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PRO
This consultation is being carried out by the Chemicals Regulation Directorate of HSE on behalf of Defra.

It concerns the approach to be taken in implementing a Directive on the Sustainable use of Pesticides (Directive 2009/128/EC) and two provisions in a Regulation on Plant Protection Product Authorisations (Regulation (EC) No 1107/2009) which may need to be implemented by domestic legislation.

It also seeks views on the case for developing new charging arrangements using powers in the European legislation on pesticides.

This consultation will be of interest to a wide range of stakeholders: members of the public; all users of pesticides including home/garden products; local authorities and other public and government bodies; the agriculture and horticulture industries; businesses and organisations involved in amenity use of pesticides; trade associations; farming unions; businesses involved in the manufacture, supply and use of pesticides; and non-governmental organisations, consumer and rural groups.

For more information: Consultation on implementing European pesticides legislation

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  • PRO
    I have, this morning, written to consultation coordinator, Caroline Kennedy for advice on how we can have our views represented on this.

    If anyone would like to coordinate and collate something on here from LN members...perhaps you could contact me?
  • Phil -

    Good move writing to the coordinator - you've raised your profile and may get an invite to discuss face-to-face as a stakeholder group. People / groups who are listed by gov't depts as those who have been approached with the consultation are normally those who have responded to previous consultations, have a lobbying presence, or are fairly well known to the department.

    In terms of coordinating, I usually work to a 'get it sent back a week before deadline' - in the case of LJN, I'd say you should also try to do the same as you aren't that well known. Send it in on deadline and you'll get lost among everyone else - those with a 'profile' will get the most attention when there is a stack of responses on the department's desks, e.g., a British Bankers' Association response will be more closely read than one received from Bank of East Grinstead's.

    With a three month consultation, say issued 1 Feb with response deadline on 1 May, I'd aim to repond on 24 April, fitting in three rounds of drafts:

    24 April - response submitted

    21 April - deadline for final comments on penultimate draft

    15 April - circulate penultimate draft for 'fatal flaw' comments

    7 April - deadline for comments on 2nd draft

    15 March - circulate 2nd draft

    7 March - deadline for comments on 1st draft

    8 February - circulate 1st draft

    Generally, we do a covering letter which says

    (1) Thank you for the opportunity to comment
    (2) Who we are, e.g., Landscape Juice is a free to join community of gardening and landscaping professionals and amateurs, our membership ranges from private individuals with an interest in gardening to [describe your 'big guns']
    (3) Responses to each of the questions posed in the CP are appended to this letter (and append a response to each question, of course), however, we would like to highlight the following key concerns:
    (4) We say we're happy to meet and discuss, give a contact name and number.
    (5) Any confidentiality statement you want to make (i.e., if you don't want your response published)

    Arguments work best if they aren't self-centered - so, what will be lost if you can't have your way that matters to more than just you? Also, it's helpful if you set out what safeguards are already in place, e.g., if someone can be prosecuted for mis-use of pesticides, etc.

    On Directives and Regulations -

    Directives are 'translated' into national law, so you can 'tweak' them a bit (unless they are maximum harmonisation - this means you have to stick as close to them as possible).

    Regulations are directly applicable into national law - no wording changes, no nothing - as it's written, so it goes - no wiggle room, not even for a dead worm.

    If it helps, I am happy to review any drafts and give feedback - I don't know much about pesticides, so I can only offer some insight into style and strategy.
  • PRO
    Hi Cat

    Great to see you here...I hope the new job is enjoyable:)

    I have been meaning to contact you since you left the comment and thanks so much for the useful advice and info. Do you have an example of a draft (or otherwise) that I can look at?

    Ih hope other LJN members can get involved and help to formulate something - pesticides and their use an important area for legislation to deal with.

    I'm sure I'll be back soon :)

    All the best


    Phil
  • Phil -

    Try this one from BBA (published on their website), it's pretty standard format (try to stay awake through the content!): http://www.ibfed.org/bba/jsp/polopoly.jsp?d=1568&a=13678&vi...

    It pretty much follows my sketch - We're the BBA.... we have 223 members in 63 countries..... here's what we contribute to the economy [read: listen to us, we're important]....

    Thank you for the opportunity to respond.....

    Here's our main points, etc.

    I should perhaps have added - if there's something in the text of the regulation which you think could be interpreted in a couple of different ways, always ask the question - if you have a preferred interpretation of the text, then argue for your interpretation - DON'T ever assume that given two interpretations, one sensible and one crazy, that the sensible one will be the one the Gov't will use.

    Also, in general, the UK tends to 'goldplate' or go superequivalent on EU standards (some jargon for yah) - if EU says in legislation, well, give'em 2 days, we'll give'em 5 just in case there's a bank holiday weekend involved somewhere!

    Bonkers!

    Philip Voice said:
    Hi Cat

    Great to see you here...I hope the new job is enjoyable:)

    I have been meaning to contact you since you left the comment and thanks so much for the useful advice and info. Do you have an example of a draft (or otherwise) that I can look at?

    Ih hope other LJN members can get involved and help to formulate something - pesticides and their use an important area for legislation to deal with.

    I'm sure I'll be back soon :)

    All the best


    Phil
  • PRO
    Thanks Cat, I'll have a read.

    It's disappointing though that the consultation coordinator has failed to respond to my request for info....or am I being impatient after five days?

    Phil
  • I wouldn't hold your breath waiting for assistance - the Civil Service are all prepping for what to do if there's a hung Parliament.... However, you could try ringing her - just dial the main number for the Directorate and ask to speak to her or someone in that office working on that condoc - nothing ventured, nothing gained.... Probably doesn't need saying but, remember - more flies with honey than with sh*t, so do be charming.

    Philip Voice said:
    Thanks Cat, I'll have a read.

    It's disappointing though that the consultation coordinator has failed to respond to my request for info....or am I being impatient after five days?

    Phil
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