Thought Starter for Working Group 1

Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides - Thought Starter Working Group I: Water Resources The role of this Conference is to bring together all of the major stakeholders to discuss the European Commission’s Communication Towards a Thematic Strategy on the Sustainable Use of Pesticides. It is hoped that by the end of the day's discussions, all stakeholders will have had a chance to express their views on the Communication and the future strategy, and that convergences and divergences of opinion, as well as concrete proposals to bridge them, will be identified. The workshop will gather all experience so far gained from the practical application of the current regulatory framework and facilitate exchange of this information. * The main objectives of the Thematic Strategy on the Sustainable Use of Pesticides, as defined by the 6th Environmental Action Programme are:1 1. to minimise the hazards and risks to health and environment from the use of pesticides; 2. to improve controls on the use and distribution of pesticides; 3. to reduce the levels of harmful active substances including through substituting the most dangerous with safer, including non-chemical, alternatives; 4. to encourage the use of low input or pesticide free cultivation among others through raising users' awareness, promoting the use of codes of good practices, and promoting consideration of the possible application of financial instruments; 5. to establish a transparent system for reporting and monitoring progress made in fulfilling the objectives of the strategy including the development of suitable indicators. This working group will address actions needed for an enhanced protection of water resources in Europe; it will focus on: • • • • • • policy issues, potential problems and protection/preservation of water resources; solutions related to the ways to avoid any overlaps or contradictions in the system; ways to harmonise, improve, and speed-up implementation of existing instruments in order to protect water resources; ways to improve accountability of the current regulatory system; ways to address gaps in the existing system; potential needs and ways to develop an extended regulatory framework in order to achieve the identified objectives for the protection of water resources; ways to address water sustainability at member state level and local level (regional variability), including in the context of enlarged EU; ways to involve all stakeholders in the monitoring/control system; ways to build-up stronger public confidence in the protection of water resources; the role of the future thematic strategy in addressing these issues. 1 • • • • OJ L 242, 10.9.2002, p. 11 p. 1/6 Thought Starter – Working Group I – Water Resources – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides This Thought Starter is divided into 3 sections: Section I – Background from the Communication – contains an overview of key points identified in the Commission Communication "Towards a Thematic Strategy on the Sustainable Use of Pesticides", which relate to the topic of the working group. Section II – Commission proposals for instruments and initiatives – contains a list of Commission proposals as presented in the Communication. Section III – Stakeholders' input – contains proposals and comments put forward by stakeholders in: (i) position papers; (ii) comments on the Communication sent to the European Commission; (iii) presentations and posters for this conference. There are clear overlaps between issues to be addressed by the 3 working groups and relevant information might also be found in the other working groups' thought starters. Working groups should however focus their work on their specific topic. * Section I: Background from the Communication • Contamination of surface water and ground water, in particular of water resources used for abstraction of water for human consumption is one of the main concerns in connection with Plant Protection Products (PPP) use in Member States. Contamination of marine environments is also a concern, in particular as regards long term risks. Exposure to PPP via drinking water, although strictly limited by the EU Drinking Water Directive, requires constant efforts to monitor and – taking into account the long time scale of contamination and remediation – high scrutiny in the regulatory process. Directive 91/414/EEC – on the placing of PPP on the market – further provides for the possibility to restrict authorisation to certain uses only and to lay down specific application requirements, e.g. risk mitigation measures related to water protection. In the Water Framework Directive (WFD), the targets and principles set out in Directive 91/414/EEC for pesticides were translated into objectives for all waters and will be implemented on a river basin scale. Updated environmental requirements of the existing surface water Directive (75/440/EEC), the Directive on discharges of dangerous substances (76/464/EEC) and the groundwater Directive (80/68/EEC) have been incorporated into the WFD. For the protection of surface waters, the WFD introduces criteria for establishing a list of priority substances and priority hazardous substances, for which specific measures such as quality standards and emission controls must be taken in order to reduce or eliminate emissions, discharges and losses. A list of 33 priority substances was adopted in 2001 2; 13 of these are used in PPP. Whilst the Community