umbrella.

      Thanks for the comment though…I’m happy to be persuaded the other way!

  6. For me it is simply the case that I trust the environmental instincts of the EU law makers over those of our own governments. Take the case of neonicotinoids: under pressure from lobbyists and the NFU our government (in the form of Owen Patterson) resisted a ban on these highly insidious and damaging pesticides (, but thankfully the EU persevered and a ban was instigated. Similarly it is EU legislation that supports reestablishment efforts for species like beaver and lynx.

    1. I had the neonics debate in my mind as I was writing, knowing it was undoubtedly something positive that did come from the EU. But, again, I have to say there is a lot of farming policy sponsored by Europe that is less palatable.

  7. “creates or exacerbates the problems”

    Like what EU does with its biofuels policy. Europe’s policy and demand for biofuels and biomass is a shameful assault on forests and food supply and biodiversity in the rest of the world. Done in our name. The numpties in Brussels don’t dream this up on their own – they are prompted by unelected NGOs with TLAs.

    1. And the EU was and continues to be intensively lobbied in favour of biofuels by our own NFU and our government representing NFU during European agri-policy negotiations.

  8. I wonder what sort of country we are thinking about for the future ? The always rather wishy-washy anti-EU case always seems to look back to some golden age of Britannia, free and ruling the waves whereas surely the reality is a rather small island becoming increasingly insignificant as the rest of the world passes it by. maybe we’ll all keep warm remembering Churchill and if we don’t go anywhere it’ll be fine; like people trapped behind the iron curtain we won’t know what we are missing.

    But surely this is a nation built on internationalism and isn’t its future more international today than it has ever been ? And just in case you are under the sort of illusion Richard and others seem to suffer from, no it won’t be the same – I reckon we’ll quickly lose at least 1 in 5 jobs and there won’t be any BMWs because no one will be able to afford them. I can’t remember when a US President previously interfered in our domestic affairs in the way Barrack Obama did when he warned against leaving – and he is right. Britain is the US’ aircraft carrier off Europe as much for business as defence – here Americans find a common language and a different, but recognisable culture. But they won’t use us as their base if we leave the EU.

    There is no doubt in my mind that constructive engagement is the sole way forward – and for that we need a Government friendly to the EU, and not playing the divide and rule games that won us the epithet of ‘perfidious Albion’. I believe we have much to offer, not least in the best of our environmental thinking so we need to be more engaged on the basis it must be made to work. There really is no exit route from this one.

    1. Thank you for the comment, Roderick. I do hope I wasn’t “wishy-washy” as you so kindly put it. I’m certainly not harking back to days gone by in expressing my thoughts; personally I don’t remember Churchill, other than from the history books. Indeed, the basis of the blog was the case against remaining in the EU from an environmental perspective, not economic, political or social. However, I’d be very interested to see the evidence for your forecasts of financial armageddon and catastrophic loss of employment as a direct result of leaving the EU. No politician or economic commentator that I have heard or read has been able to articulate why it should be so, despite claiming it.

      That said, I do agree with you. In a progressive and rational Europe we should be leaders. But I don’t believe we have a progressive and rational European model as things stand.

      Thanks again.

    2. I don’t think anyone suggests the decline of the UK economy would happen overnight – just that it would become a much less attractive place for inward investors as our “internal” market would be so much smaller than it is with us as a member of the EU. And we would have to comply with most of the internal market rules anyway to export our goods and services to what is still our largest market, and as our neighbour is likely to remain so.

      London certainly does have a real leadership position in international finance and foreign exchange markets – but the £ is not a major currency any more so I feel this would slowly decline as well. Why would China and India operate through London if their trade is mainly with the wider EU? Many of the claims made about the benefits of being outside then compare our performance with Germany’s export performance with China and India, and they are within the EU. Surely they have a better business model, more medium size local companies supported by local banks, looking to provide world class manufactured goods that are essential components of other investments – like lifts, air conditioners etc.

