Experts and the environment-the UK royal commission on environmental pollution1970-2011

Journal of Environmental Law

Volumn 24, Issue 1, 2012, Pages 1-22

  Owens, Susan ^a  

^a UNIVERSITY OF CAMBRIDGE   (United Kingdom)

Author keywords

[No Author keywords available]

Indexed keywords

AUTONOMY; ENVIRONMENTAL LEGISLATION; ENVIRONMENTAL POLICY; POLICY DEVELOPMENT; POLLUTION POLICY;

UNITED KINGDOM;

EID: 84857952989     PISSN: 09528873     EISSN: 1464374X     Source Type: Journal    
DOI: 10.1093/jel/eqr031     Document Type: Article

References (136)

1. Royal Commission on Environmental Pollution, HC Deb 11 December 1969, vol 793, col 638-39
2. SJohnson, The Politics of Environment: The British Experience (Tom Stacey Ltd 1973) 99, 101
3. The Central Scientific Unit was absorbed (as the Central Unit on Environmental Pollution) into the Department of the Environment (DoE) when that, too, was established later in 1970. Its staff furnished the Secretariat of the early Royal Commission.
4. Lord Kennet, Controlling our Environment, Fabian Research Series 283 (The Fabian Society 1970) 12, emphasis added
5. The environment portfolio in British government has been combined in various ways over time with other responsibilities. At the time of writing, it lies primarily with Defra, the Department of Environment, Food and Rural Affairs, created in 2001, though some aspects transferred to the Department of Energy and Climate Change (DECC) in 2008. This article refers to 'the environment department' when discussing the Commission's interactions with Whitehall. The Commission was not a 'Defra body'-a point discussed later in this article.
6. HC Parliamentary Written Statement on Departmental Arm's Length Bodies by the Secretary of State for Environment, Food and Rural Affairs Deb 22 July 2010, vol 514, col 32WS
7. The article is based on research involving in-depth interviews, archival work and the author's own experience as a member of the Commission, 1998-2008. An initial study (1995-97) was supported by grants from the Leverhulme Trust and the Commission itself. The author gratefully acknowledges this support and the assistance of Tim Rayner in this phase of the research. The views expressed in this article do not necessarily reflect those of the Commission.
8. The letter was sent byAnthony Greenwood towards the end of 1968
9. See M Holdgate, Penguins and Mandarins (The Memoir Club 2003)
10. W Kennet, Preservation (Temple Smith 1972), also makes interesting comments on the establishment of the Royal Commission
11. S Zuckerman, Monkeys, Men and Missiles: An Autobiography 1946-1988 (Collins 1988)
12. See also P Hennessy, Whitehall (Secker & Warburg 1989)
13. Wilson had moved Crosland from his position as President of the Board of Trade to his new ministerial appointment in 1969 (HC Deb 13 October 1969, vol 788, col 33)
14. Ashby was a well-known author on pollution and Master of Clare College, Cambridge. Zuckerman was a zoologist. The other members were Wilfred Beckerman, economist; Aubrey Buxton, Director of Anglia Television and co-founder of the World Wildlife Fund; Frank Fraser Darling, ecologist and conservationist; Neil Iliff, Deputy Chairman and Managing Director of Shell Chemicals UK; The Right Reverend Launcelot Scott, Lord Bishop of Norwich; Sir JohnWinnifrith, retired Permanent Secretary of the Ministry of Agriculture; and VeroWynne-Edwards, a zoologist.
15. The UK's prestigious Academy of Sciences
16. P Lowe, 'The Royal Commission on Environmental Pollution' (1975) 46 Political Quarterly 87, 91. The first female member was the Marchioness of Anglesey, who served until 1979.
17. After devolution, the advice of the devolved administrations in Northern Ireland, Scotland andWales would also have been sought
18. Two-day meetings at the beginning of each month became normal practice in the early 1980s, before which one day seemed to suffice. One or two of the meetings each year were usually held in other parts of the UK.
19. The Royal Warrant allowed ministers to request studies but this happened on only three occasions (leading to the reports: Air Pollution Control: An Integrated Approach, Fifth Report, (Cm 6371, 1976); Oil Pollution of the Sea, Eighth Report (Cm 8358, 1981); Crop Spraying and the Health of Residents and Bystanders (Special Report RCEP 2005). The environment department and other ministries, and latterly a wider range of interested parties, were consulted, however, about shortlists of possible topics.
