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Consultation on reducing the horticultural use of peat in England (Defra)

14 March 2011

Dear Sir/Madam

Consultation on reducing the horticultural use of peat in England

A response from the Association of Local Government Archaeological Officers:England (ALGAO:England)

The Association of Local Government Archaeological Officers:England (ALGAO:England) is part of the over-arching ALGAO:UK. ALGAO:England is the national body representing local government historic environment services on behalf of County, District, Unitary and National Park authorities in England. ALGAO:England co-ordinates the views of English local authority members (94 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association on historic environment matters.

The Association would make the following responses to the above consultation document:

Question 1: Do you support the rationale for taking action to reduce the horticultural use of peat?

ALGAO supports action to reduce the horticultural use of peat for a range of environmental reasons, including the destruction of the palaeoenvironmental record that peat contains of past climate change as well as the activities of our ancestors. This is destroyed directly through peat cutting and indirectly through drainage of wider areas than that earmarked for extraction.

Question 2: Do you agree that a better supported, industry-led voluntary approach is the right way forward?

ALGAO is concerned that a voluntary approach will not deliver the desired change either within timetable or to the extent required. The voluntary approach should be accompanied by incentives to change such as some form of environmental levy or taxation that would make peat-based products more expensive. Such a charge could be tapered-in, making such products increasingly more expensive over time, both to encourage reduction and the development of more-appropriate sustainable alternatives.

There should be well-publicised fixed targets for the industries involved e.g. both peat producers and users, so that government’s intent is seen to be serious and transparent and can be monitored easily by those involved as well as the wider public with an interest in seeing peatlands preserved rather than destroyed.

Consideration needs to be given also to measures designed to halt the import of peat from other countries which it is considered will almost certainly require government intervention.

Question 3: Do you agree that these are the core criteria that should guide the development of a future policy framework?

ALGAO agrees that these core criteria should guide the development of a future policy framework but, as in the response to Q2 above, considers that incentivisation is required both to stimulate development of sustainable alternatives as well as to develop and deliver a credible and effective policy that is translated into tangible and appropriate action.

Question 4: Do you agree that the horticultural use of peat can and should be phased out in all markets, and for all plant species and growing media products? Based on evidence where possible, should there be any exceptions to this?

ALGAO considers that horticultural peat should be phased out in all markets and for all plants. There should be no exceptions to this policy, for the avoidance of doubt and future debate/argument and to stimulate development of sustainable alternatives.

Question 5: Do you agree (based on evidence where possible) that peat can and should be phased out of all public sector procurement activities, including Local Authorities, by 2015?

ALGAO agrees that peat can and should be phased out of all public sector procurement activities, including Local Authorities, by 2015.

Question 6: Do you think that there is more that Government and the public sector should be doing to support and enable the switch to peat-free growing media? If so, what would be the priorities?

ALGAO considers that some form of environmental levy or taxation should be introduced that would make peat-based products more-expensive and therefore less attractive, incentivising the development of and change to sustainable alternatives. Market forces should then reduce the up-take of such products during the period of reducing production/sale.

Consideration should also be given to advising relevant planning authorities that planning permissions should not be granted for any activities whose principal aim is the commercial exploitation of peat deposits.

Question 7: Do you agree (based on evidence where possible) that the use of peat in soil conditioners can and should be phased out by 2013?

ALGAO agrees that that the use of peat in soil conditioners can and should be phased out by 2013.

Question 8: Do you agree (based on evidence where possible) that the use of peat in the amateur market can and should be phased out by 2020, and that the proposed interim milestones are sufficiently ambitious and achievable?

ALGAO agrees that the use of peat in the amateur market can and should be phased out by 2020, and that the proposed interim milestones are sufficiently ambitious and achievable, particularly if additional incentivisation occurs through some form of environmental levy that makes peat products, perhaps increasingly, more expensive from now until 2020, as suggested above. Consideration should be given to using the returns from such a levy – once reasonable administrative costs have been deducted – for the restoration of peat extraction areas and further safeguarding of intact peat bogs and perhaps as a small contribution towards the costs of the development of sustainable alternatives.

Question 9: Do you think that more needs to be done to build consumer awareness,

improve labelling or improve and standardise the quality of growing media products? If so, what would be your top priorities? ALGAO considers that an enhanced and continued publicity exercise is required to build and sustain consumer awareness, not only of the detrimental effects of peat extraction and use but also to publicise the impacts of the proposed reduction in use.

Information on packaging needs to be much more clear with regard to whether and what quantity of peat is incorporated into bags and pots, so that it is immediately obvious whether or not peat has been used and in what quantity, and why when alternatives are already available for many uses.

Question 10: Taking account of initial analysis, are there any subsectors that you think are likely to face higher or lower costs of transition? If so, what evidence do you have for this?

ALGAO has no evidence for such cases.

Question 11: Do you agree that a time-limited industry working group should be established to develop a ‘roadmap’ to a peat-free future in professional horticulture? If so, do you have comments on the proposed objectives above?

ALGAO considers that having the industry on board should ensure greater success than if it was excluded. However, it is considered that the timetable needs to be fixed as well as the date for the complete ban on the sale of peat-based products, as well as their import.

Question 12: Do you agree that the use of peat in the professional grower market can and should be phased out by 2030? Based on evidence where possible, do you think it is feasible to phase out peat in this market before 2030?

ALGAO agrees that the use of peat in the professional grower market can and should be phased out by 2030. ALGAO has no evidence to support its view but finds it surprising, to say the least, that it is considered that it will take almost 20 years to phase out the use of peat in this market. ALGAO suggests that if this length of time is claimed by the industry to be needed, then the onus should be on the industry to prove that this is the case. Any such claims should be subject to independent review to ensure that the arguments are both robust and defendable.

If an increasing tapered environmental levy was imposed to encourage the development of sustainable alternatives, then consideration might be given to using some of that fund to supplement industry and government investment in development of alternatives that would enable the cessation of peat in this market much earlier than 2030.

Question 13: Do you support proposals for annual Defra-led monitoring of peat-based growing media sales?

ALGAO agrees with the proposal for annual Defra-led monitoring of peat-based growing media sales but considers that this should be quite detailed, in order to identify who is leading the charge and who is lagging behind. This could be used to apply peer pressure across the retail sector as well as to enable the buying public to vote with their feet by favouring those whose deeds demonstrate their intent. The use of market forces should not be minimised or neglected.

Question 14: Do you agree that data on the volume of peat used in horticulture is most effectively collected from growing media manufacturers?

ALGAO agrees that data on the volume of peat used in horticulture is most effectively collected from growing media manufacturers.

Question 15: What are your views on timing and proposed objectives for the 2015 policy review?

ALGAO is concerned that if the policy review does not occur until 2015 then, if further measures are required, there is little time to develop and implement them effectively. Monitoring should occur on an annual basis to ensure that developing trends are in the right direction and if they are perceived to be significantly awry, then the review should be brought forward.

I hope that you find the above comments of use. Please don’t hesitate to contact me if any further information or detail is required.

Yours sincerely

Ken Smith
Convenor, Countryside Committee and Vice-Chair, ALGAO:UK