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University of Amsterdam Institute of Interdisciplinary Studies

May 2013

SustainaBEElity

A policy formation analysis

regarding the relation

between neonicotinoid based

pesticide use and bee mortality

in the Netherlands, 2008-2013

Abel Mensink Expert supervisor: dr. K.F. Rijsdijk

Merèt Muntinga Tutor: L. Rutting Msc

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For: Coyan - mother of Future Planet Studies.

To make a prairie it takes a clover and one bee, — One clover, and a bee,

And revery.

The revery alone will do If bees are few.1

- Emily Dickinson.

Abstract

Policy formation processes are generally influenced by various factors, including stakeholders and their features. In the complex reality of natural resource management, where lack of data and consensus over issues are at large, the scope of influence is even larger. This research report focusses on the policy problem concerning a potential moratorium (a two-year ban) on neonicotinoid based pesticides (NBP‘s) in the Netherlands, from 2008-2013. NBP‘s are related with increased bee mortality, and since bees provide in pollination essential for food production, this issue has gained much public attention and has been put on the governmental agenda. A policy formation analysis has been designed - an integration of economic, political and human-geographical research approaches - in order to clarify how stakeholders interpreted the policy problem which together with their levels of influence and importance was determinant for policy outcome. This policy formation analysis reveals the essential role of interpretation of a complex and constructed reality and moreover the striking appliance of scientific research for non-intrinsic interest-favoring of stakeholders.

1 This poem addresses the larger context of the research project, in an artistic manner. Without bees, no being (as A. Einstein often quoted words: ―if the bees go extinct, the human race has only four years to live.‖), but

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Table of Contents

Cover page 1

Abstract 2

Table of Content 3

1. Introduction 4

1.1 Honey bee‘s crucial role in our food system 4 1.2 Policy measures regarding neonicotinoid based pesticides (NBP‘s) 6 1.3 Theories and assumptions underlying the research project 7

1.4 Structure of the report 10

2. Methodology 10

2.1 Repko‘s research process 11

2.2 Policy Formation Analysis 12

2.2.1 Identification of key stakeholders (KS’s) 13 2.2.2 Positioning of key stakeholders in two matrices 13 2.2.3 Integration of matrices to identify prevailing key stakeholders 16

2.3 Integrative Technique of Extension 16

2.4 Conducting content analysis 17

3. Results 17

3.1 Results of identification of key stakeholders 18 3.2 Results of positioning of stakeholders in matrices 19 3.3 Explanation of assessment on three variables per stakeholder 22

3.4 Identifying prevailing key stakeholder 25

4. Conclusion 25 5. Discussion 26 References 28 Appendix I 31 Appendix II 35 Appendix III 51

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1. Introduction

1.1 Honey bee‘s crucial role in our food system

Changing biodiversity and its anthropogenic causes is a topic which has been researched extensively. Chapin et al. (2000) have indicated human behaviour and its consequences for the natural environment as ―...one of the largest experiments in the history of the Earth. Human effects on climate, biogeochemical cycles, land use and mobility of organisms have changed the local and global diversity of the planet, with important ecosystem and societal consequences.‖ (p.241). Various attempts have been put out in order to quantify monetary values of ecosystem services. Costanza et al. (1987) define ecosystem services as: ―(...) the benefits human populations derive, directly or indirectly, from ecosystem functions.” (p.3), where ecosystem functions are understood as “(...) the habitat, biological, or systems properties or processes of ecosystems.” (Ibid.). In their report (The Value of the World's Ecosystem Services and Natural Capital, 1987) they have distinguished 17 ecosystem services; pollination (essential for food production) being one of them. Honeybees account for up to 80% of worldwide pollination of crops (United Nation Environmental Programme (UNEP), 2010) and without them the production of many fruits, nuts and vegetables would be impossible. Southwick and Southwick (1992) estimated that the total value of honey bee pollination for US agriculture is equal to six billion US dollars. Borneck and Merle (1989) estimated this value for the fifteen countries of the European Union to be five billion US dollars. Hein (2009) reviewed several studies that estimated the economic value of the pollination service for different countries. He observed that on a national scale the value estimates of the pollination service range from 1% to 16% of the market value of agricultural production. Moreover, direct food production is an ecosystem service in which bees provide through honey production. Honeybees are consequently of great (economic) importance worldwide.

However, honey bee colony numbers are declining, as is put forward by beekeepers, scientists, NGO‘s and political parties. UNEP (2010) reported a ―… decrease in managed honey bee colony numbers in Europe since 1965 (...), [but] since 1998, individual beekeepers have been reporting unusual weakening and mortality in colonies, particularly in France, Belgium, Switzerland, Germany, the United Kingdom, the Netherlands, Italy and Spain.‖.

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numbers indicate that there is a substantial decline in bee population, however great ranges in numbers indicate the existence of uncertainty in measurements.

Figure 1: European colony mortality (In black 2007-2008 mortality in percentage decline/year, in red 2006-2007 mortality in percentage decline/ year).

Source: 2007-2008 (COLOSS, Zagreb meeting proceedings 2006-2007 (EFSA members poll) in UNEP (2010).

Honey bee mortality as reported by UNEP (2010) might be attributed to factors such as climate variations, transport, queen weakness, colony weakness, or diseases such as Varroa destructor and others (ibid.). Moreover, since 2008 increased concerns emerged regarding risks of neonicotinoid based pesticides (NBP‘s) to honey bee health.

NBP‘s such as Imidacloprid, first introduced in 1992 (Stokstad, 2007), have become increasingly popular and extensively used throughout Europe. According to BayerCropscience (2013), number one producer of NBP‘s such as Imidacloprid worldwide, these pesticides can be applied effective and cost-efficient. They can be applied in a ‗systemic‘ matter, which causes the entire plant -from root to pollen- to become toxic for target-insects (BayerCropscience, 2013; HFFA, 2013). Some scientists claim this includes non-target pollinators such as honey bees (Van Gestel, 2013). However, seed treatment might be linked to Colony Collapse Disorder (CCD) due to the fact that whilst foraging on treated nectar and pollen a bee‘s nervous system is affected hence its navigation back to the hive is impeded. Moreover, various lab studies have shown that high doses of pollen and nectar of plants treated with NBP‘s can be lethal (Van Gestel, 2013). This research project does not focus on the (ecological, chemical and biological) discussion regarding this causality; a lack of consensus among scientists, policy makers, beekeepers and other stakeholders is yet taken as a starting point. Since despite this lack of consensus regarding risks of NBP‘s and increased bee mortality, public attention and concern has been extensive. Initiatives such as

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the Avaaz campaign (2013) against ―bee-killing pesticides‖ which rose 2.4 million petitioners, and a Greenpeace campaign have contributed to put this subject on the governmental agenda worldwide. Bee mortality and policy decisions regarding NBP‘s should hence be considered in a greater context; the challenge of realizing a sustainable future for our natural resources2.

