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SID 5 Research Project Final Report
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NoteIn line with the Freedom of Information Act 2000, Defra aims to place the results of its completed research projects in the public domain wherever possible. The SID 5 (Research Project Final Report) is designed to capture the information on the results and outputs of Defra-funded research in a format that is easily publishable through the Defra website. A SID 5 must be completed for all projects.
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ACCESS TO INFORMATIONThe information collected on this form will be stored electronically and may be sent to any part of Defra, or to individual researchers or organisations outside Defra for the purposes of reviewing the project. Defra may also disclose the information to any outside organisation acting as an agent authorised by Defra to process final research reports on its behalf. Defra intends to publish this form on its website, unless there are strong reasons not to, which fully comply with exemptions under the Environmental Information Regulations or the Freedom of Information Act 2000.Defra may be required to release information, including personal data and commercial information, on request under the Environmental Information Regulations or the Freedom of Information Act 2000. However, Defra will not permit any unwarranted breach of confidentiality or act in contravention of its obligations under the Data Protection Act 1998. Defra or its appointed agents may use the name, address or other details on your form to contact you in connection with occasional customer research aimed at improving the processes through which Defra works with its contractors.
Project identification
1. Defra Project code IF01100
2. Project title
Impact of changing pesticide availability on horticulture and an assessment of all impacts and priorities on a range of arable, horticultural and forage crops.
3. Contractororganisation(s)
ADAS UK Ltd
54. Total Defra project costs £ 48,000(agreed fixed price)
5. Project: start date................ 01 January 2010
end date................. 31 March 2010
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6. It is Defra’s intention to publish this form. Please confirm your agreement to do so...................................................................................YES NO (a) When preparing SID 5s contractors should bear in mind that Defra intends that they be made public. They
should be written in a clear and concise manner and represent a full account of the research project which someone not closely associated with the project can follow.Defra recognises that in a small minority of cases there may be information, such as intellectual property or commercially confidential data, used in or generated by the research project, which should not be disclosed. In these cases, such information should be detailed in a separate annex (not to be published) so that the SID 5 can be placed in the public domain. Where it is impossible to complete the Final Report without including references to any sensitive or confidential data, the information should be included and section (b) completed. NB: only in exceptional circumstances will Defra expect contractors to give a "No" answer.In all cases, reasons for withholding information must be fully in line with exemptions under the Environmental Information Regulations or the Freedom of Information Act 2000.
(b) If you have answered NO, please explain why the Final report should not be released into public domain
Executive Summary7. The executive summary must not exceed 2 sides in total of A4 and should be understandable to the
intelligent non-scientist. It should cover the main objectives, methods and findings of the research, together with any other significant events and options for new work.Pesticides are fundamental to the way many crops are currently grown in the UK. They provide very cost-effective options for controlling the major weeds, pests and diseases. The availability of pesticides is currently under pressure. This is due to changes in European pesticide approvals legislation, with the replacement of EU Directive 91/414/EEC with Regulation (EC) No. 1107/2009 (changing approvals legislation) and the implementation of water quality requirements (including Water Framework Directive (2000/60/EC) WFD, and Drinking Water Directive (1998/83/EC) DWD) along with other non-legislative reasons such as increasing resistance of target organisms and market acceptability driven by residues in food products. These pressures may lead to potential reductions in the availability of pesticides which may affect crop production.
This report was commissioned to provide an economic review of the impacts of legislation in order to drive research and knowledge transfer priorities. It also demonstrates the importance of mitigation measures in reducing these impacts.
Objective 2. To identify research and knowledge transfer priorities based on the impacts of changing pesticide availability across all sectors of the industry and to provide a focus for policy, industry or other action (drawing together data from previous reports on cereals & oilseed (AHDB HGCA), forage crops In order to identify where the most important research or knowledge transfer priorities lie a gross margin calculation was used. This calculation is aimed to identify where the most important areas for further research are, rather than to say that that the legislation will cost X if it is implemented in this way. For the purposes of this report a worst case scenario of complete loss of actives was assumed, whether this be through the withdrawal of approval, or through restrictions in use preventing the effective use of the active in that crop.
Objective 1 - HorticultureMethods The horticultural crops assessed in this project were; brassicas, carrots, leeks, onions, outdoor lettuce, apples, pears, stone fruit (plum), blackcurrants, raspberries, strawberries, cucumbers, tomatoes, hardy nursery stock and protected ornamentals. For each crop a standard gross margin calculation was completed based on Defra statistics for crop area and production, and Nix (2009) figures for seed, fertilisers and pesticide usage. In some crops incomplete data was available from standard sources so
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expert opinion and industry consultation was used to determine the most appropriate figures to use. These figures provided a standard base line against which to assess the impacts of specific weeds, pests and diseases. The main weeds, pests and diseases that affected each of these crops were identified by ADAS experts. The area of crop currently affected and the yield losses caused by each weed, pest or disease was determined using knowledge of the industry. This provided a business as usual scenario - which gives rise to figures for room for improvement over current practice. In addition 3 other scenarios were assessed - untreated (worst case scenario), impact of potential losses due to changing approvals legislation and impact of potential restrictions, preventing the viable use of actives, that might be required to meet to water quality legislation. In order to identify research priorities it was assumed that under the implementation of water quality legislation actives would either have their use restricted to the point where the efficacy of the active substance was compromised to the point where its use was no longer viable or that there would be the withdrawal of at risk actives. However, withdrawals are a final resort that would not occur until all other options have been reviewed. For each scenario cost to the industry was calculated, based on area affected (by the weed, pest or disease) and severity of the weed, pest or disease with available pesticides or alternative mitigation strategies in place (e.g. use of biological control).
Findings Under all scenarios weed control came out as the largest cause of yield loss, and therefore reduction in gross margin. In the changing approvals legislation and water quality scenarios the reduction in herbicide availability would result in growers having to become more reliant on costly hand weeding. This, combined with reduced yields, could reduce gross margins (across all 15 crops) by between £150-200 million in each scenario. In crops such as blackcurrant, onions, outdoor lettuce, carrots, leeks and top fruit the reduction in production, and increases in costs of production in both the changing approvals legislation and water quality scenarios could make the production of these crops unviable.
In business as usual there is room for improvement in current levels of control (and therefore increase in gross margin) of a number of pests and diseases, the most important of which are botrytis (£58 million), weevils (£52 million), aphids (£44 million) and powdery mildew (£39 million). Under changing approvals legislation the most significant impacts, after poor weed control would be on downy mildew (£59 million) and weevils (£60 million). In onions and outdoor lettuce poor downy mildew control in this scenario could result in a 50%+ reduction in production, making the crop unviable. Under the water quality scenario the majority of the actives potentially affected are herbicides, and therefore the impacts are greatest in weed control. The potential loss of chlorpyrifos could lead to reduced control of weevils (£68 million, £55 million in strawberries alone), and the loss of metaldehyde could cost £14 million, from reduced control, and increased cost of alternatives.
Objective 2 - Pesticide PrioritiesMethod All the data from previous reports (cereals and oilseeds, potatoes, forage and pulses) was produced in a similar manner to the horticulture data above. This meant that the data could all be drawn together into a single data base, allowing the cost of specific weeds, pests or diseases to be assessed across all crops. For the purpose of this assessment the change in gross margin and reduction in production were assessed, to produce overall figures for the cost of specific weed, pest or diseases across all assessed crops. In addition percentage reduction in gross margins and production were used to identify where certain crops may become unviable as a result of changing pesticide availability. These figures were used to produce a table of priorities based on the impact on total gross margin (across all assessed crops) and percentage reduction in production or gross margin in individual crops.
Findings The greatest potential impacts on crop yields, and therefore the profitability of UK farming could come about as a result of the loss of pesticides, or restriction in their use to a point where they are no longer effective, due to the requirements of water quality legislation. The largest of these losses could arise as a result of poor control of black-grass in cereals and arable rotations (£532 million) and broad-leaved weed control across all crops (£316 million). However the losses of active substances to water quality legislation are by no means definite, with other mitigation options likely to be attempted before the withdrawal of any actives occurs. Restrictions could be put on the timing of application, for example not applying certain herbicides when the drains are flowing. For herbicides such as propyzamide this would prevent growers from being able to effectively use the active ingredient as the main application period for propyzamide in oilseed rape is November through to January, when soils are wet. Applications at other times of year would not effectively control the target weeds. This work highlights the importance of
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protecting water from these actives, in order to maintain the effectiveness and availability of these active ingredients and to maintain production.
