Butterflies, moths and bees as bedfellows

© Butterfly Conservation

© Butterfly Conservation

Katie Cruickshanks

Butterfly Conservation joined the Bee Coalition in 2016 as we were impressed by the messages coming out of the coalition and knew that we had to be a part of it. Our mission is to save butterflies moths and our environment and whilst the Bee Coalition is a natural place for us to be we felt that it was worth talking about butterflies and moths as pollinators, indicators and as part of functioning ecosystems. Our success as a species’ conservation NGO, has rested on a long history and obsession with Lepidoptera among British naturalists, dating back over 300 years and popularised by the Victorian collectors.  Butterflies are incredibly beautiful insects and have been revered and collected culturally for centuries.  They signify beauty and change through metamorphosis and these traits have been a big driver in the amount of research and data that we have at our fingertips today. 

Here at Butterfly Conservation we have worked for nearly 50 years primarily on the conservation of rare and declining species of butterflies and moths in the UK. In the last decade, the plight of more common and widespread species has shifted up our agenda.  In our recent State of Butterflies in the UK report (Fox et al., 2015) we communicated some devastating statistics about our ‘wider countryside’ species. Since 1976 our common species have declined by 25% in the UK and 30% in England.  Five of the 10 butterflies that have suffered the most severe long-term declines are wider countryside species.  These are iconic species which we associate with a healthy countryside such as the Small Tortoiseshell and Wall Brown which have declined by 73% and 77% respectively since 1976.

Our ability to produce accurate annual trends on all UK species is wholly dependent on an army of dedicated UK Butterfly Monitoring Scheme volunteers who walk regular transects at over 2000 sites each year.  This phenomenal data set has been growing since 1976 and it continues to be the most comprehensive and long running invertebrate monitoring scheme in the world.  Coupled with 11 million casual butterfly records and nearly 23 million moth records used to map distribution and model site occupancy over time, we have a uniquely powerful dataset on a subset of invertebrate pollinators.

So what does this mean for the Bee Coalition? Bees are the headline grabbers in these harrowing times of fears over ecosystem services, pesticides and food production.  Bees are undoubtedly the most commercially significant group of insects (followed by hoverflies) when it comes to getting food on to our plates.  But it’s the diversity of pollinators that is important for pollination for all our wild flowering plants.  This underpins all our flower rich habitats and their biodiversity further up the food chain.  Whilst butterflies and moths might not be out there doing the pollination leg work for commercial crops such as soft fruits, beans and apples etc., there are over 2500 species of Lepidoptera most of which are visiting flowers in the adult stage of their life cycle. Such a high level of diversity for one group of flower visiting insects is a compelling case for their importance especially when compared to 270 species of bees and 280 species of hoverflies. 

Butterflies and moths are equally at risk from the impacts of pesticides.  The major focus of the Bee Coalition’s work has been action on neonicotinoids and Butterfly Conservation is in full support of this campaign. We undertook some research with the Universities of Sussex and Stirling and the Centre for Ecology and Hydrology which showed that the number of hectares of farmland where neonicotinoid pesticides are used is negatively associated with butterfly indices (Gilburn et al., 2015). The study found population trends of 15 species showed declines associated with neonicotinoid use, including Small Tortoiseshell, Small Skipper and Wall species. Whilst a causal link between butterfly and moth mortality and neonics use is yet to be confirmed in the UK, there is strong evidence from Monarch caterpillars and their success in the USA (Pecenka and Lundgren, 2015).

The diversity of life stage requirements within the 2500 species of moths and 59 species of butterflies in the UK adds strength to their importance as flower visiting insects and pollinators.  Whilst all pollinators undergo the four stage life cycle (egg, larva, pupa, adult), the sheer number of Lepidoptera species means that conserving habitats for them will go a long way to helping other pollinator groups.  Firstly the larval stage for butterflies and moths is dependent on specific foodplants.  For common and widespread species this may be as generic as polyphagus moths feeding on deciduous trees such as oak, birch and willow species, through to highly specialised species whose larvae feed on only one, often rare, plant species. The range of larval foodplant requirements across Lepidoptera translates into a need for a diverse wider countryside coupled with expansion and conservation of rare habitats and plant species for breeding. 