1.2 Policy measures regarding neonicotinoid based pesticides (NBP‘s)

Currently3 the use of NBP‘s is allowed in the Netherlands as opposed to some other European countries and despite the fact that different international studies link the use of NBP‘s to honey bee mortality. This research analyses the policy formation process regarding NBP‘s in the Netherlands. The aim is to reveal how different stakeholders involved in the discussion have influenced the decision making process, to gain insight into the force field and why certain stakeholders prevailed in the process. Therefore the central research question is: How have different stakeholders and media shaped the policy problem and hence influenced ‗positive‘ policy outcome regarding neonicotinoid based pesticides (NBP‘s) in the Netherlands? Media are distinguished from other stakeholders in this research question since the policy problem is shaped by the other stakeholders through media (bee keepers interviewed in newspapers for example), but media have shaped the policy problem in different manners as well (Zembla‘s documentary ‗De Moord op de Honingbij‘ 4, 2011, for example).The policy problem is understood as the dilemma to ban or not to ban NBP‘s in the Netherlands. ‗Positive‘ policy outcome is defined as the decision not to ban NBP‘s. Regarding time scope, the period 2008-2013 (up to April 29th) is chosen, since this ‗positive‘ policy outcome demarcated this period together with a significant increase of bee mortality in the Netherlands. This question will be addressed with the use of theories and techniques that originate from the fields of political sciences, economics and human geography.

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1.3 Theories and assumptions underlying the research project

For this research a policy cycle is supposed where policy is formed according to the famous political scientist Jennings: ―Policy analysis [policy formation process] is policy advice (…) that pertains to the initial definition of policy problems, the identification of policy options and the evaluations of policy choices.‖ (1987, p. 130). In every phase of this threefold circular process (see figure 2) it is essential to investigate how various stakeholders interpret the problem and assess policy outcome, since they influence to varying extents the way in which policy makers reflect on the problem and thus act in terms of policy decisions and evaluations (Ibid.). The role of media is essential in the process of gaining public attention for societal and environmental issues (as the Avaaz-campaign has demonstrated), but moreover often determinant in the process of translating the various ways of interpretation of a problem by different stakeholders for the general public (Anderson, 1997). The policy formation process, represented by the policy cycle, is investigated through a ‗policy formation analyses. This analysis, which is an own method, can be regarded as an politically adjusted stakeholder analysis - integrating ‗stakeholder analysis‘ and ‗problem defining analysis‘ - , backed up with data from inter alia content analysis.

Figure 2: Policy cycle (Jennings, 1979).

The general assumption of policy formation analysis is that the way in which a policy problem (if NBP‘s should be banned or not) is framed by key stakeholders in combination with their levels of influence on the ‗project‘ and levels of importance when winning or losing the ‗project‘ determines policy outcome (hence: a moratorium on NBP‘s or not). The ‗project‘ is understood as the policy problem. Theories on which the analysis is based are the normative stakeholder theory (Reed et al., 2008) and the theory of framing in policy discourse (Rein & Schön, 1993; Stone, 2002).

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Stakeholders - those actors affected by, and/ or affecting the policy problem (World Bank, 2013) - strive to put their interpretation of the policy problem on the governmental agenda. Kingdon (1995) distinguishes the governmental agenda (the lists of subjects which are getting attention) from the decision agenda, which is defined as ―the list of subjects within the governmental agenda that are up for an active decision.‖ (p.4). The agenda-setting process narrows the set of conceivable subjects to the set that actually becomes the focus of attention. When a subject is prioritized as a policy problem on the governmental agenda, according to Kingdon (ibid.) it then automatically enters the policy cycle (figure 2) where it becomes subject of policy formation analysis. Only when ―an idea‘s time has come‖ (ibid., p.1), so when governmental officials regard the policy problem as indispensable it is ‗upgraded‘ to the decision agenda where policy is finally decided upon, actual policy is formed (between phase 2 and 3 in the policy cycle). It is important to note however that even when a problem is not decided upon, being on the governmental agenda without getting to the decision agenda, power is exerted. Where a decision can be regarded as ‗a choice among alternative modes of action‘, also ‗non-decisions‘ express policy preferences by the way in which decisions are prevented from being taken. This concept is captured by Schattschneider in his famous and often cited words: ―All forms of political organization have a bias in favor of the exploitation of some kinds of conflict and the suppression of others, because organization is the mobilization of bias. Some issues are organized into politics, while others are organized out.‖ (Schattschneider, 1960, p.71). The which question then arrises, and is vital to this research: why are some issues ‗organized out‘, while others do become focus of policy decision? Both Kingdon‘s and Schattschneider‘s theories entail the ontological assumption5 of ‗maakbaarheid‘; stakeholders interpret ‗reality‘ differently (through conflicts) hence construct different versions of ‗truth‘. In terms of the founding fathers of the concept of framing, Rein and Schön (1993), this ontological assumption enables us to bridge to gap between what ‗is‘ (as we interpret it) and what ‗should be‘; also known as the normative leap. Essential to this research is the concept of framing. Framing is defined as ―(…) a way of selecting, organising, interpreting, and making sense of a complex reality to provide

5 According to Repko (2008) assumptions of theories are of three kinds (p.251-252). Ontological assumed theories are theories with assumptions made regarding the nature of reality, for example the matter whether people act rational or not. Epistemological assumed theories are theories with assumptions made regarding the knowledge of that ‗reality‘, thus questioning: ―How do we know what we know?‖. Value-laden assumed theories are lastly theories where scientists make value assumptions about (certain aspects of) ‗truth‘,

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guideposts for knowing, analysing, persuading, and acting. A frame is a perspective from which an amorphous, ill-defined, problematic situation can be made sense of and acted on.‖ (Rein & Schön, 1993, p.146). Policy formation analysis applies the variables of influence / importance and causality / ecological - economic of key stakeholders to determine which stakeholder prevailed in the policy formation process. It is assumed that stakeholders decide on the base of their framed preferences in order to favour their prioritised interests. Hence, on top of assumptions regarding the nature of reality (which issues are framed as policy problems and enter the policy cycle or even get on the decision agenda, and which issues are ‗organised out‘?), value-laden assumptions are leading in this process. Finally, note that constructs of ‗reality‘ which influence the formulation of ‗truth‘ in terms of policy options where can be decided upon, are based on scientific accounts of this reality. When scientific consensus cannot be found, such as in the case of bee mortality in relation to NBP‘s, policy makers find themselves in the epistemological predicament - uniform knowledge cannot be constructed - where values become even more determinant.

Stakeholder analysis is a tool originating from the field of economics that can be used to generate knowledge about actors. It helps to understand the behavior of different actors and can potentially reveal their intentions, interrelations and interests. Moreover, stakeholder analysis assesses influences on decision-making or implementation processes (Varvasovszky & Brugha, 2000), hence policy formation processes. From an economic perspective, the basic assumption of stakeholder analysis is that stakeholders determine their interests via rational and objective consideration on the basis of utility, trying to maximize their gain and minimize their losses. Four attributes of actors are essential for a stakeholder analysis: (1) Stakeholder‘s position on the reform; (2) Their level of influence; (3) Their level of interest; (4) The group to which they belong (World Bank, 2013). Each stakeholder can be described on the basis of these four attributes. However, this research assumes the way stakeholders formulate those attributes to be more elaborate and subtle than standardised stakeholder analyses such as provided by the World Bank propose. Consequently, for this research, a politically adjusted stakeholder analysis (namely: policy formation analysis) has been conducted to gain more insight in the way the actors have shaped the decision-making process that has led to the formation of current pesticide policies in the Netherlands. Reed et al. (2008) have given an overview of different approaches on stakeholder analysis in their typology of stakeholder analysis methods for natural resource management. Normative stakeholder analysis regards stakeholder analysis as a tool to explore conflicting goals and different perspectives on a problem (Reed et al., 2008), thus incorporating a multiple view on

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reality - through varying patterns of framing. As normative stakeholder analysis ―can facilitate a constructivist approach to stakeholder participation, which recognises multiple perspectives of the ‗truth‘, where ‗reality‘ is socially constructed‖, policy formation analysis uses this perspective of stakeholder participation in order to explore the determinant factors in policy formation. Normative stakeholder analysis is a precursor to the entire policy cycle of Jennings (1987); identifying stakeholders in the process and their levels of influence and importance proceeds the way a potential policy problem is defined, subsequently decided upon and finally evaluated. Normative stakeholder analysis is an ontologically assumed theory too, holding a constructivists view of reality.

