From: Margaret Wilson, President

Circulation: by Leigh Sidaway, General Manager, to: Area Associations and Branch Secretaries

[ A sequel to the President’s February letter and subsequent update on the issue of a return to the use of neonicotinoids for sugar beet crops this year. ]

Last month I indicated that we were taking steps to prevent the use of neonicotinoids on the sugar beet crop. We pursued this with the help of two barristers and a solicitor.

The Wildlife Trust was also involved and following a similar process, using a Pre-action Letter and a Judicial Review. I contacted them to ask if we could work together but unfortunately their policy is to work alone on legal matters, but they have shared information with us that has been very helpful.

The derogation is only for this year but with a proviso that it could be applied again in 2022 and 2023, each being a separate action.

[Read more…]

Protection no longer required due to colder weather means less risk to the crop. Environment Secretary George Eustice said emergency authorisation was only “granted with strict conditions”. DEFRA predictions had to show the virus would otherwise reach a certain level. “In the event, that pest threshold was not passed so this seed treatment will not be used this year,” Mr Eustice added. 3/3/2021

The BBKA had issued a letter ( downloadable from here ) and reproduced below, for circulation to all members in response to news of the Government announcing the Emergency Authorisation (derogation) for the limited use of the neonicotinoid seed treatment – thiomethoxam (Cruiser SB) for sugar beet for 2021.

Had you wished to comment on the draft National Action Plan for the Sustainable Use of Pesticides, a link to the DEFRA Consultation is at the of the BBKA letter.

In addition and quite separately from the BBKA letter, below the letter the link is provided to the 38 Degrees online petition calling on the UK Government to Continue the ban on insect-damaging neonicotinoid thiamethoxam on all crops.

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Date 11th January 2021

From
Margaret Wilson – President BBKA
Anne Rowberry – Chair BBKA
Pam Hunter – Manager Research, technical and Environmental, BBKA

Beekeepers will no doubt have seen the news that the Government announce the Emergency Authorisation (derogation) for the limited use of the neonicotinoid seed treatment – thiomethoxam (Cruiser SB) for sugar beet for 2021.

The major points in their announcement are as follows:

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The advice of the Health and Safety Executive (HSE), the UK Expert Committee on Pesticides (ECP), and Defra’s Chief Scientific Adviser on the application was put to Defra Ministers. Based on the information provided, the Secretary of State considers the application meets the requirements for an emergency authorisation and has therefore decided that authorisation should be granted, subject to a number of conditions.

An emergency authorisation for the short-term use of a product (and placing on the market for no more than 120 days) may be granted if the following requirements are met:

• the authorisation appears necessary because of a danger which cannot be contained by any other reasonable means (the case for need)
• use of the product will be limited and controlled
• there are special circumstances

Emergency authorisations are a derogation from the normal requirements of pesticide authorisation. However, if the above requirements are met then the benefit of granting an emergency authorisation must be balanced against the potential harm from the proposed use of the product, taking into account the proposed conditions. Therefore, the potential risks to people, animals and the environment remain a key part of the evidence that needs to be considered.

The neonicotinoid seed treatment provides important protection to the emerging crop against insect pests and the viruses they can transmit. This protection cannot be provided by any other reasonable means. Sugar beet yields were significantly reduced in the 2020 season due to the incidence of virus, and similar conditions in 2021 would be likely to present similar dangers.

The applicant proposed a reduced application rate for the seed treatment to deliver less of the product to the soil. In addition, the applicant proposed use of a virus forecasting model to determine whether treatment is needed, setting a threshold for the level of virus infection above which economic impacts would be incurred. If this threshold is not met the seed will not be treated. Sugar beet cultivation in England is also spatially restricted by proximity to 1 of 4 beet processing factories situated in the east of England. All UK sugar beet is grown under commercial contracting arrangements, and this is considered to provide an effective mechanism for controlling the distribution and use of the treated seed. To address the requirement to control use, the applicant proposed a stewardship scheme which includes several measures to address risks to pollinating insects, underpinned by industry commercial contracting arrangements.

The applicant outlined a plan for developing alternative, sustainable approaches to protect crops without the use of neonicotinoid seed treatments. This includes the development of resistant plant varieties, measures to improve seed germination and new practices for growers. The plan is already being delivered. The plan is considered to provide a good basis to confirm that alternative, permanent solutions to neonicotinoid seed treatments for sugar beet are being sought as a matter of priority. The plan anticipates that applications for emergency authorisations for neonicotinoid seed treatments may be needed for three years (2021 to 2023). Any future applications will be fully assessed against the regulatory framework for emergency authorisations.

Risks to bees

Sugar beet is a non-flowering crop and the risks to bees from the sugar beet crop itself were assessed to be acceptable. The applicant recognised that risks could be posed to bees from flowering weeds in and around the crop and proposed to address this with the use of industry-recommended herbicide programmes to minimise the number of flowering weeds in treated sugar beet crops. This was considered to be acceptable. The applicant recognised that the persistence and mobility of neonicotinoids in soils could result in residues with the potential to cause unacceptable effects to bees in following crops. Measures were proposed to mitigate the identified risks through the exclusion of flowering crops in subsequent cultivations.
The Secretary of State is satisfied there is sufficient evidence to indicate that residues of thiomethoxam and its metabolite deteriorate over time, and that with mitigation measures in place the risks are considered to be acceptably low enough that the benefits outweigh them. Conditions are attached to the emergency authorisation to ensure that no flowering crops are planted as following crops for a period of at least 22 months, with an extended period of exclusion for oilseed rape (of 32 months), to minimise the risk to bees.

The authorisation is for the use of Syngenta’s Cruiser SB on sugar beet only and covers use in 2021 in England only. Conditions are attached to the emergency authorisation to ensure that, if the threshold for virus levels is reached and it becomes necessary to treat seeds, use of the product will be limited and controlled and any potential risks to pollinators will be mitigated to an acceptable level. In particular, the application rate of the product will be below the normal commercial rate; no flowering crop is to be planted within 22 months of the sugar beet crop, and no oilseed rape crop is to be planted within 32 months. Industry-recommended herbicide programmes will be followed to limit flowering weeds in and around sugar beet crops. The applicant will be required to limit the sowing rate of treated seeds to achieve no greater than the normal commercial plant population, and to develop and implement their proposed programme to monitor soils and plants following use of the treated seed.

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The BBKA is extremely disappointed and concerned at this derogation. It is to be hoped that the mitigation steps mentioned are followed carefully, including a reduced rate of application of thiomethoxam. Increased uses of herbicides to reduce flowering weeds, however, we regard as having potentially damaging effects on the environment generally. It is particularly concerning that this derogation may continue for two more years. It is to be hoped that any such decision is discussed more fully especially since the farming press in the autumn did not indicate any more dramatic effects on the crop in 2020 when compared with a range of other crops all struggling with an exceptionally difficult year from problematic weather conditions.

There is a draft National Action Plan for the Sustainable Use of Pesticides which is open for public consultation. We would urge you all to read this and comment on the document as soon as possible. (An example is P.21 Q2 which asks about increasing transparency for informing decisions).

https://consult.defra.gov.uk/pesticides-future-strategy/sustainable-use-of-pesticides-national-action-plan/.

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In addition to the DEFRA public consultation; if you have not already done so via the WhatsApp RBKA Crew prompts, you may be interested and motivated to sign the 38 Degrees online petition, calling on the government to …Continue the ban on insect damaging neonicotinoid thiamethoxam on all crops. (with thanks to Keith Mackie for first posting the petition on WhatsApp RBKA Crew on the 10th Jan 2021)

http://chng.it/mZFkF4Phqs

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