Most species of butterfly and moth overwinter in a non adult stage (mostly in the larval stage). Moths, in particular, are known to inhabit all habitats from the shoreline to the mountain top and occupy a wide variety of ecological niches.  There are British Moths whose caterpillars feed on roots wood, aquatic plants, lichens, algae, honeycomb, fungi, dung, fur and feathers. However, at least a third of moths over winter inside vegetation as larvae or pupae and around two thirds of butterflies do the same. Once they have completed the larval development stages by feeding on the plant material of choice, many of them seek longer tussocky vegetation, dead seed heads and hollow stems for the winter.  It is these pockets of uncut, untidy vegetation that are supporting the next years populations of butterflies and moths, not to mention a whole suite of other pollinators (bees and hoverflies included) that require tussocky vegetation for nesting and overwintering in the wider countryside.

Beyond pollination services, butterflies and moths are important food sources for taxa further up the food chain.  Birds and bats in particular are documented to consume huge numbers of Lepidoptera especially the larval and adult stages.  There is an estimate of 35 billion caterpillars consumed by Blue Tit chicks annually in Britain alone. All 16 species of bat in the UK feed on adult moths to some extent and for at least 10 species, moths make up a substantial part of their diet. 

Maintaining strong populations of Lepidoptera in a well-connected and diverse countryside will generate multiple benefits for insectivorous species and will support habitats for a wide variety of other pollinators and insects including those commercially important bees. The management tools to delivering these outcomes are well known: conserving priority habitats and species, looking after and buffering the pockets of semi-natural habitats, decreasing the intensiveness of farmland, encouraging better connectivity of habitats (hedgerows and margins), rotational management- leaving areas uncut over winter and creating more flower rich areas to provide vital pollen and nectar resources. With this knowledge, the wealth of scientific evidence and data, coupled with strong partnerships between NGOs, the public and others we can help create a countryside that’s rich and abundant in flower visiting insects. Harnessing public support and ensuring that this message gets through to governments and decision makers is what the Bee Coalition is about. Adding our voice to the Bee Coalition was an easy decision for us at Butterfly Conservation.

References:

Fox, R., Brereton, T., Asher, J., August, T., Botham, M., Bourn, N., Cruickshanks, K., Bulman, C., Ellis, S., Harrower, C., 2015. The State of the UK’s Butterflies 2015.

Gilburn, A.S., Bunnefeld, N., Wilson, J.M., Botham, M.S., Brereton, T.M., Fox, R., Goulson, D., 2015. Are neonicotinoid insecticides driving declines of widespread butterflies? PeerJ 3, e1402.

Pecenka, J.R., Lundgren, J.G., 2015. Non-target effects of clothianidin on monarch butterflies. Sci. Nat. 102. doi:10.1007/s00114-015-1270-y

BEE EMERGENCY CALL

© ClientEarth

© ClientEarth

How some Member States are threatening bees by allowing the use of prohibited pesticides and how the Commission does nothing to stop them

Member States are ignoring the ban on bee-harming pesticides and are continuing to use them across Europe. The Commission has the power to curb this alarming trend, however, it is doing nothing to stop it.  

The high honey bee colony mortality rate across the EU has been repeatedly linked to pesticide use, particularly neonicotinoid insecticides. Neonicotinoids are a class of systemic pesticides that are taken up by plants and transported to all tissues, consequently making all parts of the plant poisonous to pests.

As a result of overwhelming evidence, four bee-harming pesticides (including 3 neonicotinoids and 1 other pesticide) were banned across Europe in 2013. The ban of these pesticides is crucial to assist the recovery of bee populations in the face of dramatic declines. 

Unfortunately, Member States are using a provision in a piece of EU legislation (the Plant Protection Products Regulation) to circumvent the ban on bee-harming pesticides.  This provision says that Member States can grant ‘emergency authorisations’ to use non-authorised pesticides in ‘emergency situations’.

This means that where there is an ‘emergency’, for example, an infestation of a pest that cannot be controlled any other way, Member States can use bee-harming pesticides.

Member States are not using this provision in the correct way as envisaged by the law. Since bee-harming pesticides were banned in 2013, Member States have granted an alarming 62 emergency authorisations for bee-harming pesticides.

Beelife, ClientEarth and PAN Europe have obtained the documents that Member States submit to the Commission each time they authorise a bee-harming pesticide. These documents reveal the following:

1. Member States are not proving that there are ‘emergency situations’ that require the pesticide use

The majority of Member States are systematically failing to provide the Commission with the information required to prove that the use of a bee-harming pesticide is necessary because of an emergency.

Member States must show the Commission that there is a danger to agricultural production, for example a pest, which cannot be controlled in any other way, except by using a pesticide that is not authorised.  Also, because of the harm that the pesticides can cause, Member States must also prove that the pesticide will be used in a limited and controlled way.