will propose measures for priority substances by the end of 2003, Member States must prepare 2 • • • • Decision No 2455/2001/EC of the European Parliament and of the Council. OJ L 331, 15.12.2001, p. 1. Thought Starter – Working Group I – Water Resources – November 4, 2002 p. 2/6 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides comprehensive programmes of measures within river basin management plans by 2009, which include measures against pollution due to pesticides. • Full implementation of the WFD is expected to make a considerable contribution to an overall reduction of risks from PPP in the aquatic environment. However, the implementation process must be supported and complemented by specific initiatives regarding pesticides. These should be coherent and closely linked since the sustainable use of pesticides in European river basins is a prerequisite for the achievement of the objectives in the WFD. Spray drift, leaching or run-off are diffuse sources of uncontrolled dissemination of PPP into the environment leading to pollution of soil and water compartments (surface water and ground water), which can be minimised by controls and the respect of good application practices. Environmental contamination can also occur during and after application, cleaning of equipment or uncontrolled, illegal disposal of PPP or their containers (point sources). In order to achieve good groundwater status, the Commission will propose, by the end of 2002, criteria for assessing the chemical status of all pollutants and the reversal of upward trends in their concentration. As regards active substances contained in pesticides (and their relevant metabolites) the present limit value (0.1 µg/l), which is an exclusion criterion for authorisation purposes, is considered as the maximum permissible concentration for defining good groundwater chemical status. There exist a number of national policy initiatives aiming at the Protection of watercourses, especially in sensitive zones, e.g. by monitoring and prohibition of use of certain products in water catchment areas. Some Member states have developed national policies that prohibit aerial spraying for targeted protection of sensitive species and habitats, and protection of waters in general. There is currently no harmonised environmental monitoring of PPP in all Member States. However, some data does exist in certain Member States on water contamination. The Communication “Indicators for the integration of environmental concerns into the CAP” 3 has identified a core set of indicators and areas where indicators need to be developed further. Among those are several related to risks from PPP to the environment, including indicators of water contamination to monitor the evolution of pesticide concentrations in ground and surface water. Actual monitoring data on the situation in the Member States, such as surveys of water quality, compliance with limits for groundwater and/or surface water protection must be integrated in a wider monitoring scheme. In January 2002, the Commission adopted a proposal for a Directive on environmental liability. This proposal, currently subject to the appraisal of the European Parliament and the Council, aims to establish an environmental liability regime for the prevention and remedying of environmental damage. It covers pollution of water, damage to biodiversity and land contamination. The production of, use, storage, transport or release into the environment of PPP are among the activities covered by the proposed Directive. 3 • • • • • • • • COM (2000) 20 final. p. 3/6 Thought Starter – Working Group I – Water Resources – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides Section II: Commission proposals for instruments and initiatives • The Commission proposes the establishment within two years of national plans to reduce hazards, risks and dependence on chemical Control, tailored to local conditions. As far as water is concerned, different regions should map out their specific needs regarding pressures and impacts in water catchment areas and the plans should be closely co-ordinated or integrated with the river basin management plans under the Water Framework Directive. Reduction of risks of pollution of watercourses, ditches, and water catchment areas both through diffuse and point source pollution should be pursued through the introduction of best practices in river basin management – such as mandatory field margins or specific agreements between water companies and farmers – within the context of the Common Implementation Strategy for the WFD. The Commission supports the creation by Member States of new (where needed) or modify existing reporting systems of incidents having consequences for health and environment, which should then be coordinated. Information should be centralised and evaluated for the whole Community . The Commission proposes that the Member States report regularly on progress with national risk reduction programmes. Pending the development of harmonised indicators, they should report on progress by using the most suitable indicators currently available to them. Monitoring should include agricultural and, where appropriate, forest soils, the aquatic environment, and residues in food and feedstuff. The Commission and the Member States should actively contribute to the international development of indicators (in particular within the OECD) and their subsequent use. Further research and development is needed for: quantification of