Aside from the impacts of potential pesticide losses to water quality legislation the next most significant losses would arise from the potential loss of herbicides to changing approvals legislation with broad-leaved weeds potentially costing £206 million across all industries and black-grass £187 million predominantly to the arable industry. Under business as usual poor control of foliar diseases, such as crown rust, in the large areas of grassland present in the UK could be costing £147 million in reduced feed value. Ear diseases such as fusarium in cereals and maize are currently costing these industries £108 million on lost yield potential and reduced grain value. Loss of active substances to changing approvals legislation could result in increased yield losses from downy mildew in horticultural crops (£53 million).
In terms of viability of the industry the reduced ability to control weeds as a result of potential herbicide losses to water quality legislation could result in such large increases in costs / or reductions in yield that the production of a specific crop may no longer be viable. Crops affected in this way are blackcurrants, outdoor lettuce, winter barley, oilseed rape, wheat (with gross margins for all of these crops potentially falling by 40% or more), with clover and pulses likely to see over a 30% reduction in production.
Poor control of weeds as a result of loss of pesticides to the changing approvals legislation could reduce gross margins of onions, leeks and vining peas 40%. Loss of fungicides to changing approvals legislation could reduce control of downy mildew in outdoor lettuce and onions reducing GM by over 50%.
Project Report to Defra8. As a guide this report should be no longer than 20 sides of A4. This report is to provide Defra with
details of the outputs of the research project for internal purposes; to meet the terms of the contract; and to allow Defra to publish details of the outputs to meet Environmental Information Regulation or Freedom of Information obligations. This short report to Defra does not preclude contractors from also seeking to publish a full, formal scientific report/paper in an appropriate scientific or other journal/publication. Indeed, Defra actively encourages such publications as part of the contract terms. The report to Defra should include: the scientific objectives as set out in the contract; the extent to which the objectives set out in the contract have been met; details of methods used and the results obtained, including statistical analysis (if appropriate); a discussion of the results and their reliability; the main implications of the findings; possible future work; and any action resulting from the research (e.g. IP, Knowledge Transfer).
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Background Pesticide availability in Europe is changing. This results from changes to legislation and the implementation of existing legislation, as well as from commercial pressures on availability. The impacts predominantly arise as a result of the replacement of 91/414/EEC with Regulation (EC) No 1107/2009 (changing approvals legislation) and the implementation of water quality legislation, including the Water Framework Directive (2000/60/EC) (WFD) and Drinking Water Directive (1998/83/EC) DWD. The changing availability of pesticides in Europe will have impacts on all areas of UK agriculture and horticulture with a reduced number of pesticides available for use on a wide range of crops. ADAS have produced, and published, a series of reports looking at the economic and production impacts of changing pesticide availability on a range of crops; for HGCA on cereals and oilseeds, Potato Council on potatoes and for EBLEX and DairyCo on forage and grassland. ADAS have also collated data for PGRO on pulses, PGRO are compiling the final report. In addition HDC and Defra funded the collation of data looking at the yield implications of pesticide losses due to the revision of 91/414/EEC on 15 specified horticultural crops.
Since the publication of these reports it has been possible for the first time be possible to identify across all arable, horticultural, grass and forage crops the key issues and priorities for attention. It was important that this information was collated and assessed so that policy development can address the key issues and balance pressures coming from specific sectors within a wider context. Defra commissioned this report in order to provide them with an economic review of the impacts of legislation to drive future research priorities.
Project Aims Objective 1 - To evaluate the current status of control of weeds, pests and disease in horticultural crop production how this might be affected by changes in pesticide availability.
The first part of this project aimed to complete the assessment of the impacts of pesticide losses to the 15 specified horticultural crops (13 edible crops - brassicas, carrots, leeks, onions, outdoor lettuce, apples, pears, raspberries, blackcurrants, strawberries, plums, cucumbers and tomatoes - plus hardy nursery stock and ornamentals) to include Water Quality Legislation and to produce an economic assessment of these losses, including yield and quality.
Objective 2 - To prioritise the impacts of changing pesticide availability across all sectors of the industry and to provide a focus for policy, industry or other action (drawing together data from previous reports on cereals & oilseed (AHDB HGCA), forage crops (AHDB EBLEX & DairyCo), potatoes (AHDB PC), Pulses (PGRO) and horticulture crops (Objective 1)).
The second part of this project aimed to collate across the arable, horticulture, grass and forage sectors the impacts of the changing availability of pesticides. This was done by drawing together the existing information from the HGCA, PC and EBLEX / DairyCo reports plus the data from the PGRO assessment together with the outcomes of objective 1 of this project on 15 specified horticultural crops. It draws cross sector conclusions on the current impacts of weeds, pests and diseases and the impacts of the changing approvals legislation and the implementation of water quality legislation on the production of crops in the UK. The report prioritises the range of impacts and what can be done to address these based on financial implications and yield implications. The outcome provides a document which identifies and suggests indicators and priorities to be addressed by the Availability Action Plan Implementation Group of the UK National Pesticides Strategy.
Objective 1 - Horticulture Most horticultural crops in the UK are currently produced using a variety of pesticides to control weeds, pests and diseases. Due to the relatively small area they occupy compared with arable crops, and therefore the relatively small pesticide market they provide, the availability of pesticides on horticultural crops is already limited due to lack of specific approvals, despite the development of the ‘off-label’ system for minor uses. However the number of pesticides that are currently approved and available for use on horticultural crops is under increasing pressure from a number of different sources:
Replacement of EU Directive 91/414/EEC for the approvals of pesticides with Regulation (EC) No. 1107/2009 Water quality legislation – including Water Framework Directive and the Drinking Water Directive Failure of pesticides to gain annex 1 listing under 91/414/EEC or restrictions in rates in order to gain annex 1
listing Increased resistance of pests, diseases and weeds, changes to the specified maximum residue limits and
commercial pressures, for example the costs of providing additional data for regulatory bodies to maintain product registration, compared with the likely value of future product sales.
This report aims to assess the cost of potential reductions in pesticide availability and identify research priorities for a number of horticultural crops: Brassicas (Cauliflower, Cabbage, Brussels Sprouts), Carrots, Leeks,
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Onions, Outdoor Lettuce, Apples, Pears, Plums, Blackcurrants, Raspberries, Strawberries, Cucumbers, Tomatoes, Hardy Nursery Stock and Protected Ornamentals
A gross margin calculation was established for each crop based on values taken from Nix 20091 and expert opinion. Crop areas were taken from Defra statistics for harvest year 2009 (where available). The most important weeds, pests and diseases of each crop were identified, together with the area affected by those weeds pests and diseases. For each crop or crop group, four scenarios were assessed:
Business as usual – this assessed the current yield losses that occur despite currently approved active substances being available, or the potential to increase yield if 100% control of the weed pest or disease was possible.
Untreated – predicted yield losses and impacts on quality if no active substances were used for the control of the specific weed, pest or disease.
Replacement of 91/414/EEC with Regulation (EC) No 1107/2009 (from here on referred to as the changing approvals legislation scenario) – predicted yield losses and impacts on quality if the active substances affected by the replacement of 91/414/EEC, failed to gain approval (part of the initial assessment was completed in an earlier project completed for HDC with funding from Defra).
Water Quality Legislation – predicted yield losses and impacts on quality if the active substances that are currently causing concerns in Drinking Water Protected Areas, in groundwater or to ecosystems were to be completely withdrawn from sale or to have restrictions put on their use that effectively prevent the active substance from being used in the crop, these loses have been calculated separately to the losses that could occur to the changing approvals legislation. (Although there is no direct mechanism for the withdrawal of active substances through the Water Framework Directive the potential restrictions that might be put on the use of actives could prevent the effective use of these active substances. There are also a number of active substances that have been withdrawn through other routes that caused water quality issues e.g. IPU & Trifluralin.)
If pesticide losses occurred due to both water quality and the changing approvals legislation scenario the impacts could be considerably greater.
In addition other reasons for losses of active substances were discussed. This included the loss of actives due to increased resistance, failure to meet Maximum Residue Level (MRL) legislation or other commercial pressures.
In all cases, a worst case scenario of complete active substance withdrawal (or restrictions on use preventing its application to the crop at an appropriate timing to gain effective control of the weed, pest or disease) was applied to the affected area, with an estimated yield loss and impact on quality (reduction in value) for the crop calculated. It was also possible, using these calculations, to assess the impact per affected hectare. This figure could be applied if losses, for example as a result of water quality legislation, were for a specific catchment or area, rather than a total loss of approval.
