Frische et al. Environ Sci Eur (2018) 30:8 https://doi.org/10.1186/s12302-018-0136-2

DISCUSSION Open Access 5‑Point programme for sustainable plant protection Tobias Frische* , Sina Egerer, Stefen Matezki, Christina Pickl and Jörn Wogram

Abstract This position paper intends to stimulate a profound rethinking of contemporary agricultural practice. We criticise the current intensity of chemical plant protection in Germany as ecologically unsustainable and thus threatening the achievement of key targets of environmental protection and nature conservation policies. In the frst part of the paper, we provide background information on the use of plant protection products (PPP) in German agriculture, the role of agricultural policy, European pesticide legislation, the principles of and framework for environmental risk assessment and risk management of PPP, as well as environmental efects of PPP. The second part is presented against the backdrop of the European “Sustainable Use Directive” (2009/128/EC). This directive requires that “Member States shall adopt National Action Plans to set up their quantitative objectives, targets, measures, and timetables to reduce risks and impacts of pesticide use on human health and the environment and to encourage the development and introduction of integrated pest management and of alternative approaches or techniques to reduce dependency on the use of pesticides.” Refecting on the corresponding debate in Germany, we suggest the following fve key prin‑ ciples for a sustainable use of PPP and provide recommendations for their implementation: (1) minimising use; (2) identifying, quantifying, and communicating risks; (3) optimising risk management; (4) compensating for unavoidable efects; (5) internalising external costs. Keywords: Pesticides, Plant protection products (PPP), “Sustainable Use Directive” (2009/128/EC), Risk assessment, Risk management

Background (16.7 million hectares) is used for agriculture, and much System dependence on chemical plant protection of the German landscape has been shaped by crop pro- Chemical plant protection in conventional crop production duction on some 285,000 farms [3]. Most farms (94%) “Farming, forestry and agricultural business are among operate the conventional crop production, which is char- (…) the key sectors of the German economy…” [1]. Tis is acterised in particular by the use of mineral fertiliser and true despite the fact that agriculture comprises only 0.9% chemical plant protection products (PPPs). Mineral ferti- to Germany’s gross domestic product (GDP) [2], since it liser provides maximum nutrient supply to the crops and is the crops cultivated by farms that provide basis for our the PPPs are used to tackle harmful bacteria and fungi, existence. Cereals, fruit, and vegetables are among our harmful animal organisms, and undesirable weeds. It is most important foodstufs, food crops feed our livestock, the combination of mineral fertiliser, chemical plant pro- and for some years, we have grown increasing quantities tection, and modern high yield crop varieties that make of “energy crops” to produce biogas and electricity. Tis the current intensive crop production possible, with its is not possible without the ample use of natural resources tight crop rotation and monocultures. Tis in turn pro- (land, soil, and water). About half the area of Germany vides the high yields of conventionally produced plant products at consistently high marketable quality [4]. Since the “Green Revolution” in the mid-20th century, *Correspondence: [email protected] the conventional cultivation system has been continu- Section Plant Protection Products, German Environment Agency ally optimised, so that it now provides the basis for our (Umweltbundesamt, UBA), Woerlitzer Platz 1, 06844 Dessau‑Roßlau, Germany intensive agriculture and food production. Te intensive

© The Author(s) 2018. This article is distributed under the terms of the Creative Commons Attribution 4.0 International License (http://creativecommons.org/licenses/by/4.0/), which permits unrestricted use, distribution, and reproduction in any medium, provided you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons license, and indicate if changes were made. Frische et al. Environ Sci Eur (2018) 30:8 Page 2 of 17