The majority of Member States do not provide the Commission with any information to prove that:

  1. there is a danger to their crop;
  2. there are no other ways of controlling the danger; and
  3. the pesticide use will be limited and controlled (in terms of area and mitigation).

Because Member States do not do this, they are not complying with EU law.

2. The Commission is allowing Member States to get around the ban

It is within the Commissions power to question the emergency use of a bee-harming pesticide but it has never done so.

When a Member State provides information to the Commission on an emergency authorisation, the Commission can ask the Environmental Food and Safety Authority (EFSA) for an opinion on this information. The Commission also has the power to propose that a Member State withdraw the use of the pesticide.

As discussed above, the information provided to the Commission has been systematically deficient and as a result, Member States are not complying with their obligations under the law. However, the Commission has never used its power to question an application or even request more information from the Member State. 

The Commission is choosing to ignore inadequate notifications that are clearly being used to circumvent the bans and as a consequence, they are condemning bee populations to further decline.

3. The pesticide and seed industry are applying for most of the emergency authorisations

The Commission has said that:

emergency use[s of non-approved pesticides] are meant solely to be in the interest of agriculture, environment and governments. Applications solely based on industry interests should be refused.’

The Commission is not heeding its own advice, as a staggering 44% of the emergency authorisations notified were granted illegally because they were applied for by pesticides companies, seed producers’ associations or trading companies alone. The remaining 42% of applications were joint applications between farmer’s organisations and seed or pesticide companies.

This means that 86% of emergency authorisation applications for bee-harming pesticides in the EU were made with the participation of (and probably driven by) industry interests.

Only 14% of applications were made by farmers or public authorities, independent from industry vested interests. 

This means that the industry is utilising the exception in the legislation as a loophole to get around the ban.

Recommendations

In light of the continuous abuses of Article 53 over the years, it is clear that it is not used in cases of emergency by Member States but rather to maintain the current highly polluting conventional farming system.

We call on the Commission to properly implement the provisions of the Pesticides Regulation so that Member States cannot exploit it as back door to using illegal pesticides. The Commission should:

  • Ask Member States to send complete and detailed notifications complying with the law.
  • Use its power to scrutinise the notifications submitted by Member States and ask for scientific or technical opinions from other EU bodies.
  • Propose to withdraw emergency authorisations that do not comply with the law.
  • Challenge emergency authorisations that are made on behalf of industry, even as a co-applicant.
  • Immediately publish notifications, so that Member States are subject to public scrutiny, and are therefore incentivised to promote greater environmental protection.

Conclusion

The EU prides itself on having one of the strictest regulatory systems in the world concerning the approval of pesticides. However, as a result of the Commission’s leniency, the continued emergency authorisation of bee-harming pesticides is making a mockery of the legislator’s decision to ban these products.

The ‘business as usual’ approach, taken by the Commission and Member States, is threatening the ability of the bans to be effective and is exposing bee populations across Europe to further harm.

If Member States grant emergency authorisations and do not provide the required information to show that the use of pesticide is an emergency, they will be breaching EU law and such cannot continue to be condoned by the European Commission.

Beyond Honey: Five reasons to protect our bees

© EJF

© EJF

Bees are brilliant. They are one of the hardest working creatures around, and they contribute a great deal to our livelihoods and our economy. But they are under serious threat.

Loss of habitat, increased spread of disease and climate change are all driving a decline in bees, and other pollinators. Meanwhile, a growing body of evidence shows that harmful pesticides – particularly neonicotinoids - are reducing the survival and reproductive ability of these amazing creatures.

In the UK alone, over half of bee, butterfly and moth species have declined over the last 50 years, and this is bringing a range of knock-on effects for society. It is in our best interest to ban the use of neonicotinoids.
 

Here are just some of the reasons why we need to protect our bees:

1) Crop Yields

Pollinating insects are responsible for one in every three of the mouthfuls of food we eat. They are crucial for maintaining the function of our agricultural systems and providing sufficient crop yields, with bees considered to be the most important pollinators. Without them, we would struggle to put food on our plates.

 

2) Economic Costs

The value of bees’ pollination services are estimated at £690 million every year in the UK alone. Without them pollinating our fruit and vegetables, we would have to do it ourselves by hand. This is an extremely expensive process, and could cost us even more - an estimated £1.8 billion annually.

 

3) Food Prices

Since a decline in bee populations would result in reduced crop yields, without them we would see food prices rise. In fact, resorting to hand pollination could see the price of an apple more than double, according to research.