20. Four reports (the products of 'short' studies) were not produced as Command papers. Latterly, the devolved administrations, as well as the UK Government, received reports and sometimes responded separately.
21. Significant contributions to the discussion of expertise include H Collins and R Evans, Rethinking Expertise (University of Chicago Press 2007)
22. F Fischer, Democracy and Expertise: Reorienting Policy Inquiry (OUP 2009)
23. R Pielke Jr, The Honest Broker: Making Sense of Science in Policy and Politics (CUP 2007)
24. S Owens, T Rayner and O Bina, 'New Agendas for Appraisal: Reflections on Theory, Practice and Research' (2004) 36 Environment and Planning 1943, 1945
25. One set of challenges derives primarily from political science and organisational theory, another from Science and Technology Studies (STS)
26. The former tends to focus on the assumed linearity and rationality of the policy process (for an overview see C Ham and M Hill, The Policy Process in the Modern Capitalist State (2nd edn, Harvester Wheatsheaf 1993) ch 5. The latter questions the possibility of expert neutrality and fact/value separation. There has been a surprisingly limited conversation between these traditions
27. For a useful discussion, see A Weale, The New Politics of Pollution (Manchester University Press, 1992)
28. Facing agitation about air pollution when Prime Minister in the 1950s, Harold Macmillan said: 'I would suggest that we form a Committee. . . .We cannot do very much but we can seem to be very busy - that is half the battle nowadays' (Cabinet Office Minutes: CAB 129/ 64, C(53) 322, 18 November 1953.
29. Cited in R Hyam, Britain's Declining Empire: The Road to Decolonisation, 1918-1968 (CUP 2006) 241)
30. B Guy Peters and A Barker, 'Introduction: Governments, Information, Advice and Policy-making', in B Guy Peters and A Barker (eds), Advising West European Governments: Inquiries, Expertise and Public Policy (Edinburgh University Press 1993) 1
31. See also, R Baker, 'Assessing Complex Technical Issues: Public Inquiries or Commissions?' (1988) 59 Political Quarterly 178
32. K Litfin, Ozone Discourses (Columbia University Press 1994) 3
33. See: H Heclo, Modern Social Politics in Britain and Sweden (Yale University Press 1974), which is regarded as seminal in this respect
34. For further examples, see PA Hall, 'Policy Paradigms, Social Learning, and the State: The Case of Economic Policymaking in Britain' (1993) 25 Comparative Politics 275
35. H Jenkins-Smith and PA Sabatier, 'Evaluating the Advocacy Coalition Framework' (1994) 14 Journal of Public Policy 175
36. G Majone, Evidence, Argument and Persuasion in the Policy Process (Yale University Press 1989)
37. PA Sabatier, 'Knowledge, Policy-oriented Learning and Policy Change: An Advocacy Coalition Framework' (1987) 8 Knowledge: Creation, Diffusion, Utilisation 649
38. A useful overview is provided by C Radaelli, 'The Role of Knowledge in the Policy Process' (1995) 2 Journal of European Public Policy 159
39. Framing involves ways of looking at and talking about the world in which certain knowledge claims, problem definitions and policy options are brought to the fore; frames are often tacit, but can also involve a conscious discursive strategy
40. See M Rein and D Schön, 'Frame-reflective Policy Discourse' in P Wagner, C Weiss, B Wittrock and H Wolman (eds), Social Sciences and Modern States (CUP 1991) 262
41. D Schön and M Rein, Frame Reflection: Toward the Resolution of Intractable Policy Controversies (Basic Books 1994)
42. For analyses focusing on the significance of discourse in environmental policy-making, see B Flyvbjerg, Rationality and Power: Democracy in Practice (University of Chicago Press 1998)
43. M Hajer, The Politics of Environmental Discourse: Ecological Modernisation and the Policy Process (OUP 1995)
44. Litfin (n 25)
45. D Fiorino, 'Environmental Policy as Learning: A New View of an Old Landscape' (2001) 61 Public Administration Review 322
46. P Glasbergen, 'Learning to Manage the Environment' in W Lafferty and J Meadowcroft (eds), Democracy and the Environment: Problems and Prospects (Edward Elgar 1996)
47. These authors distinguish 'conceptual learning', through which policy paradigms change, from a simpler form in which actors work out better ways of achieving given ends
48. Similar distinctions, using different terminology, are made by C Argyris and D Schö n, Organizational Learning II: Theory, Method and Practice (Addison-Wesley 1996)
49. Hall (n 26)
50. M Jachtenfuchs, International Policy-making as a Learning Process? The European Union and the Greenhouse Effect (Avebury 1996)