use of chemical PPPs in conventional crop production is individual farmer with no choice other than the “neces- refected in the annual surveys of the Julius Kühn Insti- sary” use of PPPs. However, given the political infuence tute (JKI). Expressed as the so-called treatment index on the market—in particular with farm payments—this (i.e., number of PPPs used relative to the maximum per- line of argument is not entirely convincing. A diferent missible applied amounts and the cultivated area) in 2013 agricultural policy could well lead to a lower “necessary PPPs were applied an average of 4 times to wheat, 11 minimum”. However, implementing this would require times to potatoes, 17 times to grape vine, and 32 times to political conviction (see below) while taking care not to apple trees (Fig. 1). lose sight of the reality of the global markets for agricul- tural produce. There is no natural law which dictates a “necessary (Note: Te focus in the following is solely on PPPs. minimum” Relevant analyses and recommendations for mineral fer- Te current dominance of conventional farming sys- tiliser (in particular nitrogen) are provided in other pub- tems is not only the result of free market forces but also lications of the German Environment Agency (e.g., [8]). of developments in German and European agricultural policies of past decades, which aimed mainly at increas- Assessment and management of environmental risks ing efciency and yields [6]. European and national tax- Plant protection products: no efects without side efects funded subsidies for agriculture were a key factor in this Chemical PPPs are used because of their biological ef- context. Although now on the decline for several years, cacy in key areas: bactericides and fungicides are used agricultural subsidies still account for some 42% of the to combat plant diseases caused by bacteria and fungi; total EU budget [2]. In Germany, the agricultural sector insecticides kill insects such as aphids or caterpillars received a total of EUR 6.8 billion in 2012, and the aver- that damage plants; and herbicides are used to control age proportion of transfer payments in the income of “weeds”. To achieve these efects, the PPPs—which can German farmers was some 48% [2]. Te European and consist of mixtures of up to 20 diferent chemicals— national support for conventional cultivation systems typically contain one or more chemically synthesised not only ofered advantages for farmers, but also for con- active substance. However, their efects are not usually sumers. Te reliable supply of high-quality fruit and veg- very specifc, i.e., not restricted to the target organisms etables and food products year-round at more and more in question. Te description of the potential side efects favourable prices is something that consumers have come is, therefore, an important element of the testing and to expect. Ever higher consumer expectations (“unblem- approval procedure for PPPs. Te direct efects of a PPP ished and low-priced”) are also in part to blame for the are described mainly on the basis of laboratory experi- current degree of dependence of the conventional crop ments in which indicator organisms such as algae, water production on chemical plant protection. feas, fsh, earthworms, bees, birds, and rats are exposed Te notion of a “necessary minimum” (German: “not- to the active substances or the PPP. Tese studies are wendiges Maß”), which “denotes the amount of plant used to determine the acute and/or chronic toxicity of protection products that is necessary to secure the culti- PPPs for the so-called “non-target organisms”. Gener- vation of crops, particularly from the aspect of economic ally speaking, all PPPs can be expected to have more or viability” [7], has come to legitimise this dependence. less severe side efects—if the non-target organisms are Tis term, with its ideological undertones, suggests that exposed to relevant quantities. In other words: No efect the constraints of the market economy clearly leave the (plant protection) without side efects (on organisms in the environment). Te side efect profle of the PPP usu- ally corresponds to the intended pesticidal efect: her- bicides are particularly toxic for algae and non-target plants that are phylogenetic and biochemical relatives of “weeds”; similarly, insecticides are often just as toxic for benefcial insect species (honey bees, wild bees, butter- fies, etc.) and other arthropods (spiders, woodlice, etc.) as they are for pest insects. With regard to bactericides and fungicides, the profle of the side efects is usually less clear. At the level of natural biocoenoses and ecosystems, it is known that direct PPP efects on certain organisms Fig. 1 Mean treatment with PPPs of important crops in Germany in can lead in turn to indirect PPP efects on other organ- 2013 (our presentation, data from the PAPA Web site of JKI: http:// isms that are not directly afected by the toxicity (see fur- papa.jki.bund.de/index.php?menuid 1, see also [5]) = ther below). Frische et al. Environ Sci Eur (2018) 30:8 Page 3 of 17