Changing approvals legislation scenario The replacement of EU Directive 91/414/EEC for the pesticide approval with Regulation (EC) No 1107/2009 will result in a number of changes to the approvals system. This replacement introduces hazard-based criteria for the ‘placing of plant protection products on the market’. As a result of this change in legislation, and following the implementation of the new Regulation on 14 June 2011, there will be pesticide active substances that will not receive approval when their current approval falls due for renewal. The number of different potential actives that could be affected by this changing legislation was initially unclear, dependent in part upon the definition of ‘endocrine disruptors’.
Endocrine disruptors interfere with the function of the endocrine system (production of hormones) by mimicking naturally produced hormones, inhibiting that action of normal hormones or by altering the concentration of hormones in the body. This can lead to disruption of reproductive cycles and birth defects. In a report dated December 20082, PSD (Pesticides Safety Directorate, now CRD Chemical Regulation Directorate) identified pesticides ‘at risk’ in a series of scenarios, with a number of different definitions of endocrine disruptors. A series of votes have taken place within Europe to establish what this legislation will contain; these include votes by the European Council in September 2008, by the European Parliament Environment Committee in November 2008
1 Nix J. (2009) The John Nix Field Management Pocketbook (39th Edition – 2009)2 Revised assessment of the impact on crop protection in the UK of the ‘cut-off criteria’ and substitution provisions in the proposed Regulation of the European Parliament and of the Council concerning the placing of plant protection products on the market. Pesticides Safety Directorate Dec 2008 http://www.pesticides.gov.uk/uploadedfiles/Web_Assets/PSD/Revised_Impact_Report_1_Dec_2008(final).pdf
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and a full MEP vote in January 2009. As a result of these votes it is expected that the Swedish definition3 of endocrine disruptors (scenario 2C in the PSD report) is the one most likely to be used. The European commission currently have a project underway4 to define endocrine disruptors in advance of the final publication of this legislation. In our assessment, we have assumed that the active substances listed by PSD in their scenario 2c are most likely to be lost, see Table 1. Although it is most likely that these actives will only be lost once their current approval expires, this assessment has been based on all actives being lost at a point in the future.
Table 1. Active substances expected to be lost due to the changing approvals legislation (Council position 2C – Swedish definition of endocrine disruption) – Source PSD report Dec 2008Error: Reference source not foundActive substance Action Reason for revoking
approvalDate current approval expires
bifenthrin Insecticide PBT / vPvB + endocrine?
Final use data March 2011
esfenvalerate Insecticide PBT 2011bitertanol Fungicide R2 + endocrine? 2020carbendazim Fungicide M2 / R2 + endocrine? 2009flusilazole Fungicide R2 + endocrine?quinoxyfen Fungicide vPvB 2014cyproconazole Fungicide R3 C3 – triazole not
assessed by Sweden2020
epoxiconazole Fungicide R3 C3 endocrine 2018fenbuconazole Fungicide R3 – triazole not
assessed by Sweden2020
mancozeb Fungicide R3 – endocrine 2016maneb Fungicide R3 – endocrine 2016metconazole Fungicide R3 – endocrine 2017tebuconazole Fungicide R3 – endocrine 2019flumioxazine Herbicide R2 2012glufosinate ammonium Herbicide R2 2017linuron Herbicide R2 + endocrine 2013pendimethalin Herbicide PBT 2013amitrole Herbicide R3 – endocrine 2011Ioxynil Herbicide R3 – endocrine 2015PBT – Persistent Bio-accumulating ToxicvPvB – very Persistent, very Bio-accumulatingM – mutagenic (category 2)R – reproductive toxin (category 2 or 3)C – carcinogen (category 3)
Water quality legislation scenarioMeeting the water quality requirements of the Water Framework Directive (2000/60/EC) (WFD) and the Drinking Water Directive (1998/83/EC) (DWD), is likely to impact on a number of important active substances. The WFD requires that all rivers, lakes, ground and coastal waters should reach good ecological and chemical status by 2015, as well as a deterioration in water quality avoided within Drinking Water Protected Areas in order to reduce the level of treatment required during the production of drinking waters. The Drinking Water Directive sets a maximum allowable concentration of 0.1ug/l for any pesticide and 0.5ug/l for total pesticides in drinking water at the tap. A number of current pesticide active substances are intermittently detected, in surface and groundwater at levels that exceed the limits set in the DWD. If these can not be mitigated for, such as through catchment management or treatment, potentially more severe approaches become a necessity.
A number of approaches to minimising active substances reaching water are being adopted including farm advice and voluntary measures (e.g. English Catchment Sensitive Farming Delivery Initiative, Voluntary Initiative), including the use of buffer zones and unsprayed areas. In the future the introduction of restrictions in use (timing, crop or rate) of specific active substances in affected catchments may be necessary.
An example of the voluntary approach to protect water comes from metaldehyde. This molluscicide is currently being detected in water. A Metaldehyde Stewardship Group was established in 2008 in response to the detection
3 Swedish Chemicals Agency September 2008 http://www.kemi.se/upload/Bekampningsmedel/Docs_eng/SE_positionpapper_annenII_sep08.pdf (18/02/10) 4 http://ec.europa.eu/research/endocrine/index_en.html (05/03/10)
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of metaldehyde in catchments used for water supply production. At certain times of year the levels of metaldehyde detected were found to exceed the drinking water standards, despite treatment of the water using state of the art water treatments processes. The aim of the group is to establish best practice for slug pellet application and disseminate information to farmers, spreader operators and distributors. As part of their work new best practice guidance has been issued for the 2010 slug pelleting season. This maintains the maximum rate of application at 700 g a.i. per hectare per annum, but reduces the maximum individual application down from 250 g to 210 g a.i. per hectare. There is also a restriction in the total amount of metaldehyde that can be applied between August and December. There are also extensions to the buffer zones between the water course and area treated with metaldehyde (not within 6m). It is hoped that these measures will reduce the amount of metaldehyde that is able to reach water.
Restrictions applied might be limited to the affected catchment or sub catchment, however many of these active substances are applied to very large areas and for some the implications could encompass a large area of the crop. For many active substances the restrictions put in place could be so difficult to work around that the product is no longer an effective option. As a result we have modelled a scenario where products are not available on substantial areas to give a worst case scenario.
This approach was used in order to highlight the importance of the particular active ingredients within horticulture and therefore the importance of taking action to prevent these active ingredients from reaching water. At no point should it be considered that a complete withdrawal of all active ingredients listed under water quality implications would ever actually occur. We have assessed losses on an area (ha) basis so that, if a restriction for use was placed on a specific catchment, the impact of this on a crop within that catchment could be assessed.
The pesticides that are currently causing concerns in ground water and surface water in England and Wales are listed in Table 2. This list includes Priority Substances, UK Specific Pollutants and pesticides that are putting Article 7 compliance at risk. Article 7 of the WFD requires member states to protect water bodies with ‘the aim of avoiding deterioration in quality in order to reduce the level of purification required in the production of drinking water’. There are a number of Drinking Water Protected Areas (DrWPAs) where assessments of water have found that the levels of certain pesticides could cause non-compliance with WFD. The levels of pesticides in these water bodies does not necessarily mean that they fail DWD requirements, although to meet these a large investment in water treatment may be required.
Table 2. Actives included in the assessment of the impact of water quality requirementsFungicides Herbicides Insecticides Molluscicidescaptan A7 MCPA A7 cypermethrin (UK SP, cPS) Metaldehyde A7,A7iprodione A7 Chlorotoluron A7 diazinon (UK SP, A7)carbendazim A7 mecoprop (UK SP, A7)
2, 4-D (UK SP)asulam A7Propyzamide A7glyphosate (UK SP, A7)carbetamide A7bentazone A7linuron (UK SP) A7metazachlor A7clopyralid A7MCPB A7fluroxypyr A7 chlorpyrifos (PS)
NB This list is wider than the list of current Priority Substances and UK Specific Pollutants as it includes active substances that are used over a wide area and have been detected in water and are putting article 7 compliance at risk.PS Priority Substance, cPS candidate Priority Substance, UK SP UK Specific Pollutant, A7 article 7 compliance.