51. P May, 'Policy Learning and Failure' (1992) 12 Journal of Public Policy 331
52. TJ Cartwright, Royal Commissions and Departmental Committees in Britain: A Case-Study in Institutional Adaptiveness and Public Participation in Government (Hodder and Stoughton 1975) 217
53. See also R A Chapman (ed), The Role of Commissions in Policy-Making (George Allen and Unwin Ltd 1973)
54. KC Wheare, Government by Committee: An Essay on the British Constitution (Clarendon Press 1955) 89
55. T Gieryn, 'Boundary Work and the Demarcation of Science from Non-science: Strains and Interests in Professional Ideologies of Scientists' (1983) 48 American Sociological Review 781
56. See also D Guston, 'Boundary Organizations in Environmental Policy and Science: An Introduction' (2001) 26 Science, Technology and Human Values 399
57. S Jasanoff, The Fifth Branch: Science Advisers as Policy Makers (Harvard University Press 1990)
58. The term is also used to mean the conscious, mediating activity of certain organisations: see eg S Dammann and D Gee, 'Science into Policy: The European Environment Agency' in J Lentsch and P Weingart (eds), The Politics of Scientific Advice: Institutional Design for Quality Assurance (CUP 2011) 238
59. B de Wit, Methodology of Boundary Work (RMNO [Dutch Advisory Council for Research on Spatial Planning, Nature and the Environment] 2004)
60. Jasanoff (n 31) 250
61. Jasanoff (n 31) uses the term'regulatory science' to mean science deployed in complex regulatory issues in the public sphere, such as those relating to health and the environment
62. Others use 'post-normal science' (S Funtowicz and J Ravetz, 'Three Kinds of Risk Assessment: A Methodological Analysis' in C Whipple and V Covello (eds), Risk Analysis in the Private Sector (Plenum Press 1985) 217
63. 'Science for the Post-normal Age' (1993) 25 Futures 739)
64. The phenomenon has been characterised as 'interpenetration' (see eg Y Ezrahi, 'Utopian and Pragmatic Rationalism: The Political Context of Scientific Advice' (1993) 18 Minerva 111, 120
65. J Ravetz, The Merger of Knowledge with Power: Essays in Critical Science (Mansell Publishing Ltd 1990)
66. But Jasanoff sees it as a form of 'co-production', in which the natural and social orders are mutually constituted (States of Knowledge: The Co-production of Science and Social Order (Routledge 2006) 14)
67. For a discussion, see A Irwin, 'STS Perspectives on Scientific Governance' in EJ Hackett, O Amsterdamska, M Lynch and J Wajcman (eds), The Handbook of Science and Technology Studies (3rd edn, MIT Press 2007) 583
68. Exceptions include WE Bijker, R Bal and R Hendriks, The Paradox of Scientific Authority: The Role of Scientific Advice in Democracies (MIT Press 2009)
69. RH Clarke and J Valentin, 'A History of the International Commission on Radiological Protection' (1990) 88 Health Physics 407
70. Jasanoff (n 31)
71. Many authors have called for more detailed empirical research to illuminate relations between knowledge and policy (eg CJ Bennett and M Howlett, 'The Lessons of Learning: Reconciling Theories of Policy Learning and Policy Change' (1992) 25 Policy Sciences 275
72. Hall (n 26); Litfin (n 25); Pielke (n19))
73. DoE, Central Unit on Environmental Pollution, Controlling Pollution, Pollution Paper No. 4 (HMSO 1975), 2. This was a collective response to four reports: RCEP, First Report (Cmd 4585, 1971); RCEP (Second Report), Three Issues in Industrial Pollution (Cmd 4894, 1972); RCEP (Third Report) Pollution in Some British Estuaries and CoastalWaters (Cmd 5054, 1972); RCEP (Fourth Report) Pollution Control: Progress and Problems (Cmd 5780, 1974).
74. RCEP (Ninth Report) Lead in the Environment (Cmd 8852, 1983)
75. The report side-stepped the controversy over lead and children's health by arguing that lead-free petrol could be introduced without unacceptable costs to industry or to motorists. It also framed lead as an eco-toxin whose rate of accumulation in the environment should be reduced as a matter of precaution.
76. RCEP (Twenty Second Report), Energy: The Changing Climate (Cmd 4749, 2000). See also: PIU (Cabinet Office Performance and Innovation Unit), The Energy Review (Performance and Innovation Unit 2002); UK Government, Our Energy Future - Creating a Low Carbon Economy, Department of Trade and Industry (Cmd 5761, 2003).
77. For more detail, see S Owens, 'Learning Across Levels of Governance: Expert Advice and the Adoption of Carbon Dioxide Emissions Reduction Targets in the UK' (2010) 20 Global Environmental Change 394