point source pollution and practical solutions to address related hazards; less hazardous methods of application and handling of PPP such as precision spraying, improved coating and packaging technology (new soluble packaging and packaging which retains less residual product when empty) and better adaptation and use of protective clothing. • • • • The Commission proposes to support or create together with the Member States research and development efforts and calls on industry to contribute to the activities. Section III: Stakeholders' input • • • • All sources of PPP-contamination should be addressed, including nonagricultural uses. Development of specific initiatives in the field of pesticides for the WFD implementation is needed. Development of 'sustainable-use' programmes should be contemplated, in some cases as an alternative to bans or strict regulations. The thematic strategy should recognise and integrate the WFD which introduces the river basin district as the managing unit, the river basin management authorities defining specific pressures and measures. Care p. 4/6 Thought Starter – Working Group I – Water Resources – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides needs to be taken to ensure that this new WFD approach based on local requirements is in no way jeopardised by the Thematic Strategy. • National pesticide use reduction programmes should include qualitative and quantitative goals to achieve, at a minimum, a mandatory target for reduction in treatment frequency. This could include goals for progressive elimination of pesticides and their residues from groundwater and other environmental media. National pesticide use reduction programmes could include control measures such as bans on applications of pesticides near drinking water well heads or in pesticide vulnerable zones, such as nature sites and in buffer zones. A twin-track approach to the problem of PPP-contamination of drinking water sources in Europe is proposed: • • • regulation under 91/414/EEC for the limited number of pesticides that cause most problems; 'sustainable-use' for the majority of pesticides that cause problems 'somewhere, sometimes, somehow'. • • Risk reduction measures for the use of pesticides are needed together with cost-effective water treatment technologies to comply with the WFD. Eliminating pesticides from water sources is not sustainable over the longterm as pesticide removal is an energy and resource intensive process. Compulsory sprayer inspection can be an effective tool for optimising PPP treatments in view of guaranteeing protection of users, the environment and especially water. Beyond a product-based approach, a focus on product uses is needed to minimise the amounts of PPP entering ground and surface water, in particular from inappropriate on-farm practices. This requires targeted efforts to identify inappropriate sources and activities, and addressing them through improved farm management practices, improved infrastructure and equipment, and collaborative approaches between stakeholders (in particular in the context of the WFD implementation). To implement the WFD, there is a need for the EU to act as a conduit for sharing best-practice. Some form of 'EU wide Observatory' for pesticides or diffuse pollution data in general would be useful. Pilot catchment forums could be set up across Europe to develop best practices and assess their potential effectiveness. An effective approach to induce high levels of adoption of sustainable practices needs to include the following key elements: Promotion of awareness and acceptance of problem by farmers; Definition of baseline "good" farming practice for each catchment, based on local factors; Training and certification; Access to independent common and credible advice; System for self-assessment with independent verification; Ongoing monitoring of environmental outcomes (e.g. pesticides in water) to check for problems; Review systems in affected catchments; Financial incentives to go beyond 'good' practice and disincentives to dropping below 'good' practice. p. 5/6 • • • • Thought Starter – Working Group I – Water Resources – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides • The straw shorteners, which are plant hormones to reduce the length of straw, are used for intensifying grain production. In order to raise the yield, they permit the use of more nitrates, which obliges farmers to use more pesticides. That means a lot of external costs from nitrates and pesticides in groundwater, costs paid by the taxpayers or water consumers, and not by the agro-industry, who can buy very cheap grain, or by chemical industry who produces nitrates and pesticides. These straw shorteners should be banned. GIS-based risk assessment tools may have a role in the future thematic strategy on the sustainable use of PPP. • General Comments • Actions should be explored to strengthen 'consumer-pull' for sustainable products to facilitate the introduction of ‘sustainable-use’ programmes; e.g. co-operation and facilitation for retailers who want to propose 'sustainable' products. Improvement of definition and effectiveness of agri-environmental measures under the CAP could provide incentives for sustainable use of PPP. Substitution to safer products is an important element to develop in the thematic strategy. Close co-operation is needed between the PPP industry, farmers and the water industry. • • • Thought Starter – Working Group I – Water Resources – November 4, 2002 p. 6/6