If a water body fails to meet the necessary criteria the provisions under WFD allow for localised management plans. The preference would be for these on a voluntary basis to be implemented with the aim of improving the water quality in that area. However, many of the active substances which are listed under article 7 are used on large areas (outside horticulture) and very often the use of one active substance if restricted would be replaced by the use of another active substance which is also likely to exceed relevant criteria. This report, therefore, focuses on worst case scenarios, which assume severe restrictions on use and it should be noted that local and voluntary options would be attempted before major regulatory based changes were made.
The impacts of the potential loss of the active substances listed in Table 2 were assessed in this report. A number of active substances that have caused problems in Drinking Water Protected Areas (DrWPAs) and ground water have already been withdrawn. These active substances include; isoproturon, atrazine, diuron,
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simazine, dalapon, terbutryn, methabenzthiazuron and dichlobenil. There are also a number of insecticidal actives that have caused Ecosystem concerns that have been withdrawn from sale, these include; hexachlorocyclohexane, aldrin, dieldrin, endrin’, and permethrin. The loss of these active substances has already occurred and it is assumed in the business as usual scenario that they are not available, so no further assessment of the impacts of these losses has been conducted. In this assessment we have looked at the potential impact of the loss of the active substances causing concern in ground water and surface water.
There are a number of active substances that are classified by the EU as Priority Substances (PS), Priority Hazardous Substances (PHS) because they are considered to be ‘pollutants presenting a significant risk to or via the aquatic environment, including such risks to waters used for abstraction of drinking water’. In addition to the Priority Substances and Priority Hazardous substances member states are required to identify Environmental Quality standards for Specific Pollutants. All Priority Hazardous Substances have already been withdrawn from use in the UK, as have the majority of Priority Substances (alachlor, atrizine, chlorfenvinphos, diuron, isoproturon, simazine and trifluralin). However, chlorpyrifos is also categorised as a Priority Substance and it currently remains on the market. Given that all other actives in this group have been withdrawn it has been considered in this assessment that chlorpyrifos could also be at risk from restrictions on its use or in the worst case scenario it could be withdrawn from sale. UK Specific Pollutants (UK SP) are listed as 2,4-D, cypermethrin, diazinon, dimethoate, linuron and mecoprop. Permethrin was also listed but has had its approval withdrawn.
Other reasons for pesticide losses Active substances may be listed as Potential Future Priority Substances and UK Specific Pollutants. This list is reviewed every four years; the substances to be added to the list have not been confirmed but the review is currently underway (results due May 2010). However AMPA (the breakdown product of glyphosate), glyphosate, mecoprop and quinoxyfen have all been suggested as additions to the Priority Substances list (This information was correct at time of writing in March however as of August 2010 only quinioxifen remains on this list; AMPA glyphosate and mecoprop have all been removed). UK Specific Pollutants candidates suggested include carbendazim, chlorothalonil, glyphosate, methiocarb and pendimethalin, these actives may all be at risk of losing their approvals, or having restrictions placed on their use, at some point in the future if they are placed on these lists. Impacts of these losses have not been calculated in this project, unless the actives were also at risk from either water quality legislation of changing approvals legislation. As part of the original Council Directive 91/414/EEC legislation, a set of safety criteria had to be met by all existing pesticides in order to gain approval on to Annex1. If insufficient evidence was provided to demonstrate that chemicals met these safety criteria by December 2010, then these active substances will lose their European approval and subsequently be withdrawn from the market. There are a number of active substances that have recently had their approvals withdrawn as a result of failure to gain Annex 1 approval these include the actives listed Table 3 (this list is not exhaustive).
Table 3. Active substances that have failed to gain annex 1 approval
Active Substance Category Final use date bifenthrin5 Insecticide March 2011bromuconazole (cereals) Fungicide May 2010carbendazim Fungicide December 2009chorthal-dimethyl6 Herbicide March 2011cyproconazole Fungicide Withdrawal date not setdichlobenil7 (woody crops & non-crop uses)
Herbicide March 2010
dithianon (apples & pears) Fungicide Withdrawal date not setfenbuconazole (top fruit) Fungicide Withdrawal date not setfluquinconazole (cereals) Fungicide Withdrawal date not setguazatine (cereals) Fungicide (seed dressing) 2013isoxaben Herbicidemetaldehyde Molluscicide Withdrawal date not setmetam sodium Soil sterilant March 2014myclobutanil Fungicide (voluntary withdrawal)procloraz Fungicide Withdrawal date not setpropachlor8 Herbicide March 2010terbuthylazine (maize & pulses) Herbicide Withdrawal date not set 5 http://www.pesticides.gov.uk/uploadedfiles/Web_Assets/PSD/Bifenthrin_Revocation_Notice(1).doc 6 http://www.pesticides.gov.uk/uploadedfiles/Web_Assets/PSD/chlorthal_dimethyl_revocation_notice.doc7 http://www.pesticides.gov.uk/approvals.asp?id=2562 8 http://www.pesticides.gov.uk/approvals.asp?id=2562andlink=%2Fuploadedfiles%2FWeb_Assets%2FPSD%2FPropachlor_Decision_2008_742_EC.pdf
SID 5 (Rev. 05/09) Page 10 of 24
Data from the UK Pesticide Guide 2009. There remain a number of active substances which it is unclear whether or not there is sufficient data available for them to achieve annex 1 listing. There are also a number of active substances that have received annex 1 listing, but have required restrictions in there use in order to do so. For example metazachlor has a maximum application rate of 1 kg/ha and this can only be applied every third year on the same field. The implications of these restrictions to use were not modelled in this assessment.
There are also commercial reasons for the withdrawal of active ingredients. It costs a significant amount of money to produce and maintain the data required for approvals. Where a product has a small market share this cost can out way the value of the product. There have also been recent changes in the Maximum Residue Level limits for crops. This has meant that certain uses of active substances on particular crops are no longer possible reducing the availability of pesticides on that particular crop.
Method For each crop, a national gross margin was calculated based on standard figures from Nix 2009Error: Reference source not found, with figures modified using expert opinion where relevant. The most important weeds, pests and diseases for each crop were identified and the average area affected by that weed, pest or disease was determined. For each scenario (See Section 4), an estimate of the potential yield loss was made, where possible based on research data, but in many cases expert opinion was used, especially with reference to the scenarios, as there is very limited research data available on distribution of weeds, pest and diseases, and the yield impacts of specific pesticide losses.
Potential yield losses were calculated based on the potential for the weed, pest or disease to cause yield loss in that scenario. In the event of multiple weeds, pests or diseases being present, the total yield loss caused by single pathogen might be less than this estimate, due to interactions between the weed, pest or disease species. Consequently, the potential yield reductions given for the individual weeds, pests or diseases should not be added together. If this approach was adopted, calculated losses could actually exceed the potential yield of the crop.
The pesticide active substances that are applied to the crop often control more than one weed, pest or disease. Because multiple weeds, pests or diseases are controlled by a spray programme, the allocation of the cost of that programme to each weed, pest or disease species is variable dependent upon the level of each pathogen present in the crop at any one time. In the untreated scenario therefore, it has been assumed that as there are no actives applied the entire cost of weed, pest or disease control has been removed from the gross margin calculation. For weeds only the cost of herbicides has been removed, for pests only the cost of the insecticides and for diseases only the cost of fungicides, so as to separate out the impacts of that specific weed, pest or disease. In some cases, where control of a minor disease is incidental to more expensive applications made for other pathogens, this can make the untreated scenario actually appear more economically viable than treatment.
AnalysisEach crop was analysed separately. For each crop there is a brief description of the crop assessed (where relevant assumptions made have been included in an appendix at the end of the document). This is followed by a table of the gross margin information used in the calculations. For each crop the weeds, pests and diseases that had the largest impacts on the crop were identified by the crop experts (and from the previous work carried out for the HDC and Defra on the impacts of 91/414/EEC). Each of these weeds pests and diseases was assessed for their impact on the crop in each of the four scenarios. For each weed, pest or disease an estimate was made of the percent area of the crop affected based on expert opinion. Having established the area affected the impact of the weed, pest or disease on harvestable yield, marketable yield and price, on the affected crop, were determined using expert opinion.
For each crop the business as usual and untreated scenarios are described first, with the impacts of specific weeds, pests and diseases identified. This is followed by tables showing the data for each weed, pest and disease in the business as usual and untreated scenarios.