 

4) Ecosystem Health

Bees are essential for maintaining the health of our natural ecosystems. Through pollination, they help plant communities to develop and ensure the production of fruits and seeds. This supports animal species that need these plants for their food and shelter.  

 

5) Honey

If nothing else, honeybees work tirelessly to make delicious honey for us and ask for nothing in return. We owe it to them to provide suitable habitats where they can thrive and carry out the pollination services that we depend on.


By Michael Spencer

Secret Pesticides Documents Revealed

© maja dumat / flickr 

© maja dumat / flickr 

Disclosures Deepen Controversy about Government’s Decision to Evade Bee-killing Pesticide Ban

In July wildlife NGOs were dismayed, confused and indeed angered by the Government’s decision to allow the use of banned pesticides proven to cause great harm to wild bees.

It seemed an incomprehensible decision in light of the growing evidence that neonicotinoids routinely harm bumblebees and solitary bees and concerns, expressed even in the Government Chief Scientist’s annual report, that neonicotinoids may not actually be improving crop yields. 

Now, new Freedom of Information disclosures have revealed that in response to NFU demands Defra agreed to let pesticide companies sell farmers neonicotinoid treated oilseed rape seeds in four counties, despite the NFU:

  1. failing to provide any direct evidence that using the pesticides would improve either crop yields or crop establishment by controlling Cabbage stem flea beetle numbers;.
  2. stating that if neonicotinoid seed treatments had been used in 2014 (as the NFU had requested) they would not have helped with the problems some farmers experienced with flea beetles that autumn;
  3. clearly stating that alternative pesticides were available.
     

Decision Timeline

An EU wide ban on using three neonicotinoid seed treatments on flowering crops was introduced at the start of 2014, because the regulator, the European Food Standards Authority, had confirmed that they posed a risk to bees. 

A Member State may legally authorise a derogation to allow the use of a banned pesticide, but only for ‘a period not exceeding 120 days’, ‘for limited and controlled use’, and where ‘necessary because of a danger which cannot be contained by any other reasonable means’.

Almost immediately the NFU requested a derogation to allow the continued use of neonicotinoid seed treatments on all UK oilseed rape.  Defra did not approve the application and it was withdrawn in July 2014.

The NFU submitted the same request again in 2015.  On 18th May the Defra Chief Scientist Prof. Ian Boyd set out a long list of short-comings in the application, highlighting particularly the absence of evidence that the neonicotinoid ban had actually caused a significant problem, and the absence of evidence that neonicotinoid seed treatments would solve any localised problems caused by Cabbage stem flea beetles.  Some of the Chief Scientist’s comments were cutting “There is very little information, other than some broad statements, to support the claim that this will have an effect upon yield.” and “The NFU submission makes almost no effort to link its assertions to verifiable, published evidence or provide appropriate, balanced interpretation of the evidence”.   

On the 20th May the Government’s Expert Committee on Pesticides met behind closed doors, but with pesticide industry employees invited and present, to discuss the NFU application. The Committee concluded that for control of flea beetles there were “no alternative chemicals authorised” and hence the application met the criteria of being a ‘danger which cannot be contained by any other reasonable means’ but that the application was not for a ‘limited and controlled’ use so they would not support it.   

The NFU then submitted a second application to use neonicotinoids on oilseed rape, relating only to Suffolk.

Over 500,000 people signed a 38 Degrees petition asking the Government to keep the ban on neonicotinoids and protect British bees and pollinators; it was presented on the 7th July to No.10 Downing Street.

On the same day the secret application was discussed behind closed doors at the Government’s Expert Committee on Pesticides.  According to an ECP official Defra wanted the public to be kept in the dark “to enable Government to have the time and space to consider applications for emergency authorisations without having to provide interim comment or provoking representations from different interest groups whose views on the issue are well-known”.  The Committee accepted that the application was sufficiently evidenced for flea beetle and limited in scale, but suggested the applicant should consider if restriction to Suffolk addressed all farms/fields at greatest risk.

It was announced in the farming press on 22nd July that Defra had agreed to bypass the neonicotinoid ban on oilseed rape in four eastern counties. 

Defra had capitulated to NFU pressure without waiting to find out how good the yields were from first oilseed rape crop grown without the seed treatments.  As the harvest came in over the following two weeks it became apparent that without neonicotinoids there had been a bumper national crop, well above average yields – in the end 3.6-3.8t/ha compared with ten year mean of 3.4t/ha.  

On the 20th August a scientific paper published by Government Agency Fera showed, firstly that there was a link between the use of a neonicotinoid pesticide and honeybee colony losses, and secondly that neonicotinoids were not providing consistent yield benefits to oilseed rape; Government had been aware of this data since January 2013. 