If a constructivist view of reality is assumed, policy formation analysis can be regarded as a clear example of interpretative social science, as opposed to classical positivist science. Interpretative science does not rely on empirical data (solely) in order to formulate a theory via rational, inductive methods (Tromp, 2013). Moreover, interpretative science assumes that no single account of reality exists, thus, the way we look at ‗reality‘ determines its features to a certain extent and steers us into a (policy) direction. The domain of policy science is characterised not by neutrality or value-freedom, since values are leading factors in the process.

1.4 Structure of the report

First we shall elaborate on the methodology based on Repko‘s (2008) interdisciplinary research method (2). This part is followed by the results of research project (3). Finally, conclusions will be drawn to put the results into a bigger perspective and address the main research question, and results will be discussed in the light of theories and methods (4).

2. Methodology

In this part of our report we shall elaborate on methodologies used for this research. Policy formation analysis, as designed by our team, is inherently interdisciplinary. Policy formation analysis poses the policy cycle as object of study, which is inter alia shaped by

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stakeholders that act to favour their own interests. They act from different disciplines and backgrounds and have varying perspectives on the problem.

2.1 Repko‘s research process

Repko (2008) defines interdisciplinarity as ―(...) the essence of interdisciplinary studies, which is manifested through research involving two or more knowledge domains.‖ (p.6). Repko stresses hereby the word ‗inter‘ referring to ―the contested space between disciplines‖, as well as ―the action taken on these insights, called integration‖ and ―the something altogether new that results from integration and is additive to knowledge‖ (ibid.). Table 1 demonstrates Repko‘s representation of this interdisciplinary research process, which has been followed throughout this research. Policy formation analysis can be regarded as the result of phase 8, where common ground is created with the theories of stakeholder analysis and framing.

A Drawing on disciplinary insights

1. Define the problem or state the focus question 2. Justify using an interdisciplinary approach 3. Identify relevant disciplines

4. Conduct a literature search

5. Develop adequacy in each relevant discipline 6. Analyze the problem and evaluate insight into it

B Integrating insights and producing an interdisciplinary understanding 7. Identify conflicts between insights and their sources

8. Create or discover common ground

9. Produce an interdisciplinary understanding of the problem and test it

Table 1: An Integrated model of the Interdisciplinary Research Process. Source: Repko (2008), p. 142.

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2.2 Policy Formation Analysis

Policy Formation Analysis (figure 3) is an integrated way to investigate a policy formation process. Jenning‘s description of policy analysis (namely: policy formation process) is taken as a starting point. In our view, policy formation analysis consists of three sub-analyses, in order to investigate which stakeholders play part in the discussion and how these stakeholders frame the problem, which is backed up with content analysis.

Figure 3:. Representation of Policy Formation Analysis:

colour yellow represents object of study and colour green represents analysis applied in order to conduct research.

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Figure 4: Methodology of policy formation analysis in three stages.

2.2.1 Identification of key stakeholders (KS‘s)

In order to conduct the policy formation analysis it was first important to identify stakeholders that have shaped the decision making process. These stakeholders were categorised in general groups (A-H). This was done by conducting a content analysis in which the frequency of report of stakeholders in newspapers was observed. Moreover through literature study additional key stakeholders were identified. Furthermore, a symposium on potential pesticide toxicity related to bee mortality at the University of Wageningen (Buzzing Toxicity) was attended where several stakeholders addressed their view of the problem. All the individual stakeholders were identified through these methods and reduced to 15 key stakeholders (A1-H3) which represent the general groups (A-H).

2.2.2 Positioning of key stakeholders in two matrices

Subsequently, key stakeholders were placed in an interest-influence matrix, based on Reed et al. (2009). The influence of key stakeholders was determined by identifying the extent to which they have been able to favour their interests. The importance of key stakeholders was determined by looking at the degree in which they would be affected by a potential moratorium on NBP‘s. In other words: how much do they gain or lose from the possible moratorium?

In addition to the World Bank‘s matrix (2013) in which stakeholders are categorized based on their influence and importance, the team developed a matrix particularly focusing on the case study. This matrix enabled the team to visualise the way in which key

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stakeholders have framed the policy problem. First, observed was to what extent key stakeholders perceived bee mortality as a direct result of increased use of NBP‘s or attributed it to other causes. This was done by placing the different key stakeholders on a scale of low causality up to high causality in the relation ‗bee mortality is caused by NBP‘s. Subsequently, whether the policy problem was perceived as in effect ecological or economic by key stakeholders, was observed and placed on a scale.

Data on which stakeholder‘s positions were chosen were based three sources; (1) stakeholder‘s viewpoints as observed in the content analysis (see §2.4) and (2) open source literature, such as several reports and documents (UNEP (2010), Profundo (2011), HFFA (2013), PRI (2009) etc.). Moreover (3) statements of key stakeholders as put forward in presentations during the symposium Buzzing Toxicity were translated into terms of ‗causality‘ and ‗economic – ecological‘.

Table 2 gives an overview of the variables (terms) and their definitions as used along the axes of the matrices. Based on the guidance note provided by the World Bank (2013), key stakeholders were positioned in matrix 1. A new matrix (matrix 2) was designed to capture the concept of framing in the policy formation process.

Terms Definitions

Matrix 1 Influence =

Range:

(--, -, -/+, +, ++)

The extent to which stakeholders could affect the outcome of ‗the project‘; the policy problem whether NBP‘s should be banned or not. Ranging from (--), stakeholder has very little influence, to (++), stakeholder has very large influence. Importance =

Range:

(--, -, -/+, +, ++)

The extent to which stakeholders seem to gain or lose significantly from ‗the project‘; the policy problem whether NBP‘s should be banned or not. Ranging from (--), stakeholder has very little importance in winning or losing, to (++), stakeholder has very large importance in winning or losing.

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Matrix 2 Causality =

Range:

(--, -, -/+, +, ++)

The extent to which stakeholders assume a causal relationship between the use of NBP‘s and bee mortality. Ranging from (--), stakeholder assumes no causal relationship, to (++), stakeholder assumes a direct causal relationship.

Economic - Ecological =

Range:

(--, -, -/+, +, ++)

The question to which stakeholders perceive the policy problem as ecological or economic; do they perceive the implications of a prohibition of the use if NBP‘s as an ecological benefit/cost (mostly in terms of pollination or biodiversity) or as an economic cost/benefit (mostly in terms of agriculture or innovation)? Ranging from (--), stakeholder perceives the problem as highly economic to (++), stakeholder perceives the problem as highly ecological.