78. Some proposals, it has to be said, were simply not well thought through, and were never going to be practicable propositions
79. J Kingdon, Agendas, Alternatives and Public Policy (2nd edn, Longman 2003)
80. RCEP (Fifth Report), Air Pollution: An Integrated Approach (Cmd 6371, 1976)
81. DoE, Central Directorate on Environmental Pollution, Air Pollution Control: The Government Response to the Fifth Report of the Royal Commission on Environmental Pollution, Pollution Paper no 18 (HMSO 1982)
82. Subsequently, the UK was influential in the drafting of the European Directive on Integrated Pollution Prevention and Control, an example of the Commission's indirect, international influence
83. RCEP (Eleventh Report), ManagingWaste: The Duty of Care (Cmd 9675, 1985)
84. RCEP (Thirteenth Report), The Release of Genetically Engineered Organisms to the Environment (Cmd 720, 1989). Some environmental organisations were active both in giving evidence to the Commission and in lobbying Parliament during drafting of the Billça good example of the importance of networks discussed further in Section 5. One environmentalist described how they had 'developed a whole lobbying agenda [on GMOs] . . .A lot of [the issues] were prompted by things the Royal Commission was saying, and that all went into the briefings . . .' (see n 48).
85. Unless otherwise attributed, quotes are from interviews conducted for the study described above (n 7). All officials and ministers cited had served at some point in the environment department. Interviewees remain anonymous, though their relation to the Commission is indicated.
86. Ministry of Agriculture, Fisheries and Food (MAFF), Food from Our Own Resources (Cmd 6020, 1975)
87. RCEP (Seventh Report), Agriculture and Pollution (Cmnd 7644, 1979)
88. DoE, Central Directorate of Environmental Protection, Agriculture and Pollution: The Government Response to the Seventh Report of the Royal Commission on Environmental Pollution, Pollution Paper No. 21 (HMSO 1983).
89. RCEP (n 50) para 8.30.
90. House of Commons Environment Committee, Pollution of Rivers and Estuaries, Third Report Session 1986-7, HC Paper 183-1 (HMSO 1987). Significant shifts in the politics of water pollution also occurred during privatisation of the water industry.
91. The period 1989-91 saw the introduction of new Farm Waste Regulations, a Farm and Conservation Grant Scheme, a revised and more accessible code of practice for water protection, and a tougher approach to prosecution (yet another measure in the Environmental Protection Act 1990)
92. For details, see P Lowe and others, Moralizing the Environment: Countryside Change, Farming and Pollution (UCL Press 1997)
93. C Weiss, 'Research for Policy's Sake: The Enlightenment Function of Social Research' (1977) 3 PolicyAnalysis 531
94. S James, 'Influencing Government Policymaking' in D Stone (ed), Banking on Knowledge: the Genesis of the Global Development Network (Routledge 2000) 162, 163
95. See S Owens, 'Risk and Precaution: Changing Perspectives from the Royal Commission on Environmental Pollution' (2006) 63 Science in Parliament 16
96. Ideas about precaution were developed through reports on specific aspects of pollution (eg RCEP (Third Report) (n 36); RCEP (Ninth Report) (n 37); RCEP (Sixteenth Report) Freshwater Quality (Cmd 1966, 1992); RCEP (Twenty Fourth Report), Chemicals in ProductsçSafeguarding the Environment and Human Health (Cmd 5827, 2003); RCEP 2005 (n 17)) and also through the Commission's periodic overviews and 'philosophical' studies (eg RCEP (Second Report) (n 36); RCEP (Tenth Report) Tackling Pollution - Experience and Prospects (Cmd 9149, 1984); RCEP (Twelfth Report), Best Practicable Environmental Option (Cmd 310, 1988))
97. RCEP (Sixth Report), Nuclear Power and the Environment (Cmd 6618, 1976); RCEP (n 47); RCEP (Twenty Seventh Report), Novel Materials in the Environment: The Case of Nanotechnology (Cm 7468, 2008)
98. RCEP Second Report (n 36). The call for better access to information was reiterated in numerous reports after the second; wider engagement was urged from the late 1990s onwards (see RCEP (Twenty First Report), Setting Environmental Standards (Cmd 4053, 1998); RCEP (Twenty Fourth Report) (n 57) and RCEP (Twenty Seventh Report) (n58)).
99. Litfin (n 25) 4, uses the term'knowledge brokers' to mean 'intermediaries between the original researchers, or the producers of knowledge, and the policy-makers who consume that knowledge but lack the time and training necessary to absorb the original research'. 'Policy entrepreneurs', according to Kingdon (n 42) 179, are persistent advocates willing to invest time and energy into pushing their pet proposals.