      I feel our relatively poor productivity record and poor record of turning innovation (which we are good at) to market results would simply get worse outside the EU.

      As for the environment, most Governments need a reminder and the EU provides that. One reason Italians feel they benefit is that the Commission provides this for their Government’s financial management.

  9. I once heard a lady from Norway on the radio talking about being in or out and she said (I paraphrase)
    “Why vote to be out of it with no say in its operation when your life and country are so heavily influenced by its decisions and rules?”

    Also, although its nice to hypothesize, no-one is saying what the mechanics of the vote would be. I confidently predict the people of Scotland voting No. If in the unlikely event of the rest voting yes, then break up of the UK and an EU border Carlisle to Berwick.

    1. I think using Scotland as an example is a good way of looking at this problem because the EU was quick to point out that Scotland would have to re-negotiate its place in the EU should they vote for independence. The interesting side to this is that just about everyone in Scotland irrespective of the way they actually voted, wanted to stay in the EU. It was the one thing Alex Salmond (yes, I know it was not about the SNP but it is still true to say they were driving the ‘No’ vote without any manifesto to back what they were saying) never came up with an answer to and may have even arguably, lost the vote in the end.

      As I said above, the good thing about the EU from the environmental perspective is that it provides a background to reference policy against. I notice some people are referencing the WCA 1981 but putting aside differences about control of native species, the act has the flexibility to be changed when circumstances permit or when needed, as happened in 2005. I would be very concerned that the WCA 1981 was to replaced as per some comments here and that would be pretty much a given if the UK left the EU.

  10. Does anyone have a good understanding of what would happen to the farm subsidy system (both environmental and Pillar 1) if we left the EU?

  11. Alan, assuming we would then have a UKIP controlled government their manifesto would suggest that part of the savings from our contribution would go to agricultural support within the UK, bit vague but I’m sure they will work out the detail !

    Richard, the Neonics ban I would suggest was completely the opposite of your reading of what happened. The temporary ban was brought in with no thought as to what the consequences would be on the usage of alternative insecticides and led to a massive increase in the use of synthetic pyrethrum followed by a last minute decision to allow the use of Biscaya insecticide (which is a Neonic) to deal with the flea beetle issue in oilseed rape last autumn. Large area of crop were lost after massively increased pesticide use which failed in those instances.

    1. Julian, what is the evidence for ‘no thought’? It seems a bold assertion given that the decision was made following extended consideration by the EFSA. As is the claim that large areas of crop were lost – at any rate in the context of a widespread belief promoted by a disreputable journalist that this means large percentages. In fact 2.7% of the crop was lost of which half was redrilled. Source HGCA.

      Sorry about the FLAs.

      1. Loss of Oil seed rape crops due to the neonic ban has indeed been grossly misrepresented by the NFU and journalists of a certain jaun. Buglife has managed to correct some of the misinformation:-

        The loss of this year’s autumn planted crop was indeed c.2.7% with half replanted. Last year’s spring sown Oil seed rape had a good harvest without neonics (despite what you might believe from the NFU propaganda).

        The decision to permit the use of Biscaya (Thiacloprid) on OSR flea beetles will no doubt have to be reviewed following yesterday’s ruling in a German court that the chemical does harm bees –

  12. For all its imperfections I believe we are better in the EU than out. One reason for this is that I believe that countries such as Switzerland and Norway find that they are obliged to follow and apply EU policies and decisions in all sorts of areas but have no say in how these policies are made or what they should be. As the EU is our major trading partner we would certainly find ourselves in the same boat. Within the EU at least we can seek to work with other members states to reform the organisation.

  13. Dear Richard

    You do not present a strong positive environmental case for BRexit. You say the advantages would be “reduced bureaucracy” and “abandonment of some damaging practices and subsidies”. This is a common mantra, but what does it mean in practice and, if there are such positive actions to be taken, why can’t they happen across the EU?