Table 2: Definitions of terms used in the matrices.

I

Matrix 1: This matrix describes criteria under which stakeholders were positioned in different boxes along the axes high importance – low importance and high influence – low influence (World Bank, 2013).

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Matrix 2: This matrix describes criteria under which stakeholders were positioned in different boxes along the axes: ecological – economic and high causality – low causality.

2.2.3 Integration of matrices to identify prevailing key stakeholders

Based on these two matrices it was possible to determine how different stakeholders have shaped the policy formation process and consequently reveal which stakeholder prevailed in the process.

2.3 Integrative Technique of Extension

Framing, a political-science concept, is the leading concept of this research. This concept has been extended to support not only the problem defining analysis but also the stakeholder analysis. Repko (2008) defines the integrative technique as extension as addressing ―conflict between disciplinary concepts or assumptions by extending the meaning of an idea beyond the domain of one discipline into the domain of another discipline.‖ (p.286). Comparable to the concept of resilience, which Scheffer (Tromp, 2013) extends from the domain of ecology into the domain of economics; policy formation analyses extends the concept of framing from the domain of political sciences into the domain of economics.

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2.4 Conducting content analysis

The content analysis provided the base for the identification of stakeholders, essential to both stakeholder analysis and problem defining analysis. For both national and regional newspapers the same structured study is conducted in order to make the research valid and reliable (Droogleever Fortuijn, 2013).

The academic version of database LexisNexis was used for the identification of relevant articles. Keyword for the search was ―bijensterfte‖ (bee mortality) and as source type ―all Dutch news‖ was selected. For the list of results the option ―Duplicate Options‖ was put on ―high similarity‖. From the list with results the three biggest national- and three biggest local newspapers were selected, based on print run. Then the articles from 2008 onwards were selected. Thereafter, articles referring to another, more comprehensive article in the same newspaper with the same date, were excluded. Furthermore, some newspapers had a section recipes with an introduction were ―bijensterfte‖ was mentioned; those were excluded too.

From the relevant articles, statistics were extracted, which form the latent part of this research. While reading the articles, stakeholders were derived. The amount of articles where these stakeholders appeared were listed in the column ―Frequency‖ in the final results table (see Appendix I).

3. Results

Through the integrative approach of extension three analyses (and their underlying theories) have been combined into one policy formation analysis which was used to investigate how stakeholders shape and influence the policy cycle. The case study of this research was the policy problem whether NBP‘s should be banned or not. The policy formation analysis was conducted in three stages; the second stage (positioning of key stakeholders in two matrices) addressing the central question of this research and the latter stage (integration of matrices to identify prevailing key stakeholder) addressing the research aim as presented in the introduction. This section is divided into three parts, parallel to the three stages of the policy formation analysis.

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3.1 Results of identification of key stakeholders

Table 4 demonstrates general groups of stakeholders (A-H) and the final list of key stakeholders (A1-H3) based on individual stakeholders (I+II).

General

Stakeholders as identified through Stakeholder Analysis (SA)

Key Stakeholders Stakeholders attending buzzing toxicity categorized

Stakeholders categorized from content analysis A. Policy makers + governmental institutions and advisors A1 EU Parliament/ Commission + EFSA

3. Robert van Luttik (EFSA); 9. Bas Eickhout (EU-parlementslid Groen Links) EU Europese Raad Europese Commissie Europees Parlement Minister/Staatssecretaris van Landbouw

Ministerie van Landbouw CTGB

A2 NL government + CTGB

4. Jacoba van Wassenberg (CTGB)

B. Bee keepers B1 NBV 10. Marcel Hallmans (imker)

NBV Imkers

Imkerverenigingen

C. Farmers C1 LTO Sector land en tuinbouw

LTO

D. Consumers D1 Consumers, public Nederlandse bevolking Consumenten E. NGO‘s E1 NL Bijenstichting, Beemonitoring.org, Avaaz.org, Greenpeace Bijenstichting CLM Greenpeace Milieufederatie IUCN

F. Media F1 Zembla De Telegraaf

Algemeen Dagblad De Volkskrant De Gelderlander Noordhollands Dagblad Dagblad van het Noorden F2 National newspapers

F3 Regional newspapers

G. Persticide industry

G1 BayerCropscience 1.Mieke Hoogendoorn (Bayer)

BayerCropscience

H. Scientists H1 UU Jeroen van der Sluijs

Henk Tennekes Tjeerd Blacquiere Arie Koster Frans Jacobs

H2 WUR 5. Coby van

Dooremalen (PRI); 6. Sjef van der Steen (PRI); 7. Ivo Roessink (Alterra); 8. Tjeerd Blacquière (WUR) H3 Other scientists 2. Kees van Gestel

(VU)

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3.2 Results of positioning of stakeholders in matrices

Matrix 1 depicts the results of positioning the key stakeholders along the axes of interest/ importance. Subsequently matrix 2 depicts the results of positioning the key stakeholders in the framing matrix, along the axes of causality and ecological/ economic. As made explicit in the Methods, each stakeholder has been assessed on all four variables on the base of three sources (content analysis, open-source literature, presentations at Buzzing Toxicity Symposium), table 5 demonstrates this outcome in a concise manner. To make this process transparent, explicit and valid we have described this for each stakeholder. Stakeholder A1 (EU Parliament/ Commission + EFSA) is indicated as an example in this section, the remaining stakeholders are to be found in Appendix II.

Level -- - +/- + ++ Influence D1 B1,F2,F3,H1,H 3 A2,C1,E1,F1,G 1,H2 A1

Importance F2, F3 D1, H3 A2-A4, F1 B1, A1, H1 C1, E1, G1, H2 Causality A1, A2 - A4,

C1, G1

H2 D1, F2, H3 B1, F3, E1, F1, H2

Economic/ ecological

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Matrix 1: Influence/ Importance

A1: EU Parliament/ Commissions + European Food Safety Authority (EFSA) A2: NL department Economic Affairs (EZ)

A3: NL department Infrastructure and Environment (I&M)

A4: NL government + Commissie Toetsing Gewasbeschermingsmiddelen (CTGB) B1: Nederlandse Bijenhouders Vereniging (NBV)

C1: Land- en tuinbouworganisatie (LTO) D1: Consumers, citizens, public

E1: Nederlandse bijenstichting, beemonitoring.org, avaaz.org, Greenpeace F1: Zembla (vara)

F2: National newspapers F3: Regional newspapers G1: BayerCropscience H1: University of Utrecht

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Matrix 2: Economic – Ecological and Causality

A1: EU Parliament/ commission + European Food Safety Authority (EFSA) A2: NL department Economic Affairs (EZ)

A3: NL department Infrastructure and Environment (I&M)

A4: NL government + Commissie Toetsing Gewasbeschermingsmiddelen (CTGB) B1: Nederlandse Bijenhouders Vereniging (NBV)

C1: Land- en tuinbouworganisatie (LTO) D1: Consumers, citizens, public

E1: Nederlandse bijenstichting, beemonitoring.org, avaaz.org, Greenpeace F1: Zembla (vara) F2: National newspapers F3: Regional newspapers G1: BayerCropscience H1: University of Utrecht H2: University of Wageningen H3: Other scientists

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3.3 Explanation of assessment on three variables per stakeholder6

Stakeholder A1: EU Parliament/ commission + EFSA

Influence (--, -, +/-, +, ++) Importance (--, -, +/-, +, ++) Causality (--, -, +/-, +, ++) Economic (--, -) / Ecological (+, ++) A1 ++ + -- -- INFLUENCE

EU Parliament/ commission + EFSA have the highest influence of all stakeholders. This is due fact that if centralized European government decide for a moratorium, this effects the whole union, as a result of article 2:2.