100. See also S Owens and T Rayner, "'When Knowledge Matters": The Role and Influence of the Royal Commission on Environmental Pollution' (1999) 1 Journal of Environmental Policy and Planning 7
101. As expressed by a former Chair
102. A broader view was taken by a former environment minister, who described the Commission as 'scientific in a rather . . .ancient sense of . . . people trying to assess argumentation and not regarding themselves as representative'.
103. RCEP Twelfth Report (n 57) para 2.30. Although the Commission was never guilty of the naïve assumption that difficult issues could be settled by science alone, for much of its life it regarded the technical and the political as separable (see also RCEP (Twenty First Report), (n 59)). In its last decade, however, most notably in reports on chemicals (Twenty Fourth Report (n 57)), crop spraying (2005 (n 17)) and nanotechnologies (Twenty Seventh Report (n 58)), it became increasingly conscious of what Jasanoff calls the 'hybrid normative-cognitive character of regulatory science' (S Jasanoff, 'Quality Control and Peer Review in Advisory Science' in Lentsch and Weingart (n 31) 28). The broader social scientific presence on the Commission by this stage almost certainly influenced this shift.
104. Quotes from members who served during the 1980s and 1990s. Although the Commission did not have 'lay members'as such, distinguished individuals often claimed this status in the context of particular studies.
105. Comments to this effect were offered by many interviewees. Inevitably, on some occasions, there were vigorous disagreements, disciplinary fault lines and clashes of personality. However, there was only ever one minority report, arising from a disagreement about the practicability and likely efficacy of economic instruments in pollution control (RCEP (Third Report) (n 36)).
106. In frame reflection, the presumptions of a dominant frame become subject to examination and critique. See Rein and Schön, Schön and Rein (n 27).
107. The term was used by a civil servant
108. Hennessy (n 10)
109. RCEP1979 (n 50); RCEP (Sixteenth Report) (n 57); RCEP (Eighteenth Report), Transport and the Environment (Cmd 2674, 1994); RCEP (Twenty Third Report), Environmental Planning (Cmd 5459, 2002)
110. H Morris, 'Study SaysWhat the Government Left Out' (March 2002) Planning 11
111. Morris refers to the Commission's twenty-third report (RCEP 2002, ibid), which argued for an integrated system of land use and environmental planning at a time when the government was bent on 'streamlining' the planning process. Not surprisingly, although the report won plaudits in some quarters, it had relatively little impact on policy.
112. For example, '[m]isgivings' were expressed by members about ministerial direction of the Commission's study of air pollution control in the 1970s (minutes, RCEP fourth meeting 1974, 6 June [quote from minute 22]). In 1981, when financial responsibility for the Commission passed from central departments to the environment department, the Chair sought reassurance from the Prime Minister that this would not weaken the Commission's independence (letter from Professor Sir Hans Kornberg to the Rt Hon Margaret Thatcher, 11.11.80; PM's response, 28.11.80).
113. G Podger, 'Quality control and the Link Between Science and Regulation from a National and EU Administrator's Perspective' in Lentsch and Weingart (n 31) 229, 232. The Secretariat, many of whom were drawn from (and often returned to) the environment department might also have been thought to espouse particular worldviews.
114. Some members might even have been'placed': one civil servant suggested, for example, that in the Commission's first few decades 'MAFF always . . . made sure that they had someone on it' (emphasis added).
115. D Wilson, The Lead Scandal (Heinemann Educational 1983)
116. Diane Stone, in a discussion of think tanks, notes that such bodies can enjoy 'scholarly' independenceçthe ability to pursue particular interests relatively unhinderedçeven if they are in resource-dependent relations with government ('Introduction: Think Tanks, Policy Advice and Governments' in D Stone and A Denham (eds), Think Tank Traditions: Policy Research and the Politics of Ideas (Manchester University Press 2004) 3)
117. The term'functional independence' was used in the letter from the Chair to the Prime Minister referred to in n 71. Kornberg wrote, 'I . . .very much hope that the Commission's functional independence will continue to be publicly asserted, whatever new financial arrangements may be envisaged . . .'.