This is followed by sections for the other two scenarios; changing approvals legislation scenario and Water Quality. Each section starts with list of active substances that could potentially be affected on that crop in that scenario. There is then a description of what the impact of the loss of these active substances with be on the specific weeds, pests of diseases affected. Where relevant suitable mitigation methods have been identified to enable production to be maintained at the highest level.
SID 5 (Rev. 05/09) Page 11 of 24
Summary of resultsThis work identified what the potential cost to the industry (in terms of reduction in gross margin) the changing availability of pesticides would cause (See tables 4, 5 & 6). In summary; The potential loss of herbicides to control broad-leaved weeds due to water quality legislation could cost up to
£132 million. Carrots (£26 million), strawberries (£24 million), onions (£14 million), outdoor lettuce (£12 million) and leeks (£10 million) would be particularly badly affected.
Losses of active substances to changing pesticide legislation could cost £103 million in as a result of reduced yield and increased costs of control relating to broad-leaved weeds. Outdoor lettuce (£51 million), strawberries (£33 million) and raspberries (£11 million) would be particularly badly affected.
Grass weed control would also be affected by the reduction in herbicide availability and could cost the industry £75 million under the changing approvals scenario and £49 million if herbicides were to be lost or have their use severely restricted due to the water quality legislation.
The potential loss of insecticides, e.g. chlorpyriphos, due to failing to meet water quality requirements could cause losses in control of weevils in certain crops, costing the industry £68 million in reduced yields. The worst affected crops would be strawberry (£55 million) and hardy nursery stock (£13 million).
The loss of insecticides to approvals legislation could cost the industry £60 million as a result of poor control of weevils. The worst affected crops would be strawberries (£41 million), raspberries (£13 million) and hardy nursery stock (£7 million).
The loss of fungicide active ingredients to the changing approvals legislation could result in significant reductions in yield due to downy mildew. This could cost the horticulture industry £59 million. The worst affected crops would be outdoor lettuce (£29 million) and onions (£26 million).
A reduction in insecticides due to changing approvals legislation could reduce aphid control in certain crops (£23 million). Raspberries (£15 million) and outdoor lettuce (£8 million) would be worst affected.
Changing approvals legislation would also result in reduced control of powdery mildew reducing gross margins by £14 million. Raspberries (£12 million) would be the worst affected crop.
The potential loss of metaldehyde, an important molluscicide, due to failures to meet with water quality legislation could reduce the ability to control molluscs, especially snails. This could reduce gross margins by £14 million. Strawberries (£11 million) and raspberries (£2 million) would be the worst affected crops.
Rusts would become more difficult to control with the pesticides left available after the changes to the approvals legislation. This could reduce yields and therefore the total gross margin by £9 million, with raspberries the main crop affected.
Not all weeds, pests and diseases are well controlled with the currently available plant protection products. In this assessment we also identified under the business as usual scenario where there was room for improvement in the horticulture sectors. Important areas where there is room for improvement are (the potential increase in gross margin is given in brackets);
Weed control of both broad-leaved weeds (£58 million) and grass weeds (£51 million), these generally affect all crops, but the potential for improvement in weed control in strawberries is particularly high at £29 million as it is estimated that in current practice yields could be increased by 15% if better weed control was achievable.
Botrytis currently causes significant crop losses (£52 million), with strawberries (£33 million), raspberries (£5 million), outdoor lettuce (£5 million) and hardy nursery stock (£4 million) having the greatest potential to increase in value.
Weevil control is not always very effective, if improved control were achieved there is the potential to increase the gross margin of the 15 horticultural crops assessed by £52 million. Strawberries (£44 million) and hardy nursery stock (£7 million) have the most to gain from improved control.
Aphids currently cause crop losses amounting to £45 million across the 15 horticultural crops. If improved control was achieved outdoor lettuce (£20 million), carrots (£14 million) and brassicas (£6 million) would receive the greatest benefit from improved control.
Powdery mildew causes yield losses in a range of crops with a potential value of £37 million. Strawberries (£25 million), hardy nursery stock (£4 million) and tomatoes (£4 million) have the greatest potential to increase production, and therefore gross margin, if improved control could be achieved.
Slugs and snails affect a number of crops causing an estimated £32 million loss in potential yields. If improved control were achieved strawberries (£20 million), outdoor lettuce (£6 million) and brassicas (£5 million) would see the greatest benefits.
Downy mildew is not well controlled in all crops, improved control could be worth £22 million for the horticulture sector. Outdoor lettuce (£10 million), tomatoes (£6 million) and onions (£3 million) have the greatest potential to increase in gross margin if better levels of control could be achieved.
SID 5 (Rev. 05/09) Page 12 of 24
Table 4 Potential financial implications of pesticide losses or restrictions in approvals on weed control in 3 scenarios £K to the industry (RFI – room for improvement, Approvals – changing approvals legislation & WQ – water quality legislation)
Impact of herbicide losses
£K
Scen
ario
Bro
ad-le
aved
w
eeds
Gra
ss w
eeds
(in
c co
uch)
Volu
ntee
r po
tato
es
RFI 1,111 0 777Approvals 3,126 0 0WQ 2,457 0 719RFI 4,524 3,176 7,146Approvals 25,852 15,285 14,455WQ 0 0 11,458RFI 1,060 2,120 707Approvals 10,160 12,633 1,814WQ 327 0 424RFI 797 1,898 224Approvals 13,745 10,880 1,784WQ 577 0 346RFI 9,505 0 0Approvals 11,952 0 0WQ 51,446 0 0RFI 0 0 0Approvals 0 0 0WQ 19,126 734 0RFI 0 0 0Approvals 0 0 0WQ 2,708 61 0RFI 0 0 0Approvals 198 121 0WQ 5,025 113 0RFI 170 85 0Approvals 214 79 0WQ 6,318 10,114 0RFI 9,492 4,746 0Approvals 6,311 10,998 0WQ 11,189 11,273 0RFI 29,414 37,257 0Approvals 23,716 15,992 0WQ 33,362 25,816 0RFI 0 0 0Approvals 0 0 0WQ 0 0 0RFI 0 0 0Approvals 0 0 0WQ 0 0 0
RFI 2,169 2,169 0Approvals 8,674 8,674 0WQ 434 434 0RFI 0 0 0Approvals 0 0 0WQ 0 0 0RFI 58,241 51,451 8,854Approvals 103,949 74,662 18,054WQ 132,968 48,545 12,947
Onions
Leeks
Carrots
Brassicas
Plums
Pears
Apples
Lettuce
Cucumbers
Strawberries
Raspberries
Blackcurrants
Total
Ornamentals
Hardy nursery stock
Tomatoes
SID 5 (Rev. 05/09) Page 13 of 24
Table 5 Potential financial implications of pesticide losses or restrictions in approvals on pests in 3 scenarios £K to the industry (RFI – room for improvement, Approvals – changing approvals legislation & WQ – water quality legislation)
Impact of insecticide losses £K
Scen
ario
Aph
ids
Cab
bage
root
fly
Car
rot f
ly
Mot
h an
d bu
tterf
ly
Thrip
s
Spid
er m
ites
Wee
vils
Slug
s an
d sn
ails
RFI 5,927 15,003 0 6,650 0 0 0 4,742Approvals 200 0 0 200 0 0 0 0WQ 0 2,405 0 0 0 0 0 0RFI 13,572 0 4,284 2,936 0 0 0 0Approvals 0 0 0 551 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 0 0 0 0 309 0 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 0 0 0 0 448 0 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 20,113 0 0 6,165 0 0 0 6,165Approvals 7,706 0 0 0 0 0 0 0WQ 7,706 0 0 0 0 0 0 17RFI 0 0 0 0 0 0 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 0 0 0 0 0 0 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 15 0 0 18 0 0 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 0 0 0 0 0 0 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 646RFI 1,329 0 0 190 0 949 949 237Approvals 15,234 0 0 280 0 311 12,635 0WQ 0 0 0 285 0 0 0 2,041RFI 0 0 0 1,471 0 8,236 44,121 20,394Approvals 0 0 0 958 0 270 40,685 0WQ 0 0 0 7,326 0 0 55,208 10,914RFI 1 0 0 276 1 79 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0RFI 551 0 0 1,652 0 275 0 0Approvals 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0