2:2 When the Treaties confer on the Union a competence shared with the Member States in a specific area, the Union and the Member States may legislate and adopt legally binding acts in that area. The Member States shall exercise their competence to the extent that the Union has not exercised its competence. The Member States shall again exercise their competence to the extent that the Union has decided to cease exercising its competence.

EFSA is an independent research institute, however EFSA is the main adviser of the EU where all policy regarding pesticides is based on; their influence equals parliamentary influence. EFSA assesses via special protection goals (SGP‘s) through a Risk Assessment Framework.

IMPORTANCE

The main interest of A1 is the implementation of the policy it has made. The European Commission has various areas for which policy is made. The environmental action programs (EAPs) give guidance to the work of the European Commission in the environmental field. One of the four areas of the EAP is addressing environment and health issues. In the 6th EAP it is stated that: ―Pesticides used in agricultural practices require special attention‖ and further: ―Pesticides must be used responsibly and in quantities or strengths that reduce the risk they pose to health‖ (European Commission, 2001). The EAP focuses on the

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direct effect of pesticides and therefore not mentions the possible implications for food security. The European Food Safety Authority (EFSA) is responsible for the risk assessment regarding food and feed safety and provides the advice on which the European Commission bases its policy on. It serves as: ―an independent source of scientific advice and communication on risks associated with the food chain‖ (EFSA, 2013) It also considers the possible impact of the food chain on the biodiversity of plant and animal habitats. REACH is the European community regulation that monitors chemicals and their safe use. It deals with the Registration, Evaluation, Authorization and Restriction of Chemical substances. The aim of reach is: ―to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances. At the same time, REACH aims to enhance innovation and competitiveness of the EU chemicals industry.‖ (REACH, 2013). It becomes clear that on the one hand A1 tries to secure food supply and to protect the environment from harmful pollutants. On the other hand it aims to enhance the innovation and competitiveness of the EU chemicals industry. Because of these conflicting interests it is not clear whether A1 ‗loses‘ or ‗gains‘ with a possible prohibition on the use of neonicotinoïds. However, the importance of A1 in the policy problem is it that NBP‘s are banned or not, thus serving different interests, is high regarding its primary tasks.

CAUSALITY

Throughout a wide range of reports the European Food Safety Authority has taken a clear position in the debate on the use of NBP‘S related to CCD and bee mortality in general. Up to 2013, EFSA assumes no direct causal link between the use of neonicotinoïd based pesticides and bee mortality, although the EFSA does assume bee mortality and CCD existing as such.

―The cause of CCD has not been determined however many theories have been postulated including starvation, viruses, mites (Varroa), electromagnetic radiation or pesticide exposure (Hayes 2007, Cox et al. 2007, Kievits 2007).‖ (EFSA, 2008, p.6)

In 2008, the need for further research is stressed. In 2010 however, several studies have been conducted, yet no consensus on the cause of CCD and bee mortality in general is established.

―In particular, in recent years, there have been several reports of increased mortality in bees both in the EU and elsewhere. This has caused serious concern all over the

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world, but scientific studies have not been able to determine the exact cause or the extent of these increased mortalities. (...) Other factors to be considered include the use of pesticides in agriculture. At least in order to clarify if and to which extent they may play a role in bee health.‖ (EFSA, 2010, p.5).

Nevertheless, in 2008 the European Parliament has adopted a resolution which stresses the importance of measures to protect honey bees for all member states, and the need for further research. In 2010 however, EFSA‘s point in the debate remains unaltered, as in 2013.

―As yet, no direct causal link between the increased bee mortalities and specific substances or agents has been established, it is still unclear what should be done to combat it effectively.‖ (EFSA, 2010, p. 7)

―No single cause of declining bee numbers has been identified. However, several contributing factors have been suggested, acting in combination or separately. These include the effects of intensive agriculture and pesticide use, starvation and poor bee nutrition, viruses, attacks by pathogens and invasive species – such as the Varroa mite (Varroa destructor), the Asian hornet (Vespa velutina), the small hive beetle Aethina tumida and the bee mite Tropilaelaps – genetically modified plants, and environmental changes (e.g. habitat fragmentation and loss).‖ (EFSA, 2013).

It is remarkable to note the subtle change of perspective of the EFSA in the period 2010 (―no direct causal link‖) to 2013 (―include the effects of intensive agriculture and pesticide use‖). However, officially EFSA (thus A1‘s) stand in the debate had remained (up to April 29th, 2013) very low causality (--).

ECONOMIC/ ECOLOGICAL

This variable is closely linked to the variable of causality. The European Union together with EFSA pay serious attention to the problem of bee mortality, as is put forward through the newspaper analysis. However, the policy problem regarding NBP‘s is framed highly economic (--). This is due to the high economic value of NBP‘s, and their importance to agricultural practices within the EU. A17 supported a study, carried out by the Humboldt Forum for Food and Agriculture (HFFA), entitled: ―The Value of Neonicotinoid seed treatment in the European Union‖ (2013). This working paper described five scenario‘s varying from scenarios with a ban on NBP‘s on all crops to a ban on

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only sunflower or corn, and assessed the monetary impact in the agricultural value chain per scenario. The HFFA claims that in total NBP‘s contribute between 3.8 EUR and 6.3 billion EUR to GDP (p.7). This study has been used to decide policy upon, hence indicates the economic framing of the policy problem by A1.

The arguments on which other stakeholders are positioned in the matrix can be found in Appendix II. 3.4 Identifying prevailing key stakeholder

The key stakeholder that has been most successful in shaping the policy formation process to its interest can be deducted from its position in the two matrices. Matrix 1 shows that the European Union is the stakeholder that can exert most influence (++) on the policy formation process and its interest (importance) in this discussion has been labelled as high (+). Additionally, matrix 2 shows that the European Commission have framed the problem as highly economic (--) while assuming low causality (--). This corresponds to the policy outcome until April 29th 2013 (no prohibition of NBP). The outcome of the policy formation process suggests that the European Commission can be identified as the prevailing key stakeholder. It must be stated however that outcome of policy formation is also to the interest of BayerCropscience and LTO. Because there may be processes triggered by these stakeholders that are not visible their influence may actually be higher than our results suggest.

4. Conclusion

Concerns regarding bee mortality are raised by reports of beekeepers that experienced unusually high colony losses. No scientific consensus existed on the causes of this phenomenon. Several causes were mentioned which could be related to these high mortality numbers. The increased population of the Varroa destructor (mite) was seen as one of the main causes of these high number of colony losses. Other possible causes as mentioned in newspapers were an overall decline in biodiversity, viruses and other parasites. Finally, the use of pesticides and more specifically, neonicotinoïd based pesticides (NBP), was increasingly mentioned as a possible cause of bee mortality. As scientific research to a larger extent linked the use of these crop protectors to bee mortality, public concerns were raised. Different stakeholders tried to influence policy decisions regarding NBP. At that time the use of NBP was still allowed in the EU as well as in the Netherlands. The identification of policy

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options and the evaluation of these options have not led to a prohibition of NBP. The absence of policy can also be seen as policy. Dutch policy was based on research from Wageningen University, who saw no direct causal relationship between neonicotinoïd based pesticide use and bee mortality. The findings of Wageningen University opposed the conclusions from researchers at Utrecht University who clearly saw the risks these neonicotinoïd based pesticides posed to bees. The presumed cooperation between BayerCropscience -world‘s largest producer of these pesticides- and Wageningen University further raised public concerns.