    You conclude with three examples. In two of the examples the UK Government has taken wildlife damaging decisions despite the presence of EU legislation which might suggest the actions should not happen (and Lydd is a full-on long-term wildlife tragedy). But these simply present an argument that the EU legislation should be strengthened because national governments are finding loopholes.

    The third example highlights the benefits that British conservationists can have on wildlife across the EU by being a member. The UK played a strong role in developing the wildlife Directives, Stanley Johnson, dad of Boris, is largely credited with being the political force behind the Habitats Directive. While it is disappointing that some countries have been very slow to implement the Directives progress is being made and UK residents are making powerful and legitimate representations to resolve outstanding issues. This would not be possible if we were just an outsider throwing stones in.

    The point has been made that without the EU the UK would have continued to allow the use of bee destroying neonicotinoid pesticides. The bigger point here is that is a world full of wealthy multinational companies nation states are played off each other and bullied into submission. The people need a larger scale of democratic representation to be able to regulate the increasingly powerful industrial forces. The UK Government has repeatedly shown itself to be in the pocket of agro-industry. While you may hope that an independent UK could introduce more environmentally productive subsidies there is a greater risk that the ‘food security’ agenda, rocked powered with agroindustry finance, would dominate the national priorities.

    Frankly there is more to be gained for the environment by engaging with the Transatlantic Trade and Investment Partnership (TTIP) negotiations between the EU and US and persuading our democratic EU representatives to be absolutely robust in protecting the environment from litigious pressure from multi nationals, than could be gained by BRexit.

    You present a convincing case that the UK Government cares less about the environment than the EU appears to, but also that without the engagement of UK people in supporting the EU wildlife conservation agenda it could slip backwards very quickly.


  14. Hi! Matt

    Thanks for taking the time to write; food for thought, indeed!

    If I believed that continued membership of the EU would lead to increased levels of protection, comprehensively enacted by all member states, policed by an authority empowerd to act to prevent illegal activities before they do damage, and rigourously enforced by a centralised judiciary when necessary then my position would be different.

    I completely agree with you that UK government policy, recently in the case of neonicotinoids but going further back and involving both Conservative and Labour administrations, leaves much to be desired. Clearly the farming and chemical industries (and others) wield far too much power, used for their own profit-led benefit rather than the greater good. But, is it not more realistic to influence and shape national policy than international/European. You, I imagine, must deal with politicians at different levels of the hierarchy; where do you have most success? My hunch would be that it’s at the lower levels where local people directly affected by change are prepared to act to safeguard their natural world. I’d like to be convinced otherwise because we will clearly never halt and reverse global biodiversity loss by only working in our backgardens.

    To go to the other extreme, truly global rather than just European, I refer to the CBD as further commitment by the UK to act responsibly. I don’t really believe the UN is the answer, largely because it is a toothless organisation, but it highlights another point that influences my position. I spent a lot of years working in some very big companies – global companies. I came to the conclusion that, without exception, those companies have become too big, to the point that no-one, expecially the people at the top, knows what is going on further down; they are too far removed from the action (HSBC appears to be a very good example of this, right now!). Does the same philosophy not apply to government; bigger is not always best.

    We are losing biodiversity rapidly. Climate is changing rapidly. We’ve recognised both for some considerable time now but, fundamentally, the world prevaricates and does little. Whether it’s at national, European or International level, something needs to change becuase the status quo is failing us.

  15. Interesting food for thought Richard. I think that EU membership is more important for anti-pollution reasons than for conservation reasons. I know more about the former than I do about the latter (as Mr Avery regularly points out to me…). British air would be even dirtier were it not for EU legislation (also drafted in part by Boris´dad Stanley). Pollution is obviously transboundary. The UK has better climate and energy policies than most other EU countries do (Sweden is best in my opinion). All three DECC secretaries have helped the UK make EU climate policy less weak. (Granted, it´s still pretty weak.)