Concerning risks and side efects ask the German is the case frst for long-term risks, which in view of the Environment Agency complexity of the organisms and ecosystems can only In view of their potential side efects and because they are be estimated to a limited extent and with considerable introduced directly into the environment in considerable uncertainties through the available test and assessment quantities and over large areas, the application of a PPP is methods. Gaps in knowledge will always exist despite any only allowed in the European Union after it has success- further scientifc progress that can be taken into account fully passed through a harmonised testing and approval in the ofcial assessment procedure. Te very complexity procedure applicable in all Member States since 2012. In of the issue precludes certain knowledge and the ability Germany, the legal framework is established by the Plant to make predictions. Te resulting residual risks of chem- Protection Act [9] in combination with the European ical plant protection are often overlooked in the public Regulation EC No. 1107/2009 concerning the placing of debate [11]. plant protection products on the market [10]. It requires an examination of the environmental impacts of each The total dose is what counts proposed application of a PPP to combat a defned harm- Another problem of the current authorisation proce- ful organism in a defned crop. Te objective is not abso- dure is that consideration of “the big picture” is omitted lute protection or zero risk, but only that there should be by examining the individual PPP application in isolation. no unacceptable efects on the environment. However, As already seen with the treatment index, most crops are the risk assessment does not explicitly include weigh up treated a number of times in the course of the growing the pros and cons of crop protection versus protection of season with the same and/or various PPPs. Te sum of the environment. Instead, it is carried out on the basis of the applications and the total amount applied on a crop legally binding decision criteria (at least for the standard is, therefore, decisive for the overall risk or the environ- assessment, i.e., lower tier) defned in the PPP Regulation mental impacts in the agricultural landscape and not the [10] and in corresponding technical guidance documents. individual PPP. A rough calculation demonstrates the In Germany, the German Environment Agency (UBA) general intensity of the use of PPPs in Germany: in 2014, is responsible for the environmental risk assessment of 106,155 tonnes PPP containing 34,515 tonnes of active PPPs—including the impact on groundwater. Te UBA substances (without inert gases) were sold in Germany commits considerable human resources to fulflling this (BVL, 2015)—this amount has remained largely con- task with independent expertise and in accordance with stant over the past 10 years or has even increased slightly the state of knowledge in science and technology. To (Fig. 2). Ignoring the diferences in treatment intensity ensure that the environmental impacts are acceptable between crops, and assuming some 12.1 million hectares the German Federal Ofce of Consumer Protection and of arable land under cultivation, this gives an average Food Safety (BVL), which is the competent national body application of 8.8 kg PPPs and 2.8 kg active substances responsible for the approval procedure, draws on the risk per hectare. assessment provided by UBA to formulate legally binding conditions of use and risk mitigation measures that are When “theoretical” risks become real environmental impacts displayed on the PPP packaging and with which farmers Te remaining assessment uncertainties and the over- have to comply. In the case of spraying this might involve all treatment intensity are more than mere “theoretical” technical regulations for the application (e.g., using drift- reducing technology) or requirements for maintaining a certain distance from surface water bodies. Te list of PPPs currently authorised in Germany including the con- ditions of use and required risk mitigation measures can be accessed on the online BVL database (https://apps2.bvl. bund.de/psm/jsp/index.jsp). Monitoring compliance with the risk mitigation measures in Germany is the responsi- bility of the individual Federal States (Bundesländer).

Residual risks, overall risks, and environmental impacts Difcult predictions and residual risks Even though UBA deemed the environmental impacts of each individual PPP authorised in Germany to be acceptable on the basis of current knowledge, residual Fig. 2 Sales in Germany of PPP active substances (without inert risks remain that cannot be conclusively assessed. Tis gases) in tonnes (our presentation, data taken from [12] and [13]) Frische et al. Environ Sci Eur (2018) 30:8 Page 4 of 17