RFI 3,123 0 0 1,952 3,253 4,337 6,506 0Approvals 62 0 0 39 1,340 51 6,583 0WQ 1,041 0 0 651 65 0 13,011 0RFI 122 0 0 122 178 9 0 13Approvals 252 0 0 455 0 23 0 0WQ 119 0 0 0 0 0 0 593RFI 44,753 15,003 4,284 21,431 4,189 13,885 51,576 31,551Approvals 23,454 0 0 2,483 1,340 656 59,902 0WQ 8,866 2,405 0 8,262 65 0 68,219 14,211
Total
Ornamentals
Hardy nursery stock
Tomatoes
Cucumbers
Strawberries
Raspberries
Blackcurrants
Plums
Pears
Apples
Lettuce (outdoors)
Onions
Leeks
Carrots
Brassicas
SID 5 (Rev. 05/09) Page 14 of 24
Table 6 Potential financial implications of pesticide losses or restrictions in approvals on diseases in 3 scenarios £K to the industry (RFI – room for improvement, Approvals – changing approvals legislation & WQ – water quality legislation)Impact of fungicide losses £K
Pow
dery
m
ildew
Dow
ny m
ildew
Bot
rytis
Scle
rotin
ia
Leaf
spo
ts
Leaf
spo
ts
Rus
ts
Pyth
ium
Phyt
opht
hora
RFI 1 890 0 0 9,855 9,855 0 0 0Approvals 40 0 0 0 187 187 0 0 0WQ 0 276 0 0 0 0 0 0 0RFI 1,906 0 0 8,124 3,811 0 0 2,936 0Approvals 1,390 0 0 1,316 4,049 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 0 0 0 0 0 0 2,120 0 1,272Approvals 0 0 0 0 0 0 10 0 7WQ 0 0 0 0 0 0 0 0 0RFI 0 3,486 3,498 0 0 0 0 0 0Approvals 0 26,338 0 0 0 0 0 0 0WQ 0 0 4,912 0 0 0 0 0 0RFI 0 9,965 4,983 5,395 0 0 0 0 0Approvals 0 29,289 0 0 0 0 0 0 0WQ 0 0 84 0 0 0 0 0 0RFI 0 0 0 0 0 0 0 0 60Approvals 0 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 0 0 0 0 0 0 0 0 0Approvals 59 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 0 0 0 0 0 0 0 0 0Approvals 0 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 0 0 0 0 68 0 0 0 0Approvals 0 0 0 0 81 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 2,373 0 4,746 0 0 0 475 0 0Approvals 11,847 0 0 0 0 0 8,999 0 0WQ 0 0 0 0 0 0 0 0 0RFI 24,708 0 33,336 0 0 0 0 0 0Approvals 668 0 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 39 59 197 20 0 0 0 99 0Approvals 0 59 0 0 0 0 0 0 0WQ 0 0 0 0 0 0 0 0 0RFI 3,855 5,508 551 0 0 0 0 441 551Approvals 0 0 0 0 0 0 0 0 0WQ 0 2,203 1 0 0 0 0 0 0RFI 4,337 1,735 4,337 0 0 0 607 0 0Approvals 0 2,602 0 0 0 0 0 0 0WQ 0 0 3,501 0 0 0 0 0 0RFI 33 244 1,067 2 0 0 9 133 0Approvals 0 487 0 0 0 0 0 0 0WQ 0 0 720 6 0 0 0 0 0RFI 37,252 21,887 52,714 13,542 13,735 9,855 3,210 3,608 1,883Approvals 14,003 58,775 0 1,316 4,318 187 9,009 0 7WQ 0 2,479 9,218 6 0 0 0 0 0
Brassicas
Carrots
Leeks
Onions
Lettuce
Apples
Pears
Plums
Blackcurrants
Raspberries
Strawberries
Cucumbers
Tomatoes
Hardy nersury stock
Ornamentals
Total
SID 5 (Rev. 05/09) Page 15 of 24
Objective 2 - PrioritiesBackgroundPesticide availability in Europe is changing. This is due to changes in European pesticide approvals legislation, with the replacement of EU Directive 91/414/EEC with Regulation (EC) No. 1107/2009 (changing approvals legislation) and the implementation of water quality requirements (including Water Framework Directive, WFD, and Drinking Water Directive) along with other non-legislative reasons such as increasing resistance of target organisms and market acceptability driven by residues in food products. The changing availability of pesticides in Europe will have impacts on all areas of UK agriculture, horticulture and forage crop production with a reduced number of pesticides available for use on a wide range of crops. ADAS have produced, and published, a series of reports looking at the economic and production impacts of changing pesticide availability on a range of crops; for HGCA on cereals and oilseeds, Potato Council on potatoes and for EBLEX and DairyCo on forage and grassland. ADAS have also collated data for PGRO on pulses, PGRO are compiling the final report. In addition the first part of this project involved producing a similar report for 15 horticultural crops.
For the first time it is now possible to identify across all arable, horticultural, grass and forage crops the key issues and priorities for attention. It was important that this information was collated and assessed so that policy developments can address the key issues and balance pressures coming from specific sectors within a wider context.
Project aimThis project aimed to provide an economic review of the impacts of legislation across all sectors arable, horticulture, forage, pulses and potatoes in order to drive research and knowledge transfer priorities. This was done by drawing together the existing information from the HGCA, Potato Council and EBLEX / DairyCo reports plus the data from the PGRO assessment together with the outcomes of part 1 of this project on 15 specified horticultural crops. It draws cross sector conclusions on the impacts of the replacement of EU Directive 91/414/EEC with Regulation (EC) No. 1107/2009 (changing approvals legislation) and the implementation of water quality legislation on the production of crops in the UK. The report prioritises the range of impacts and what can be done to address these based on financial implications and yield implications. The outcome of this is a document which identifies and suggests indicators and priorities which could be addressed by the industry and could provide the basis of indicators for the Availability Action Plan Implementation Group of the UK National Pesticides Strategy.
MethodologyAll the data from previous reports (cereals and oilseeds, potatoes, forage and pulses) was produced in a similar manner to the horticulture data produced in objective 1 of this project. For each individual crop the key weeds, pests and diseases that affect the crop were identified. The area of the crop that is affected by each weed, pest or disease was determined from survey data where available or from expert knowledge where data was not present. In each of the five reports four basic scenarios were assessed;
Business as Usual (BAU) – this assessed the current impacts of the weed, pest or disease and therefore identified areas where there was room for improvement over current practice.
Untreated – this assessed the worst case scenario, if no pesticides were available. It assessed the level of losses that would occur as a result of each weed, pest or disease. In this scenario suitable mitigation methods were applied to reduce the impact of these losses to a minimum; e.g. increased cultivation or hand weeding to control weeds.
Changing approvals legislation (referred to as revision of 91/414/EEC in earlier reports) – this identified the most likely pesticide active substances to be lost due to the changes in approvals legislation based on the list of active substances published by PSD (now CRD) in December 20089. An assessment was made as to what impact these losses would have on the level of control of specific weeds, pests or diseases.
Water quality legislation (referred to as Water Framework Directive in earlier reports) – The implementation of this legislation requires water bodies within the UK to meet certain legislative requirements. Currently there are a number of active substances that are being detected in water that are of concern. A number of approaches to minimising the detection of these substances in water are currently being undertaken. However, as a final resort there is the risk that some active substances might have severe restrictions on their use or at an extreme might be withdrawn from the market in order to protect water. In this scenario the impact of a complete withdrawal or restrictions that prevent the effective use of the active substances has been assessed, to highlight the importance of protecting these actives and looking for appropriate solutions.
9 Revised assessment of the impact on crop protection in the UK of the ‘cut-off criteria’ and substitution provisions in the proposed Regulation of the European Parliament and of the Council concerning the placing of plant protection products on the market. Pesticides Safety Directorate Dec 2008 http://www.pesticides.gov.uk/uploadedfiles/Web_Assets/PSD/Revised_Impact_Report_1_Dec_2008(final).pdf
SID 5 (Rev. 05/09) Page 16 of 24
For each crop a standard gross margin was calculated, based on figures from Nix 200910, and applied to the crop areas and production figures available from Defra statistics. For each weed, pest or disease in each scenario an assessment, based mainly on expert knowledge, with where possible, experimental reference to support the assessment, was made as to what percent area of the crop would be affected and what percentage yield loss (on average) would be expected on the affected crop. This then enabled economic and yield impacts to be determined.