118. The term was coined by an interviewee who had been a member of both the House of Lords and the Royal Commission
119. A case in point would be the way in which the former Chairs, Lord Ashby and Lord Flowers, pressed for the implementation of integrated pollution control (see eg debates on The Environment: HL Deb 23 March 1983, vol 440, col 1204-22, and Environmental Pollution: Air Pollution - Reports: HL Deb 29 October 1984, vol 456, cols 354-404). Another would be Lord Nathan's membership of the Select Committee on the European Communities while serving on the Commission (1979-89).
120. Stone makes this point about think tanks (n 75) 13. Following Heclo (n 26), many scholars have argued that policy is influenced by learning within and between networks. For useful discussions, see Bennett and Howlett (n 35); M Jachtenfuchs (n 28); P May (n28) 331.
121. EA Parson and WC Clark, 'Sustainable Development as Social Learning: Theoretical Perspectives and Practical Challenges for the Design of a Research Program' in LH Gunderson, CS Holling and SS Light (eds), Barriers and Bridges to the Renewal of Ecosystems and Institutions (Columbia University Press 1997) 428
122. On networks and policy-making more generally, see H de Bruijn and E ten Heuvelhof, Networks and Decision Making (Lemma 2000)
123. D Marsh and R Rhodes, Policy Networks in British Government (Clarendon Press 1992)
124. As expressed by a former Secretary. In the case of transport, the Commission's eighteenth report (n 69) was followed by another, when it considered the government to be taking insufficient action (RCEP (Twentieth Report), Transport and the Environment - Developments Since 1994 (Cmd 3752, 1997)).
125. See eg Defra, Review of the Royal Commission on Environmental Pollution: Final Report (prepared for Defra by PricewaterhouseCoopers) (Defra 2007)
126. ENDS at 30, Special Anniversary Issue, Environmental Data Services (May 2008), 28
127. I am grateful to Albert Weale, Professor of Political Theory and Public Policy, University College London, for putting it to me in this way
128. Several interviewees suggested that the Commission had been vulnerable during the early 1990s, when its investigation of freshwater quality was seen by some withinWhitehall as 'insensitive and unhelpful' in the run-up to water privatisation. There were also concerns about its productivity. One civil servant thought, however, that it would have been politically impossible to 'kill' the Commission at this time, perhaps (as a former member suggested) because of 'the uproar that there would [have been] in the Lords'.
129. One consequence was that reports grew significantly in size. The extreme cases are the second report (RCEP 1972 (n 36)), extending to a mere nine A5 pages, and the twenty-fifth (RCEP (Twenty Fifth Report), Turning the Tide: Addressing the Impacts of Fisheries on the Marine Environment (Cmd 6392, 2004)), a 377-page, A4-sized tome. Concerned that its findings should be accessible, the Commission took to producing summary reports from the late 1990s onwards.
130. At least two of the Chairs in the 1970s and 1980s had good, informal relations with ministers, enabling them to discuss issues of mutual concern 'offline'
131. Defra (n 80)
132. The Commission and the Advisory Committee on Pesticides differed in their views about the need for precautionary measures, specifically the introduction of buffer zones to protect residents from the possible harmful effects of spray drift. Each effectively accused the other of being 'unscientific' (RCEP 2005 (n 17.
133. Advisory Committee on Pesticides, Crop Spraying and the Health of Residents and Bystanders: A Commentary on the Report published by the Royal Commission on Environmental Pollution in September 2005 (ACP, December 2005): accessed 1 September 2009.
134. RCEP, Response to Commentary of the Advisory Committee on Pesticides on the RCEP's Report on Crop Spraying and the Health of Residents and Bystanders (RCEP July 2006): accessed 1 September 2009. The environment department ultimately declined to introduce the buffer zones.
135. For more detail, see S Owens, 'Knowledge, Advice and Influence: The Role of the UK Royal Commission on Environmental Pollution, 1970-2009' in Lentsch and Weingart (n 31) 88
136. L M Warren, 'Healthy Crops or Healthy People? Balancing the Needs for Pest Control Against the Effect of Pesticides on Bystanders' (2009) 21 Journal of Environmental Law 483