Miljøprojekt, 1169 – Konsekvensanalyse af den foreslåede zoneinddeling i forbindelse med revision af direktiv 91/414/EØF om plantebeskyttelsesmidler

Konsekvensanalyse af den foreslåede zoneinddeling i forbindelse med revision af direktiv 91/414/EØF om plantebeskyttelsesmidler

Summary

Introduction and aims

The European Commission has suggested a comprehensive revision of Council Directive 91/414/EEC on the placing of Plant Protection Products (PPPs) on the market with a new zone regulation, which recommends that PPPs that have been legalized in one country and in one zone of jurisdiction should be recognized in the other countries within the same zone. This report contains the results of an impact assessment concerning the environmental and production effects which would result if Denmark were to belong to either a Northern or a Central zone. Furthermore, the analysis includes an impact assessment of the effects which would occur within Denmark arising from the Commission’s suggestion that the EU become one zone of jurisdiction regarding plant protection products to be used in glasshouses. These regulatory initiatives are analyzed in comparison with the present directive, which allows Denmark refuse approval of a PPP, which has been approved in another member state according to national pesticide regulations, if it does not meet with Danish national standards relating to groundwater, the environment and human health.

Limitations

The impact assessment includes the perspectives concerning marketing new active ingredients in Denmark, earnings and competitive power in Danish agriculture and glasshouse production as well as administrative aspects. The environmental analysis includes impact assessments on groundwater, surface water, aquatic organisms and terrestrial biodiversity. Regarding the impacts on human health, the analysis includes the possible effects on workers in glasshouses. Economic impact calculations regarding the environmental and human effects have been performed whenever possible.

Due to the nature of the report, the analyses are limited to active ingredients used in the following crops: Winter wheat, oilseed rape, potatoes, maize, strawberries, apples and carrots. Besides being important crops in agriculture and horticulture they represent different types of crops: (perennial vs. annual, winter vs. summer annual) and the use of different types of pesticides (herbicide vs. fungicide/insecticide intensive). Because glasshouse production is, to a large extent, based on biological control, it was decided to only focus on ornamental plants, as these are by far the most important glasshouse production in Denmark. Finally, the use of dichlobenil in non-crop production is analyzed.

Larger number of active ingredients

The Northern zone is much smaller than the Central zone, both with regard to cultivated land and glasshouse production. The total farmland in the Central zone accounts for over 44 % of the total EU farmland, whereas the Northern zone accounts for only 6.5 %. Out of the total pesticide use in the EU-15, the Northern zone accounts for only a few percent whilst the Central zone accounts for more than one quarter. Even if Denmark was to enter the Northern zone, it would still be a much smaller market for pesticides.

For the chosen crops, complete lists have been compiled of the number of active ingredients available in countries in both the Northern and the Central zone – compared with the amount of active ingredients available in Denmark for the same purposes. Almost all active ingredients, which have been approved in Denmark, have also been approved in the two zones. However, the number of approved active ingredients in Denmark is only 10-30 % of the total that has been approved in the Central zone, whilst it is 30-50 % of the total in the Northern zone. Consequently, the availability of active ingredients will increase in Denmark regardless of zone assignment. However, the increase in the number of active ingredients will be considerably higher if Denmark is placed in the Central zone as opposed to the Northern.

From the complete lists of active ingredients available in the two zones, additional relevance lists have been compiled for new ingredients. A new ingredient is classified as relevant if it is expected to be of agronomic and/or economic significance in one of the crops; winter wheat, rape, potato and maize. It has not been possible to compile a similar list of relevant active ingredients for the horticultural crops that are included in this survey. The classification shows that there will be a considerable increase in the number of relevant active ingredients in the Central zone compared with the Northern zone. However, only 14 new active ingredients have been identified, which are expected to be applied to a significant extent to the aforementioned crops. Out of these 14 active ingredients, 12 will be available in both the Northern and the Central zone, whereas 2 will only be available in the Central zone.

Economic advantages for agriculture and horticulture

Danish agriculture and horticulture will have a greater number of active ingredients available regardless of zone placement, but the total will be highest if Denmark is placed in the Central zone. It has only been possible to estimate the economic advantages of the 14 most relevant active ingredients for the crops; winter wheat, rape, potato and maize. The advantages are due to increased yields and/or lower prices for the relevant pesticides. The total economic gain if Denmark is placed in the Central zone is estimated to be DKK 32 million per year. For the Northern zone the total economic gain is estimated to be DKK 25 million per year. If this income flow is discounted over a period of 30 years with a 3 % discount rate, the present value is DKK 628 million for the Central zone and DKK 489 million for the Northern zone.

Access to a larger number of active ingredients provides economic advantages in addition to those quantified above. An important element in this context is improved possibilities of preventing resistance to pesticides. Resistance prevention is an especially important element in minor crops where the supply of relevant active ingredients is rather limited at present. Placement in the Central zone will give the greatest advantages concerning resistance prevention because the largest number of active ingredients will be available in this zone. Thus, placement in the Central zone will be particular advantageous for horticulture and nursery production with a large number of minor crops.

As far as pesticides prices in general are concerned, placement in the Central zone will probably also result in advantages for the users of pesticides, as it can be assumed that a larger supply of products will sharpen competition between pesticide suppliers. This is especially relevant in cases where old pesticides, which are no longer protected by patent, can be reintroduced. The demand for pesticides has relatively low price elasticity. Still, other things being equal, marginally higher use of pesticides is expected upon placement in the Central zone due to greater supply and possibly lower prices.