risks: they have had and continue to have considerable ing erosion on slopes, protecting against run-of negative impacts on nature and the environment. In ret- from heavy soils, avoiding soil compaction, and rospect, the development of chemical plant protection improved soil water household), but in most cases, can be seen as an example of “pathological learning” [14]. economic considerations are the main motivation It is now half a century, since the classic “Silent Spring” for this trend. Farmers can save time and money if by Rachel Carson raised public awareness about the they control weeds using the relatively cost-efective environmental damage caused by the frst PPP genera- glyphosate products. However, the massive use of tion [15]. Te old active substances (DDT, organophos- glyphosate and other herbicides leads to a progres- phates, etc.) have largely been replaced by more modern sive loss of abundance and diversity in the farmland and much better tested active substances. However, three fora, with indirect efects on sensitive fauna. In examples show the continuing relevance of PPP-environ- the case of ground-nesting bird species such as the mental impacts: partridge, these food web efects are scientifcally proven [21]. Te elimination of feld weeds by herbi- •• Neonicotinoids Tis group of highly efective insec- cides and of arable farmland insects by insecticides ticides have been widely used in the past 20 years depletes food supplies such that the birds are not for seed treatment (seed coatings). Tese “systemic” able to successfully reproduce in intensively farmed active substances are taken up by the seedling, ofer- agricultural landscapes. As a result, populations are ing protection against sucking insects and some declining (Fig. 3). Chemical plant protection is one chewing insects. In 2008, the spread of abrasion dust of the causes contributing to the disturbing continu- from coated seeds spread by pneumatic seed drilling ous decline in biodiversity in the German agricultural equipment led to a massive poisoning of bee colonies landscape [22]. in south-western Germany [16]. Te importance of •• Tolyfuanid Te authorisation of PPPs containing this the airborne distribution of abrasion dust had been fungicidal active substance was withdrawn in 2007. underestimated in the EU approval for the active Te reason for this was the “delayed” discovery that substances and in PPP testing. Te European Food a metabolite (N,N-dimethylsulfamide) which can fnd Safety Authority (EFSA) reassessed the risk of the its way into groundwater, though previously classifed main neonicotinoids for honey bees and wild pollina- as toxicologically harmless, can be transformed into tors (e.g., bumble bees) in the light of the new scien- a genotoxic and carcinogenic substance (N-nitros- tifc fndings and found serious gaps in the data—in odimethylamine) during the preparation of drinking particular concerning long-term toxicity. For many water by ozonisation. Te use of the active substance applications, EFSA concluded that an unacceptable was prohibited as a precautionary measure for the risk was indicated or could not be excluded. As a protection of drinking water [24]. However, residues consequence, the EU Commission banned these crit- of other active substances such as atrazine, which ical applications in 2013 and called on the producers has long been banned in Germany, are still found in to provide the missing data [17]. It remains to be seen groundwater and other currently authorised active what decisions will be reached by the EFSA, the EU substances (e.g., bentazon, isoproturon, and chlori- Commission and the national authorities on the basis dazon), and their metabolites are frequently found in of the data that is provided and in consideration of groundwater at concentrations above the limit levels the massive criticism of this group of substances by [25]. Tere have recently been intensive debates in scientists [18] and environmental and nature conser- Germany about the pollution of groundwater and vation associations (e.g., [19]). the problems faced by water utilities endeavouring to •• Glyphosate Tis is the most important herbicide in maintain the high quality of German drinking water. Germany and worldwide, and in contrast to neonico- Te position of the water utilities is “that the active tinoids, it is currently thought to be relatively harm- substances in plant protection products and their less for non-target organisms in the environment. metabolites should be kept away from the water cycle Te environmental problems arise from the blanket at the frst opportunity for the sake of precaution” application of this broadband herbicide on a mas- [26]. sive scale. Te amount sold and used in Germany has risen sharply over the past 15 years and some Chemical plant protection and sustainability—a politically 5000 tonnes are now used by German farmers every controversial topic year [20]. Tis is due in particular to an increase in “Sustainable Use Directive” and the national action plan no-till cultivation. Tere are many environmental In “A Tematic Strategy on the Sustainable Use of Pes- arguments in favour of less ploughing (e.g., reduc- ticides” in 2006, the EU Commission had already noted Frische et al. Environ Sci Eur (2018) 30:8 Page 5 of 17

Fig. 3 Changes in the populations of indicator bird species in Germany’s agricultural landscape (Figure copied from [23]) that, in addition to the authorisation procedure, the use targets and measures it contains are not legally binding. phase was decisive for the risks and impacts of PPPs [27]. Te NAP is closer in character to a declaration of intent As a consequence, EU Directive 2009/128/EC established and the success of its implementation depends on the a framework for Community action to achieve the sus- degree of motivation of the actors involved (in particu- tainable use of pesticides, introducing “sustainability” as lar the Federal Government, Federal States, and agricul- a political goal. Te Directive obliges the Member States tural associations) as well as on the funding available for to draw up national action plans, “aimed at setting quan- implementation. titative objectives, targets, measures, timetables, and indicators to reduce risks and impacts of pesticide use Sustainability in plant protection—controversy about the on human health and the environment and at encourag- need for action ing the development and introduction of integrated pest Te German NAP was developed over a number of management and of alternative approaches or techniques years in a multi-stakeholder process organised under to reduce dependence on the use of pesticides […]” [28]. the responsibility of the then Federal Ministry for Food, However, neither the Tematic Strategy nor the Directive Agriculture, and Consumer Protection (BMELV, now proposed a precise quantitative reduction target for the Federal Ministry for Food and Agriculture, BMEL). Te application of PPPs. Te European Commission, never- environmental protection and nature conservation asso- theless, expected a signifcant reduction in PPP use as a ciations, the professional beekeepers, and the water man- result of the Tematic Strategy measures [27]. agement sector were all critical of the draft version of the Some of the Directive requirements were transposed NAP. Te associations voiced their criticism through ter- in Germany as “hard” regulations in the Plant Protec- mination of their further participation, stating in a press tion Act (e.g., regarding certifcates of competence for release dated 24.11.2011: “Te Agriculture Ministry ori- sellers and professional users, or the aerial application ents itself in the Action Plan towards the interests of the of pesticides). In these cases, violations and infringe- agricultural industry and seems deaf to suggestions to ments of key provisions of the law can lead to prosecu- seriously reduce pesticide pollution. Tey will not receive tion and the imposition of fnes. However, most of the support from the Associations for this.” [29]. important requirements relating to nature conservation Under the Plant Protection Act, UBA is involved in and environmental protection in the Directive were not drawing up and implementing the German NAP in transposed in the Plant Protection Act. However, they accordance with its responsibilities for the environ- were included in the German National Action Plan on mental risk assessment of PPP. In this context, UBA Sustainable Use of Plant Protection Products (NAP) provided expert advice for the Federal Ministry for the adopted by the German Federal Government on 10 April Environment, Nature Conservation, and Nuclear Safety 2013 [7]. Te National Action Plan represents a com- (BMU; meanwhile: Federal Ministry for the Environ- paratively soft regulatory instrument and most of the ment, Nature Conservation, Building and Nuclear Safety, Frische et al. Environ Sci Eur (2018) 30:8 Page 6 of 17