    Canete is not just an oil man – he´s an oil and gas man. So he hates coal. Fine by me!

  16. Dear Richard

    “You, I imagine, must deal with politicians at different levels of the hierarchy; where do you have most success?”

    It’s a good question without a simple answer. Buglife is engaged with promoting both established and new policy issues. Often we will be bringing issues to the attention of decision makers that have not previously been brought to their attention, or put in front of them. Local, national, UK and EU structures each have their own strengths and weaknesses.

    Local government can be good for the environment where the issue is easy for the lay person to comprehend and fits within a clear policy framework. But it can be impossible where the local authority lacks ecological expertise (35% of councils), the policy is unclear, or they are afraid of legal challenge by the commercial interest.

    Country governments can be very accessible and open to wildlife issues, but can lack the ability to gather a substantive independent evidence base or to buck the UK position.

    Broadly UK Government has been poor at engaging on wildlife issues, although there are some exceptional MPs (see for instance this speech The economy, health, defence and climate change are all serious and important, and wildlife is seen as a side issue. Although the UK is a good level for the generation and collation of scientific evidence, this is regularly trumped by ideology. In addition the UK civil service is uniquely defensive. When approached about a problem the civil service seem to consider it their proper duty to make the issue disappear, this involves telling you that 1) there is no issue, and failing that 2) there may be an issue but it is being addressed by current efforts. The default denial and obfuscation of the UK civil service creates a confrontational process rather than a collaborative process. Often it appears that the UK refuses to act on environmental issues unless there is a court ruling forcing them to do so.

    I find the European Commission the easiest level of government to talk to – they have genuine expertise in their policy areas, they are not afraid to be ambitious for their objectives and want to see progress, they will tell you what the blocks are to that progress and how these could be addressed. But of course there are big departments who don’t necessarily agree (e.g. over CAP) and a complex set of accountability to the EU Parliament and national governments – so it can be frustrating. To circumnavigate political difficulties, often created by conflicting ideological positions, the EC often resorts to science and evidence – which is generally good for wildlife.

    There are advantages and disadvantages to being big. However in a world with big commercial interests we also need big democratic representation to prevent the distortion of priorities and to protect the consumer and the environment.

    Hope this is interesting.


  17. Matt I wish I’d lost only 2.7% of our rape crop, just re drilled a further block today with spring beans which takes my losses up to 80 hectares out of 500 hectares which excludes the amount I had to re drill last autumn which was considerable. I will be cutting my area of rape by 50% next year as I simply can’t afford those sort of losses especially when the insecticide cost has reached ridiculous levels of both cost and product. If I still can’t succesfully deal with that reduced area in terms of sprayer capacity, as in some circumstances it takes up to five applications of pyr. to control the flea Beatle I will stop growing rape completely.

  18. Well Julian, its your call, and minimising risk is important to balance against maximising income.

    I am sure that you are weighing into the equation the following factors:-

    In 2014 very early cropping and very dry September provided ideal conditions for cabbage stem flea beetle to thrive. Losses may have been the same with neonic seed treatments.

    The NFU ‘neonic ban will destroy farming’ campaign of fear will no doubt persuade many farmers to reduce the area of OSR planted next year.

    Less crop usually means higher prices.

    Soil and climate are important in the equation, some areas had no CSFB problem at all.

    Having had CSFB last year it may be more likely you will have it again next year?

    What do you think about farmers applying 5 pyrethroid treatments? It seems difficult to justify? Are the beetles resistant? Has the prophylactic co-treatment of seeds with neonics and pyrethroid created resistance?

    More here:-

  19. Well Matt !

    Loads of questions there;

    Csfb last year so more/less likely this year. My guess is no difference, used Cruiser since it came out and had no issues until the ban when the levels were epidemic so there obviously quite resilient to year on year Neonics.