As a result of all of these assessments having been conducted in a similar manner it was possible to draw all of these data sets together into a single large dataset. This allowed the cost of specific weeds, pests or diseases to be assessed across all crops. For the purpose of this assessment the change in gross margin and reduction in production were assessed, to produce overall figures for the cost of specific weed, pest or diseases across all assessed crops. In addition percentage reduction in gross margins and production were used to identify where certain crops may become unviable as a result of changing pesticide availability. The report also identifies the key issues associated with risks to water quality. These are listed separately as the way they might need to be addressed is different – with as much emphasis, at least initially, on stewardship and retention as finding alternative options.
These figures were used to produce a table of priorities based on the impact on total gross margin (across all assessed crops) and percentage reduction in production or gross margin in individual crops.
The relative size (in terms of area grown and value) of the crops varied hugely with grassland (temporary and permanent) making up over 55% of the land area assessed, whilst some of the horticultural crops are high value, but grown on a small area (e.g. raspberry). See Table 4 for details of all the crops included in this overview. .
The largest potential impacts come from a potential loss of herbicides to water quality legislation, closely followed by losses of herbicides to changing approvals legislation. These losses are broad affecting a wide range of crops. The other significant peaks show that there is room for improvement in foliar disease control in both arable (including grassland) and horticultural crops.
Table 4 Standard figures used for assessment (crop area, yield, production & gross margin)
CropUK area (2008)
Average yield
Total production Gross margin Price
ha t/ha t/year £/year £/t (HNS & ornamentals £ /plant)
Wheat 2,072,900 8.25 17,101,425 871,889,379 135Winter barley 421,000 5.75 2,420,750 128,271,683 145Spring barley 609,000 5.25 3,197,250 210,902,790 150Oats 130,200 6.50 846,300 42,293,300 125OSR 599,100 3.25 1,947,075 203,414,420 300Potatoes - processing 36,000 49 1,764,000 75,996,000 110Potatoes - fresh 86,000 43 3,698,000 198,746,000 130Potatoes - seed 17,280 25 432,000 34,715,520 200Peas – vining 37,000 4.75 175,750 36,334,000 300Peas - combining 40,000 4.64 185,600 27,016,000 210Beans - winter 85,000 4.36 370,600 39,474,000 165Beans - spring 80,000 4.21 336,800 40,060,000 175Beans – broad 900 5 4,500 1,687,500 375Beans – dwarf green 900 6 5,400 1,296,000 240Grass - permanent* 5,035,443 10 60,350,000 6,994,565,000 140Grass - temporary* 1,141,000 15 17,115,000 2,523,321,500 170Clover – white* 247,572 8 1,980,576 293,000,440 164Clover - red* 4,000 12 48,000 6,672,000 154Lucerne* 1,000 14 14,000 2,006,000 159Lupins* 6,000 3 18,000 1,248,000 175Maize* 152,700 12 1,832,400 100,079,580 92Stubble turnips* 23,944 6.9 126,960 13,839,008 145
10 Nix J. (2009) The John Nix Field Management Pocketbook (39th Edition – 2009)
SID 5 (Rev. 05/09) Page 17 of 24
CropUK area (2008)
Average yield
Total production Gross margin Price
ha t/ha t/year £/year £/t (HNS & ornamentals £ /plant)
Kale* 10,266 7.2 28,440 1,959,042 119Forage rape* 10,266 4.9 19,355 1,972,551 146Fodder beet* 7,495 13.65 79,170 4,138,735 96Chicory* 20,000 15 300,000 39,700,000 146Brassicas 26,719 17.6 470,254 87,312,348 473Carrots 11,028 67.9 719,300 77,862,960 180Leeks 1,647 26 42,822 20,042,343 825Lettuce - Outdoors 5,592 20.8 116,314 63,727,550 839Onions 8,575 41 351,575 12,622,400 132Apples 8,741 27.8 243,000 78,284,396 495Pears 1,472 13.5 19,872 2,054,176 503Plums 880 13 11,440 14,415,280 1,472Blackcurrant 2,250 6.2 13,950 5,539,500 610Strawberry 4,770 21.4 102,078 140,496,773 1,921Raspberry 1,634 8.7 14,216 79,473,021 6,677Cucumber 105 557 58,485 32,888,625 675Tomato 212 416 88,192 106,653,808 1,249Hardy Nursery Stock (plants) 939 106,535 253,553,300 261,315,670 3Ornamentals (plants) 9,519 539,992 507,052,488 175,148,853 0.43 Total 10,959,049 877,254,637 13,052,436,152
* value & gross margin of forage and grass crops was based on relative feed value (in comparison to feeding barley).UK Area, yield & production – Defra StatisticsGM based on NIX (modified for horticultural crops, forage crops the value of the crop is based on relative feed value compared to barley)
List of prioritiesThree separate priorities lists have been identified based on different criteria;
Total cost to the industry (across all sectors) of specific weeds, pests or diseases,
% reduction in gross margin and production caused by a specific weed, pest or disease in order to identify crops where the increased costs of production and or losses of yield would result in the crop no longer being viable at current prices or where serious short falls in production could occur, and where production of a certain crop might no-longer be viable.
% reduction in gross margin and production due to the impacts of water quality legislation.
SID 5 (Rev. 05/09) Page 18 of 24
Total impact across all sectorsTable 5. Research priorities across all sectors based on total impact on gross marginRank (based on GM)
Scenario Category Weed / pest / disease Loss of margin (£M)
1 Water quality Grassweeds Black-grass 5322 Water quality BLW 3163 BAU Foliar disease Crown rust & other foliar
diseases in grassland217
4 Approvals legislation BLW 2065 Approvals legislation Grassweeds Black-grass 1876 Water quality Grassweeds Rye-grass 1657 BAU Grassweeds 1618 BAU BLW 1479 BAU Ear diseases Fusarium (ear) 108
10 Water quality Grassweeds Annual meadow grass 10411 Approvals legislation Grassweeds Annual meadow grass 8512 Water quality Slugs & snails Slugs & snails 7813 BAU Viruses General viruses (grassland) 71
14 Approvals legislation Foliar disease Downy mildew (hortic) 5915 BAU Foliar disease Blight 5616 BAU Foliar disease Botrytis (hortic) 5417 Approvals legislation Volunteers Volunteer potatoes 5118 Water quality Beetle pests Blossom weevil 4419 BAU Foliar disease Powdery mildew (hortic) 4120 BAU Fly pests Frit fly 36
Table 5 shows that the largest potential losses to the industry could occur as a result of losing herbicides for the control of grass weeds, such as black-grass (£532 million) and rye-grass (£165 million), and for the control of broad-leaved weeds (£316 million) due to the implementation of water quality legislation. However given that there is no certainty over pesticide losses to the implementation of this legislation this should perhaps serve as an incentive to farmers and growers to keep all pesticide active substances out of water, rather than being dealt with as separate priorities.
The next largest potential impact on gross margin occurs in grassland as a result of few fungicides actually being applied to grassland under business as usual. Improved disease control in grassland is estimated to be able to increase the relative feed value and yield of these pastures by £217 million.
Aside from the losses relating to the implementation of water quality and business as usual in grassland management, the next most significant losses in gross margin would occur as a result of changing approvals legislation. The loss of herbicides as a result of the changes would result in reduced control of broad-leaved weeds (£206 million) and black-grass (£187 million). The loss of gross margin due to broad-leaved weeds affects a large number of crops including cereals, pulses, carrots, leeks, strawberries. There are some options to mitigate against the loss of yield in terms of changing cultivations, increased mechanical weeding and hand weeding. However these options remain costly. There are also environmental concerns relating to increased cultivation, with an increased risk of soil erosion, and possible impacts on the soil quality, especially if minimum tillage systems have to revert to ploughing in order to control certain weed species. Additional cultivations and passes with mechanical weeders will also increase the amount of fossil fuels (and therefore greenhouse gas emissions) that are associated with the production of these crops. Black-grass is predominantly a weed of winter arable rotations, it is found largely in the eastern half of England, favouring clay soils. The crops most severely affected by this weed are therefore the cereals and oilseeds.
Under business as usual there is currently less than optimal control of grass weeds (worth an estimated £161 million to the industry in lost yield potential) and broad-leaved weeds (worth and estimated £147 million in lost yield potential).
Fusarium ear diseases currently affect cereals and maize. These are relatively poorly controlled and affect a large area better control of these diseases has the potential to increase the gross margins of these crops by £108 million.