The aim of this research was to identify the stakeholders that have shaped the formation of these policies. The analysis of the policy formation process showed that the European Commission can exert the most influence, as policy outcome demonstrated. This can be explained by the fact that policy of the European Commission is binding for all member states. It can be stated that the approach of the European Commission is decisive in determining policy. Their policy is based on research from the EFSA, but this research is only conducted after the European Commission requests. The European Commission will only request this research if public concern regarding a substance is high enough, and therefore has entered the political agenda. This public concern is raised (or tamed) by different stakeholders that try to influence policy outcome to their liking. The claims of stakeholders -as well as policy decisions- are supported by scientific research. This scientific research is sometimes financed by stakeholders that have a substantial interest in policy outcome. The influence of scientists may not be as direct as other stakeholders but it is nevertheless substantial. The lack of consensus on the causality between NBP and bee mortality impeded the policy formation process. Finally, the influence of NGO‘s cannot be neglected. Several NGO initiatives have been successful (Avaaz‘ petition was signed by 2.5 million people) in framing the policy problem to their liking and raising public awareness. 5. Discussion

Conducting a literature study of which the subject is topical is not the easiest one. For the discussion on honey bee mortality it meant a lack of consensus among scientists about the causes, various positions of governments and major interests for farmers and the industry. On the one hand side this makes the subject quite interesting. However, the large and continuously growing amount of information made it difficult to frame the research. Furthermore, due to the fact the subject of the

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paying one another – are interesting and might give new insights in the discussion on neonicotinoid based pesticides. In order to clarify: this study was conducted with only open source data.

Besides the open source data, the researchers have generated certain data themselves, in example the stakeholder division over the matrices in the section ―Results‖. By discussing any stakeholder and substantiate its position on the matrices with arguments it is tried to remain as objective as possible. Yet that is not as easy as it appears. Remaining neutral in the discussion whether a correlation between neonicotinoid based pesticides and non-natural honey bee mortality exists was a challenge during the study since all three researchers did see a correlation. Although much effort is done to prevent biased conclusions, some subjectivity might have slipped through.

Despite the assignment involved merely a literature study, qualitative data are used as well. Besides attending a symposium, ―Buzzing Toxicity‖ at the University of Wageningen, a few interviews were conducted. In order to be reliable and precise it is necessary to give every stakeholder the opportunity to give its conception on the subject. Since this did not happen it can be marked as a missed opportunity for this study; it may have improved the quality. In addition, another missed opportunity is the ecosystem valuation of honey bees, which has not been conducted. It could have provided key information about the importance of honey bees in an ecosystem. Choices had to be made and since ecosystem valuation is such a hard and complex calculation it was decided to exclude it for this study. Moreover, via an interview with a Dutch member of the European Parliament, Bas Eickhout, a report of a Stakeholder Analysis by the British government was obtained. According to Eichhout (personal communication, April 5th, 2013) the British government decided after this SA unanimously to ban neonicotinoid based pesticides. An analysis of this report could have given important impediments for a Dutch moratorium. Finally, the content analysis could have been more extensive, with a manifest section to clarify all the stakeholders‘ programs. It is unknown if the conclusions drawn in this research would be different; however, it would have strengthened the results with clear arguments. Needless to say the subject of this research requires more scientific research. The European moratorium on neonicotinoid based pesticides actually indicates that the case is not closed yet. The correlation between certain pesticides and bee mortality requires more research. On the side of policy formation there are subjects to be examined. A more comprehensive stakeholder analysis can give great new insights in policy formation processes. Lessons can be drawn and policy might be achieved more quickly in future, resulting in less damage for humans and their environment. A final recommendation is a proper study regarding ecosystem valuation of honey bees. The importance of bees is now mainly based on assumptions. An interdisciplinary study involving economics and ecology appears to fit best.

To conclude, the overall discussion point is about the value of scientific research. Study on the policy formation process regarding bee mortality showed that interest, influence and framing of a

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stakeholder determine to a large extend how the problem is dealt with. In other words: policy is usually based on scientific research. However, all the conducted studies cost a lot of money. Since policymakers do not have endless cash resources, monetary inflows of other institutions are necessary. Thus, the overall message that can be extracted from this study is that in the case of inflows from important stakeholders, a dispose of independence might occur in the outcome of research.

References

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Droogleever Fortuijn, J. (2013) Kwalitatieve methoden van onderzoek: Inhoudsanalyse, lecture ―Kwalitatieve Methoden van Onderzoek‖, Human Geography, University of Amsterdam. Amsterdam, January 15th 2013.

Bayer (2013). M. Hoogendoorn: Chemie & toxicologie van neonicotinoïden, Buzzing Toxicity Symposium, Wageningen University. Wageningen, April 5th 2013.

Blaquière, T. (2009). Visie Bijenhouderij en Insectenbestuiving, Analyse van bedreigingen en knelpunten. Plant Research Institute, Wageningen UR.

Borneck, R., & Merle, B. (1989). Essai d‘une evaluation de l‘incidence economique de l‘abeille pollinisatrice dans l‘agriculture européenne. Apiacta,24(1), 33-38.

Chapin III, F. S., Zavaleta, E. S., Eviner, V. T., Naylor, R. L., Vitousek, P. M., Reynolds, H. L., ... & Díaz, S. (2000). Consequences of changing biodiversity.Nature, 405(6783), 234-242.

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Costanza, R., d'Arge, R., De Groot, R., Farber, S., Grasso, M., Hannon, B., ... & Van den Belt, M. (1997). The value of the world's ecosystem services and natural capital. nature, 387(6630), 253-260.

Europe.eu (2013). Retrieved: May 21st 2013 from http://europa.eu/pol/agr/index_nl.htm

Gestel, van K. (2013) Exotoxiciteit van neonicotinoiden voor bijen en andere non-target arthropoden, lecture at Buzzing Toxicity Symposium, Wageningen University. Wageningen, April 5th 2013.

Humboldt Forum for Food and Agriculture (HFFA), entitled: ―The Value of Neonicotinoid see treatment in the European Union‖ (2013).

Hein, L. (2009). The economic value of the pollination service, a review across scales. Open Ecology Journal, 2, 74-82.

Lasswell, H. (1951). The Policy Sciences, Recent Developments in Scope and Method. Stanford University Press, Stanford, California. Chapter 1: The Policy Orientation (p.1-15).Losey, J. E., & Vaughan, M. (2006). The economic value of ecological services provided by insects. Bioscience, 56(4), 311-323.

Losey, J. E., & Vaughan, M. (2006). The economic value of ecological services provided by insects. Bioscience, 56(4), 311-323.

Luttik, R. (2013) Bijen in Europa: de EFSA opinie, lecture at Buzzing Toxicity Symposium, Wageningen University. Wageningen, April 5th 2013.