    Five pyrethroid plus Biscaya on some fields in a lot of cases. Its a nightmare and to be avoided at all costs however if you have just spent £75/ha on seed, £16/ha on slug control and say £60 on cultivations its worth risking £2.50/ha on pyrethroid per application or £12.50/ha + fixed costs to try and save the crop. Biscaya would be £12.50/ha.

    As for dropping rape from the rotation totally my point would be that no one action can be seen in isolation within a crop rotation, its not a simple binary choice (hate that word) and in this case rape volunteer plants post rape harvest provide a very effective anti slug cover crop for the next direct drilled wheat crop. Without it my use of molluscicides would go up substantially. My argument to counter yours in this particular case would run something like; Is would a reduction to a 50% rate Neonics as a seed dressing be better than 5 x pyrethroid (0.25lt x 5 applications i.e. 125 grams product) + 0.30 lt Biscaya plus extra slug pellets in the following crop ??

    As for your blog I just think you are kidding yourself based on a desk top exercise. (sorry not meant to be rude but I just couldn’t think of a better way of saying it) HGCA figures take no account of the extra actives applied to treat the percentage of the crop which sat between your 2.7% and whatever the percentage was of the crop which was unaffected by csfb and had to be treated with Biscaya. Good point ? In addition to this those figures are just those from last autumn and do not include crops which were attacked by csfb into late October and early November before the temperatures dropped. Its these crops which were then weak and subject to pigeon damage which are being lost this spring.

    Just as an aside I spent some time the other day with a group of soil microbiologists, plant breeders and biologics and a well respected place which will remain nameless and the conversation got round to SA and other NGO’s and the unanimous view was that on no account would they ever consider taking them on in a public debate on any issue which was within their policy portfolio. I was a bit conserved about that comment.

    1. Dear Julian

      The difficulty with natural systems is that all sorts of factors are at play and attributing an outome to one of the factors is difficult.

      In this instance I am questoning wether neonicotinoid seed treatments on OSR had a significant effect on yeilds. It is an important question to address because average yeilds do not significantly change when neonicotinoids are introduced or removed from national farming systems. Also in the USA it has been shown that the near universal treatment of soyabeans “provide little or no overall benefits to soybean production”

      We know that in years with weather like that in 2014 there are many more CSFB than in other years, we don’t know that in years with less neonicotinoids there are more CSFB.

      Did you use “Five pyrethroid plus Biscaya on some fields in a lot of cases” on your farm?

      “HGCA figures take no account of the extra actives applied to treat the percentage of the crop which sat between your 2.7% and whatever the percentage was of the crop which was unaffected by csfb and had to be treated with Biscaya.” – I think their figures indicate that 40% of the crop needed to be treated, I don’t quite follow your Biscaya point.

      Yes, not engaging with a public debate is a risky strategy, but I think they may believe that there are other ways to get the outcome thay want.

      Looking foward to seeing you in June.


  20. I remember the UK being called ‘The dirty man of Europe’, because of the various opt-outs our leaders extracted from the EEC.

    What worries me is the fervour of the Conservative right and the likes of UKIP to be forever wanting to roll back legislation. Of course we are concerned that Juncker may abolish some controls on pollution, agribusiness and all sorts but our own politicians have long been complaining about European rules. I don’t expect them to be in a hurry to bring in firmer legislation than the EU. (Tory or Labour dominated)

    Whichever way the politics go, I think we have to fight very hard to hinder the juggernaut of economic growth.

  21. Thanks Matt, see you in June and yes I did I’m afraid; also quite concerned about the levels of csfb lavie within the stem base of rape plants at the moment. This is something which I didn’t see previous to cruiser use however we didn’t have widespread resistance to pyrethrum at that point. I was with another farm manger who runs 12k acres today and he confirmed my observations. I think we are going to see a lot of pre senescence in July with considerable yield losses. I gather that Dow have a new seed treatment out which is not pyrethrum, Neonics or Op based and are applying for EU fast clearance for this Autumn ?

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