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Other key areas for research priorities research are downy mildew control in horticultural crops which will be affected by changing approvals legislation (£59 million), blight control in potatoes (£56 million) under business as usual and botrytis control in horticultural crops under business as usual.Impact on gross margin and production
Table 6. Research priorities in each sector based percentage reduction in gross margin and production (changing approvals legislation and business as usual (BAU)) Scenario Main source of loss Crops affected %
reduction in margin
% reduction in production
1 Approvals legislation
Downy mildew Onions 209% 46%
2 Approvals legislation
Annual meadow grass Onions 86% 12%
3 Approvals legislation
Annual meadow grass Leeks 63% 31%
4 Approvals legislation
BLW Leeks 51% 24%
5 Approvals legislation
Volunteer potatoes Vining peas 49% 35%
6 Approvals legislation
Downy mildew Lettuce (outdoor) 46% 30%
7 Approvals legislation
Other fungal leaf spots (inc anthracnose)
Lupins 38%
8 Approvals legislation
BLW Carrots 33% 17%
9 BAU Downy Mildew Onions 28% 8%10 Approvals
legislationBlack-grass Winter barley 28% 9%
11 Approvals legislation
Volunteer potatoes Leeks 26% 1%
12 Approvals legislation
Raspberry Beetle Raspberry 25% 20%
13 BAU Botrytis (hortic) Strawberry 24% 17%14 BAU Rusts (arable) Fodder beet 23% 6%15 Approvals
legislationBLW Pulses (peas &
beans)22% 30%
16 Approvals legislation
Blossom Weevil Strawberry 21% 15%
17 Approvals legislation
Annual meadow grass Carrots 20% 10%
18 Approvals legislation
BLW Lettuce (outdoor) 19% 9%
19 BAU Blight Processing potatoes
19% 7%
20 Approvals legislation
Volunteer potatoes Carrots 19% 10%
21 BAU Blight Seed potatoes 18% 7%22 BAU Blight Potatoes 18% 7%23 BAU Powdery mildew Strawberry 18% 13%24 Approvals
legislationBlack-grass Wheat 17% 6%
25 BAU Cabbage root fly Brassicas 17% 7%26 Approvals
legislationStrawberry runner control
Strawberry 17%
27 Approvals legislation
BLW Strawberry 17% 5%
28 Approvals legislation
Weevils (including vine)
Raspberry 16% 9%
29 BAU Downy Mildew Lettuce (outdoor) 16% 10%30 BAU White blister Brassicas 15% 6%31 Approvals
legislationPowdery mildew Raspberry 15% 13%
32 BAU Downy Mildew Vining peas 13% 9%33 BAU Ring spot Brassicas 11% 4%
SID 5 (Rev. 05/09) Page 20 of 24
Scenario Main source of loss Crops affected % reduction in margin
% reduction in production
34 BAU Rusts Leeks 11% 6%35 BAU Fusarium Wheat 11% 0%36 BAU Sclerotinia Carrots 10% 6%
Under the changing approvals legislation the reduction in yield and increased costs of production associated with downy mildew on onions would make production of onions in the UK unviable at current prices unless alternative control measures can be identified. In outdoor lettuce reductions in yields could result in the gross margin decreasing by 46%.
Losses of herbicides to changing approvals legislation, for controlling annual meadow grass would result in the production of onions and leeks in the UK becoming unviable at current prices with over a 60% reduction in margin expected as a result of reduced yields and increased cost of weed control.
Broad-leaved weed control in leeks and carrots would be affected by the loss of active substances to changing approvals legislation. The reductions in yield and increased cost of control could result in reductions in the gross margin of 51% in leeks and 33% in carrots.
Under changing approvals legislation there are concerns about the ability to control volunteer potatoes in following crops. In vining peas and leeks the failure to control volunteer potatoes, or associated extra cost of control, could result in gross margins reducing by 49% and 26% respectively.
Possible losses if water quality is not protectedTable 7. Priorities in each sector based percentage reduction in gross margin and production (Water quality)
Main source of loss Crops affected % Reduction in margin% reduction in production
Grass weeds Blackcurrant 183% 39%BLW Blackcurrant 114% 33%BLW Lettuce (outdoor) 81% 12%Black-grass Winter Barley 61% 21%Black-grass Oilseed Rape 43% 15%Black-grass Wheat 40% 14%Blossom weevil Strawberry 31% 15%BLW Pulses (peas & beans) 29% 30%BLW Apples, pears & plums 28% 5%BLW Strawberry 24% 10%Rye-grass Winter Barley 23% 8%Slugs & snails Fresh potatoes 22% 7%Slugs & snails Processing potatoes 18% 7%BLW Clover 16% 30%Rye-grass Wheat 15% 5%BLW Raspberry 14% 10%Annual meadow grass Spring Barley 14% 3%
Losses of weed control (both broad-leaved and grass) due to potential losses of herbicide active substances to water quality legislation could result in blackcurrants, outdoor lettuce and winter barley suffering reductions in their gross margin in excess of 60%, wheat and oilseed rape would also see significant reductions in their gross margins of over 40%. These impacts highlight the importance of preventing herbicides from entering water.
If metaldehyde was lost due to water quality issues there would be a reduced ability to control slugs. The crop that would see the most significant impacts of this loss would be potatoes. If slugs damage the tubers they become unmarketable.
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CommentsThe greatest potential impacts on crop yields, and therefore the profitability of UK farming could result from severe restriction or the loss of pesticides due to failure to meet water quality legislation. The largest of these losses could arise from poor control of black-grass in cereals and arable rotations (£532 million) and broad-leaved weed control across all crops (£316 million). However the losses of active substances to water quality legislation are by no means definite, with other mitigation options likely to be attempted before the withdrawal of any actives occurs. This work highlights the importance of protecting water from these actives in order to maintain production.
Aside from the impacts of potential pesticide losses to water quality legislation the next most significant losses would arise from the potential loss of herbicides to changing approvals legislation with broad-leaves weeds potentially costing £206 million across all industries and black-grass £187 million predominantly to the arable industry. Under business as usual poor control of foliar diseases, such as crown rust, in the large areas of grassland present in the UK could be costing £147 million in reduced feed value. Ear diseases such as fusarium in cereals and maize are currently costing these industries £108 million on lost yield potential and reduced grain value. Loss of active substances to changing approvals legislation could result in increased yield losses from downy mildew in horticultural crops (£53 million).
In terms of viability of the industry the reduced ability to control weeds as a result of potential herbicide losses to water quality legislation could result in such large increases in costs / or reductions in yield that the production of a specific crop may no longer be viable. Crops affected in this way are blackcurrants, outdoor lettuce, winter barley, oilseed rape, wheat (with gross margins for all of these crops potentially falling by 40% or more), with clover and pulses likely to see over a 30% reduction in production.
Poor control of weeds as a result of loss of pesticides to the changing approvals legislation could reduce gross margins of onions, leeks and vining peas 40%. Loss of fungicides to changing approvals legislation could reduce control of downy mildew in outdoor lettuce and onions reducing gross margin by over 50%.
Recommendations and possible indicatorsFailure to protect water quality has the potential to cause the most significant impact. Measures and messages need to be adopted to minimise this risk. This is not product specific and requires a portfolio based approach. There is a need for the Availability Action Plan to closely interact with the Water Action Plan group to devise measures for increasing the protection of water which also ensure availability of pesticides, especially herbicides. Possible indicators would include development of new approaches to use, such as portfolio based and catchment based assessments of risk. Ultimately the water quality indicators would be a measure of action and success in this area. More specifically it would be possible to list a number of key actives and to measure the success in retaining these for use, and this could provide an interim measure of success and indicator. The pesticides that are currently causing concerns in ground water and surface water in England and Wales are listed in Table 811.
Table 8. Key active substances being detected in surface and ground waterFungicides Herbicides Insecticides Molluscicidescaptan MCPA cypermethrin Metaldehydeiprodione chlorotoluron chlorpyrifos carbendazim mecoprop
2, 4-DasulampropyzamideglyphosatecarbetamidebentazonelinuronmetazachlorclopyralidMCPBfluroxypyr
The 36 scenarios in Table 3 would provide a greater focus for the major costs to industry of lack of available control options. These could provide a focus for research and knowledge transfer. The success of the Availability Action Plan could be measured in relation to how many of these 36 ‘gaps’ were being filled. This could be considered as a possible indicator for this group. A small number of additional ‘gaps’ could be identified to cover other sectors, such as from amenity.
11 As advised by the Environment Agency
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References to published material9. This section should be used to record links (hypertext links where possible) or references to other
published material generated by, or relating to this project.
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