Administrative burden

Notionally it can be expected that compulsory mutual recognition of active ingredients will reduce the overall administrative burden for national provisional authorisation. On the other hand,, it is expected that a greater number of active ingredients will be brought up for approval in the system of mutual recognition. Furthermore, the Danish authorities expect that the evaluation procedure, within the country where the active ingredient is first evaluated will be far more demanding under the new zone system. The consequences of the new zone system on Denmark’s administrative burden will therefore depend on the number of times Denmark is called upon to be the first evaluating country, known as the Rapporteur Member State (RMS).

Groundwater pollution

There will be a considerable increase in the number of available active ingredients, compared with status quo, regardless of whether Denmark is placed in the Northern or Central zone. Calculations have been made of the possible consequences for groundwater of a reintroduction of active ingredients that have previously been phased out in Denmark. The potential pollution in groundwater is estimated from the pollution that can be found today as a result of active ingredients previously used. This method might lead to an overestimation of the actual pollution potential from reintroduction of active ingredients, because it is possible that they will not be used to the same extent as before. Conversely, it is not possible to quantify the pollution potential arising from the availability of new substances that have never been used in Denmark before.

If the assessment is confined to new ingredients relevant to crop production, there is little difference between groundwater pollution risks in the two zones. It is estimated that the pollution load affecting groundwater will increase by19-20%. The EU regulatory standard for the content of chemicals is expected to be exceeded in 5-6% of the groundwater resource. The estimated groundwater pollution is only marginally higher in the Central than in the Northern zone. However, because the multitude of active ingredients itself influences the amount of chemicals found in groundwater, placement in the Central zone implies a somewhat greater risk of groundwater pollution for this reason alone.

However, groundwater pollution risks depend to a considerable extent on the herbicide dichlobenil, which is banned in Denmark. In the Central zone, the use of dichlobenil is allowed on non-crop areas (and in apple orchards). When non-crop areas are included in the calculations, placement in the Central zone represents a considerably greater pollution potential. If Denmark is unable to prevent the reintroduction of dichlobenil, there is a risk that the groundwater pollution load will increase by 35 % and that the chemical content will exceed the EU regulatory standard in at least 14 % of the groundwater resource.

Economic consequences of increased groundwater pollution

The social costs of groundwater pollution are calculated in present value terms over a time horizon of 50 years and for discount rates of 3 and 6% respectively. The cost intervals given below depend primarily on the choice of discount rate, whereas zone placement has only marginal effects as long as dichlobenil is not considered.

One way of averting the consequences of increased groundwater pollution is to establish new well fields to replace polluted aquifers. The establishment of new well fields can be a realistic option provided the pollution exceeding regulatory standards does not exceed 5-6 % of the groundwater in Denmark. If 6 % of the Danish water supply has to be transferred to new well fields, it is estimated that the costs will be between DKK 3.1 and 5.4 billion in present value terms.

Preventive measures can made in terms of agricultural agreements concerning pesticide-free farming. Over a time horizon of 50 years this alternative implies costs with an estimated present value between DKK 5 and 27 billion– the magnitude depending on the soil types involved as well as the choice of discount rate. In addition to groundwater protection, pesticide-free farming also leads to considerable advantages for wildlife and plants, whereas the other alternatives only secure clean drinking water.

Treatment of drinking water in activated carbon filters is a possible mitigation alternative. Filtratinf 5-6% of the drinking water during the next 50 years implies costs with a present value between DKK 7 and 20 billion. The span depends on the size of the water works involved and the choice of discount rate.

If the possible use of dichlobenil on non-crop areas in the Central Zone is taken into account, the pollution of groundwater is estimated to increase by 14 % above the regulatory standard. The present value of water treatment costs in this case will be between 17 and 49 billion Danish Kroner.

Impacts on animals and plants

It has not been possible to quantify the impacts on biodiversity associated with different zone placements. Qualitative assessments indicate that compared with the present situation, the impacts on animals and plants will be worse, regardless of zone placement. However, the impacts will be worst if Denmark is placed in the Central zone.

Impacts on human health

The overall impacts on human health arising from the zone system are estimated to be rather limited. There will be a small increased risk of Parkinson’s disease. Likewise, the introduction of new active ingredients in the glasshouse sector will lead to a change in work procedures for employees in terms of longer pregnancy leaves. The total societal costs are estimated to have a present value of 38-55 million Danish Kroner depending on the choice of discount rate.

Impacts on producers and importers of pesticides

Theoretically the zone system should lead to reduced transactions costs for suppliers of pesticides as a result of more centralised approval procedures. However, it seems that the sector does not generally expect that this potential will in fact be realized. In any case, the advantages are assumed to be greater in the Central zone due to the larger market.

Importance of exemption clauses for Denmark

As already noted, the present directive gives Denmark the possibility to refuse approval of a pesticide, which has been accepted in another member state, if it does not meet with Danish national standards relating to groundwater, the environment and human health. The present analyses of groundwater pollution potentials show that there is a risk of incurring considerable social costs if the stringent Danish requirements for approval of pesticides are relaxed. This is especially so in case of placement in the Central zone where dichlobenil is available.