Mayring, P. (2000) Qualitative content analysis. Forum: Qualitative Social Research, Volume 1, No. 2 Art. 20. June 2000.

Moord op de honingbij (2011) [Documentary]. March 12, 2011. Retrieved from:

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Noleppa, S., Hahn, T. (2013). The value of Neonicotinoid seed treatment in the European Union, a socio-economic, technological and environmental review. Humboldt Forum for Food and Agriculture (HFFA), 2013.

Profundo (2011). Financiële banden Wageningen UR met het bedrijfsleven, een onderzoeksrapport voor Zembla. Profundo, 2011.

Reed, M. S., Graves, A., Dandy, N., Posthumus, H., Hubacek, K., Morris, J., ... & Stringer, L. C. (2009). Who's in and why? A typology of stakeholder analysis methods for natural resource management. Journal of environmental management, 90(5), 1933-1949.

Ritz Herald (2013, January 18). Essential value of neonicotinoid pesticides for Europe [Video file]. Retrieved from https://www.youtube.com/watch?feature=player_embedded&v=0a7A1gnwOWE#!

Southwick, E. E., & Southwick Jr, L. (1992). Estimating the economic value of honey bees (Hymenoptera: Apidae) as agricultural pollinators in the United States. Journal of Economic Entomology, 85(3), 621-633.

Stokstad, E. (2007). The case of the empty hives. Science 316

Tromp, J.C. (2013) What are theories, concepts and assumptions?, lecture ―Interdisciplinary Project‖, Future Planet Studies, University of Amsterdam. Amsterdam, February 14th 2013.

United Nations Environmental Programme (UNEP) (2010) Global Honey Bee Colony Disorder and Other Threats to Insect Pollinators. UNEP Emerging Issues.

Wassenberg, J. (2013) Hoe werkt de toelating van gewasbeschermingsmiddelen, lecture at Buzzing Toxicity Symposium, Wageningen University. Wageningen, April 5th 2013.

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APPENDIX I: Content Analysis

Appearance stakeholders in national newspapers + frequency:

Category Stakeholders Frequency

B1 D1 H3 A1 C1 A3 B1 H2 G1 H1 E1 B1 E1 A4 Imkers

Nederlandse bevolking, consumenten

Bijenexperts & deskundigen (i.e. Arie Koster, Telegraaf) EU (Europees Parl., Europese Commissie, Europese Raad) Sector land- en tuinbouw

Minister van Landbouw, staatssecretaris Ministerie van Landbouw

Nederlandse Bijenhouders Vereniging (NBV) Nederlands Parlement/Overheid

Nederlands Centrum voor Bijenonderzoek Verenigde Naties

Wageningen Universiteit Blacquiere Bayer

Universiteit Utrecht (Van der Sluijs, Tennekes) NGO‘s, milieuorganisaties

(Stop de Bijensterfte, Entomologische Vereniging) Imkerverenigingen

Bijenstichting

College van Toelating Gewasbeschermingsmiddelen (CTGB) FAO

IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII IIIII III IIIII II IIIII II II IIIII II IIIII IIIII IIIII IIII III III III IIII III II II I

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Possible dead causes mentioned Frequency

Landbouwgif, pesticiden, insectieciden Specified: Neonicotinoide Varroa

Gebrek biodiversiteit

Nosema cerenae (parasite)/Parasieten Virussen, bacterien en schimmels Verstedelijking , Globalisering

Slecht kastonderhoud, verwaarloosde bijen Mobiele telefonie, zendmasten

Klimaatverandering Vervuild voedsel

IIIII IIIII IIIII IIIII I IIIII IIII

IIIII IIIII IIII IIIII II IIIII I IIIII IIII IIII III III I

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Appearance stakeholders in local newspapers + frequence C1 H1 A3 H2 H3 E1 D1 E1 A1 B1 H3 B1 G1 A4 C1

Imkers (opvallend: Kruidenberg, NH-dagblad) Sector land- en tuinbouw

Universiteit Utrecht (Van der Sluijs, Tennekes) Provincie & gemeenten

Minister van Landbouw, staatssecretaris Ministerie van Landbouw

Nederlands Parlement/Overheid(NH-dagblad) Wageningen Universiteit

Blacquiere

Wetenschappers (Algemeen, Gelderlander) NGO‘s, milieuorganisaties

(Greenpeece, Milieufederatie, CLM, IUCN, EIS Nederland, IVN Nederland, KNNV) Nederlandse bevolking, consumenten

Politici (Gelderse pvv etc.) Bijenstichting

EU (Europees Parl., Europese Commissie, Europese Raad)

Imkerverenigingen

Bijenexperts & deskundigen(Frans Jacobs, Gelderlander)

Nederlandse Bijenhouders Vereniging (NBV) Bayer (Noordhollandsch dagblad)

Nederlands Centrum voor Bijenonderzoek

College van Toelating van

Gewasmiddelenbescherming

LTO Nederland (gelooft utrecht niet, gelderlander)

IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII

IIIII IIIII IIIII IIIII IIIII II IIIII IIIII IIIII IIIII IIII IIIII IIIII IIIII IIIII III IIIII IIIII IIIII IIIII I IIIII

IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII IIIII IIII

IIIII IIIII IIIII II IIIII IIIII IIIII II

IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII III IIIII IIIII III IIIII IIIII II IIIII IIIII IIIII IIII IIIII IIII IIIII IIII IIII

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Possible deadcauses mentioned Frequency

Landbouwgif, pesticiden, insectieciden Specified: Neonicotinoïds

Varroa

Gebrek/verlies biodiversiteit

Nosema cerenae (parasite)/ Parasieten Virussen, bacterien, schimmels Klimaatverandering

Verstedelijking/EHS Mobiele telefonie Slecht kastonderhoud Vervuild voedsel

IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII

IIIII IIIII IIIII IIIII IIIII IIIII IIIII III IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII IIIII IIIII IIIII IIIII III

IIIII IIIII II IIIII III IIIII II I I I

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APPENDIX I I: Explanation of all stakeholder‘s position in the matrices

Stakeholder A2-A4: NL department EZ + I&M + Dutch government + CTGB

Influence (--, -, +/-, +, ++) Importance (--, -, +/-, +, ++) Causality (--, -, +/-, +, ++) Economic (--, -) / Ecological (+, ++) Level + +/- -- -- INFLUENCE

NL department of economic affairs (EZ) (A2) is responsible for economic activity in the Netherlands, including agriculture. EZ has a higher degree of influence than the NL department of infrastructure and environment (I&M) (A3) because the problem is covered by EZ (personal communication, Eickhout April 5th 2013). They have conflicting interests; EZ tends to favour agricultural activities whereas I&M has a focus on biodiversity, nature conservation and protection of the environment. Since perspectives on the problem of both stakeholders are based on the same research conducted by Wageningen University they both perceive the problem as ‗low causality‘. I&M however approaches a potential ban on NBP from an ecological perspective. The NL government + CTGB (A4) can be compared to the functioning of the EU + EFSA but then on a national scale. In this case, policy is formed by the NL government based on advice given by CTGB.