 

The NFU Application

On Wednesday Defra finally made the second NFU application public. 

It is clear from the document that the Chief Scientist’s initial concerns about the weakness of the evidence presented were not resolved.  There are no data, studies or scientific references provided to evidence claims that the ban on oilseed rape had reduced yields, and no new evidence that neonicotinoid seed treatments would be an effective way to reduce flea beetle populations.  Indeed the NFU admits in relation to the high levels of flea beetle seen in autumn 2014 that “Had the 2014/15 Emergency Use Approval been given, the problems seen in the east and south east of England would not have been prevented.”  A startling statement in direct opposition to the claimed purpose of the application – this should have set Defra alarm bells ringing, but was not highlighted in the subsequent opinion expressed by the Chief Scientist on 8th July.

The application also states that there are a ‘few chemical products to control [CSFB] infestation levels” and lists pesticides that can be used to combat aphids that spread a virus called TuYV – quite clearly establishing that the (unproven) ‘danger’ could be ‘contained’ by ‘other reasonable means’.  This failure to meet the legal criteria should alone have resulted in the perfunctory rejection of the application.  The deviation was further compounded by the Government concurrently approving a neonicotinoid (Acetamiprid) spray to control flea beetles.

In justifying that neonicotinoid seed treatments would protect oilseed rape from flea beetles the NFU application makes the following claim:

“In the 2014/15 planting season a number of studies have examined the impact of CSFB in the establishment of the OSR crop in the UK. Studies from the HGCA and independent research organizations have demonstrated that CSFB populations impacted on crop establishment.  Critically and as expected the majority of these areas demonstrated increased plant establishment when the OSR seed has been treated with a neonicotinoid seed treatment.”

This statement is vague, but there was a HGCA (AHDB) report produced in August comparing oilseed rape crops that had, and had not, been seed treated with neonicotinoids. However this study reported that neonicotinoids did not improve yields and did not report any difference in establishment rates – it would appear that the NFU was confused or misleading in referring to this study as providing evidence that supports the application, it does the reverse. It is, in any case, well known that small differences in “plant establishment” don’t usually translate into yield differences at the end of the year.

 

Environmental Injustice

In Prof Ian Boyd’s response to the first application he states “The same level of scrutiny and standards need to be applied to the evidence of efficacy as is being applied to that of negative effects on the environment and, at present, this does not appear to be happening.” He is quite right, the imbalance in justice highlighted is huge, the level of proof that is required to ban a pesticide in order to protect the environment is in effect ‘beyond all reasonable doubt’ – vast tomes of published scientific papers showing statistically significant results in vitro, in the lab, in the field and across whole countries are still met with calls of ‘not proven’ – while here a decision, claimed necessary to protect farmers, has been taken to un-ban a pesticide with more evidence available in the application to dis-prove, than to prove, the claims – and more evidence out in the real world that would also suggest that this derogation will not provide significant benefit to farmers (but will harm the environment).

One might hope that the pesticide regulators were carefully examining the mounting evidence that neonics are harming populations of beneficial insect predators such as ground beetles and ladybirds, and are leaching into, and destroying, aquatic ecosystems, and that they are diligently considering if a complete ban on neonicotinoids it is now the only rational response. Instead we find the regulators are sat around a table with the pesticide companies, poring over an incomprehensible mish-mash of industry claims and assumptions described by the Chief Scientist as “an advocacy document” and conspiring to hurriedly unpick hard won environmental protection measures.

 

In conclusion

From the evidence in the public domain, it seems clear, and even the NFU admit, that the flea beetle problems of 2014/5 would not have been resolved by neonicotinoid seed treatments.  It also appears that the NFU did not address the Defra Chief Scientist’s concerns: no new evidence was presented to support the claim that neonicotinoid seed treatments provide yield benefits; nor was evidence presented that showed that the high yields in the first year of the ban would have been any higher had neonicotinoid seed treatments been used. Furthermore the application provides evidence that there are alternative pesticides available, hence the criteria for an emergency derogation were explicitly not met.

The decision to allow the use of neonicotinoid insecticides on oilseed rape in the Eastern counties of England appears to have been about as far from an evidence or science based decision as it is possible to get. The imbalance between securing protection of the environment and protection of pesticide industry profits appears bigger than ever, and again it looks as if the NFU and Defra are deeply in the pockets of the agrochemical industry.

Friends of the Earth have initiated a Judicial Review of this decision; the evidence available suggests they may have a compelling case.