IMPORTANCE

Like the European Commission the Dutch government seeks to implement policy it has made. The responsibility for pesticide policies lies with the ministry of economic affairs and the ministry of infrastructure and environment. The ministry of economic affairs in the Netherlands stands for: ―an enterprising country with an eye for sustainability.‖ .This ministry is responsible for agricultural policy in the Netherlands which includes policies regarding pesticides. In making this policy it has to weigh various interests. The largest pesticide producer in the world; BayerCropscience has establishments in the Netherlands and accounts for a revenue of 414 million euro‘s. Furthermore, Bayer provides around 894 jobs (BayerCropscience, 2013), which is a substantial economic interest. Despite this economic interest, the secretary of state (Sharon Dijksma) has announced that she seeks to limit certain

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applications of neonicotinoïd based pesticides because of the risk the use of them poses for honey bees. (Dijksma, 2013). The ministry itself does not directly have much to gain or lose from a prohibition on the use of neonicotinoïd based pesticides.

CAUSALITY

On February the 17th 2011 there a parliamentary debate was held in the Netherlands concerning an amendment in the enactment on insecticides and biocides (Wet gewasbeschermingsmiddelen en biociden, dating February 17th 2007; Overheid, 2013). This happened chronologically succeeding the Zembla documentary (De Moord op de Honingbij II, 2011).The parliament (Tweede Kamer) requested the government (Regering) a reassessment on neonicotinoid based pesticides, formulated in a motion as following: ―de reeds toegelaten bestrijdingsmiddelen die behoren tot de klasse neonicotinoïden opnieuw te toetsen op de effecten op de gezondheid van bijen, en hierbij ook expliciet eventuele sublethale effecten mee te nemen‖ (CTGB, 2011). The Dutch authority on assessing insecticides and biocides (the CTGB) conducted this reassessment, of which they have written an extensive report (2011). Neonicotinoid based pesticides and its relation to bee mortality as described by various scientists, is mentioned in the report. However, the CTGB concludes that is cannot be stated that neonicotinoid based pesticides significantly contribute to the deterioration of bee colonies in the Netherlands, based on an analysis of the currently available open source scientific literature (2011, p.29). The CTGB refers to the UNEP (2010) report, where bee mortality and a causal relation with the pesticides is not assumed as scientifically proven. It was very interesting to note that during the Buzzing Toxicity symposium the CTGB representative could not give an answer when a student asked why solely scientific research from the EFSA and Wageningen University where used. Concluding, CTGB, thus Dutch government, have up until 2013 framed the policy problem with a low causality (--).

ECONOMIC/ ECOLOGICAL

Different from the EU, the agricultural interests play major roles on national scale. In the newspapers it is stated that The Netherlands is leader in the use of pesticides and moreover, economic interests surpass the need for policy regarding plant protection products

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the CTGB, the Dutch version of the EFSA and independent advisor of the Dutch government. Representing the CTGB at the ―Buzzing Toxicity‖ symposium, Jacoba Wassenberg (2013) explained that risk assessment in principle is the same throughout the Union, but with nationally specific features. One of these features in The Netherlands is that the sources where the CTGB bases their policy recommendation on are not public available (personal communication, Bas Eickhout, April 5th 2013). Since the organisation is autonomous, it is imaginable that industries pay the CTGB in order to influence policy formation processes. Although this cannot be proven by open source literature, the short term framing of this stakeholder is obvious, which fits within economic (--).

Stakeholder B1: Beekeepers Influence (--, -, +/-, +, ++) Importance (--, -, +/-, +, ++) Causality (--, -, +/-, +, ++) Economic (--, -) / Ecological (+, ++) Level +/- + + + INFLUENCE

Bee keepers themselves do not play a decisive role in the policy formation process. To a larger extend they fulfill the role of raising awareness. However, since they are well united in the Dutch bee keeper association (NBV) they form a stakeholder witch is taken into account. The influence of bee keepers and their association can therefore be categorized as moderate.

IMPORTANCE

The mission of the NBV is: ―to create optimal conditions for beekeepers so that they can keep bees in a professional manner‖ (NBV 2013). The NBV serves as an interest group for beekeepers in the Netherlands. The current position of the NBV on neonicotinoïds is that they advise the Dutch governments to put a moratorium on the use of neonicotinoïds due to the lack of scientific consensus on the harmfulness. If the pesticides are indeed harmful to bees the NBV has a large interest in this discussion. The beekeepers are the ones experiencing bee mortality so in that case a prohibition would be favorable to them.

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CAUSALITY

Beekeepers do not agree on the topic of causality. At the symposium, several beekeepers indicated that it cannot be proved it is NBP‘s causing increased bee mortality. However, they do propose the precautionary principle to be taken into account. Hence, causality is indicated medium high (+).

ECONOMIC/ ECOLOGICAL:

Remarkably, among bee keepers there is also no consensus regarding bee mortality. Based on the newspaper analysis the majority of the bee keepers have ecological worries about the bee mortality rates (Appendix III: §B1). However, in the same newspapers sound noises from mainly industrial bee keepers who are concerned to lose benefits (Ibid.). Moreover, there are bee keepers who do not even recognize non-natural bee mortality (personal communication, Jan van de Waerdt, April 5th 2013). Typical is this case is the role of the NBV, the association representing a large group of bee keepers. In 2012 they again created awareness in Dutch politics, but to the surprise of members and NGO‘s without mentioning the relation between pesticides and bee mortality (Appendix III: §B1). Again it might be that different interests appear, without evidence due to a lack of open source information. Yet on the base of the open source information, the stakeholder is categorised as moderate ecological (+).

Stakeholder C1: LTO Influence (--, -, +/-, +, ++) Importance (--, -, +/-, +, ++) Causality (--, -, +/-, +, ++) Economic (--, -) / Ecological (+, ++) Level + ++ -- -- INFLUENCE

The farmers are well organized by an association too, but in contrast to the NBV the Dutch agricultural and horticultural organization has significant more political influence. The agricultural sector is an important economic industry causing that interest of farmers has a heavy weigh.

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IMPORTANCE

LTO is an employers‘ organization that promotes a strong economic and social position of entrepreneurs in the agricultural sector (LTO, 2013). Around 50.000 agricultural entrepreneurs are member of LTO Netherlands; this makes it one of the most important representatives of Dutch farmers. Farmers are the ones using neonicotinoïd based pesticides. That is why they will be affected the most if a moratorium is accepted. If the use of these pesticides is prohibited the farmers will have to look for alternatives to protect their crops. It is expected that this will result in substantial losses of yield. Therefore, their interest is very large.

CAUSALITY

LTO has published a report which entails their vision on the Common Agricultural Policy (CAP), (LTO‘s Nederland view on agricultural and rural areas policy, 2013). Improving Dutch competitiveness is number one in this vision. Environmental risks of NBP‘s are not mentioned in the vision. This stakeholder thus frames the problem low causality (--).

ECONOMIC/ ECOLOGICAL

All the sources point in the direction of an economic framing of the farmers and growers. Not surprisingly since a lack of pollination is directly noticeable through their income, and thus short term welfare. Remarkable is the opinion of this stakeholder on pesticides, especially neonicotinoid based pesticides (NBP‘s). LTO, the organisation representing farmers and growers, does not see correlation between NBP and bee mortality (see section ‗correlation‘, Appendix III: §C1). This can be declared by the economic interest farmers have. The usage of treated seeds is very labour- and cost efficient. A moratorium on NBP‘s will simply mean: more effort for the same profit (Ritz Herald, 2013).

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