BMUB). Te common goal of BMU and UBA was to real- the “Code of good practice for plant protection” (Grund- ise an action plan that included targets and measures for sätze für die Durchführung der guten fachlichen Praxis environmental protection and nature conservation that im Pfanzenschutz) [31], since the Plant Protection Act were specifc, binding, and ambitious. Tis was only par- requires compliance with this code in every PPP use. tially successful, which is why UBA believes that there is a However, three preconditions must be met for such a clear need for improvements with regard to environmen- requirement to be fully efective: tal protection and nature conservation when the action plan is revised in the upcoming years (2016–2018). Tis i. If they are to use PPPs sparingly, farmers need bet- view is not shared by the conventional agricultural sec- ter training and efective assistance from independ- tor where the general opinion is that plant protection ent advisors about practical plant protection. In Ger- in Germany is already sustainable. According to an EU many, both tasks are now the responsibility of the Commission analysis, this attitude is widespread among plant protection services at the federal state level, but the EU Member States: “Te majority of NAPs appear to these are frequently understafed [32]. As a result, adopt the default position that the current PPP use pat- advice on plant protection is predominantly given tern in their M(ember) S(tate) is sustainable.” [30]. Tis by consultants acting on behalf of the PPP producers is confusing, because the Member States had in principle and their primary goal is certainly not to advice on acknowledged the need for political action on the sus- how to use PPPs sparingly. Terefore, widely available tainable use of pesticides yet have so far seemed unwill- independent consultancy should be provided with ing to follow through with any action. the clear goal of “minimising PPP use”. ii. An efective and independent monitoring system is 5‑Point programme for sustainable plant required. It must be possible to determine whether protection an individual PPP user is, indeed, working to mini- UBA is of the opinion that the current intensity of the mise the amounts applied, and checks must be car- chemical plant protection in Germany is ecologically ried out frequently enough to ensure efectiveness. unsustainable and threatens the achievement of key tar- Te legal obligation of farmers to document their use gets of environmental protection and nature conserva- of pesticides (in application logs) provides a suitable tion policies. Plant protection that merits the attribute basis for traceability. Te responsibility for check- “sustainable” must be much more ambitious, specifc, ing compliance with the minimisation requirement and transparent than is the case with the current Ger- could again lay with the plant protection services at man NAP. Reforms are also necessary with regard to the the federal state level. Teir remit would be to defne authorisation of plant protection products. To promote criteria for good farming practice for plant protection truly “sustainable development” in plant protection, UBA in accordance with the minimisation requirement, recommends an integrated approach for all relevant pol- taking into account the regional conditions and “pest icy areas (plant protection, environment, nature conser- pressure”, and to check compliance. Tis calls for vation, and agriculture) based on the following fve basic random or targeted inspections of the application principles: records. iii. Obvious breaches of the minimisation requirement Point 1: Minimising use must be answered with appreciable sanctions. One Anchoring minimisation in German plant protection option would be the reduction or withdrawal of legislation Common Agricultural Policy (CAP) direct payments. From the perspective of nature conservation and envi- ronmental protection, the frequency of use of chemical Integrated plant protection—back to the roots PPPs and the amounts applied must be minimised. How- For conventional cultivation, “minimising use” means ever, the farming sector is facing stif competition, ration- adopting an integrated approach to plant protection alisation pressure, and favourable prices for PPPs, with for which the basic principle is: “Chemicals are the the costs of undesirable PPP impacts born by the public. last resort!” (Fig. 4). Integrated Plant Protection (often With no efective incentives for farmers, it would appear referred to as Integrated Pest Management, IPM) grants the correct approach to introduce a legally anchored priority to preventative measures (choice of varieties, minimisation requirement. Tis would also start the crop rotation, cultivation methods) and biological meas- urgently needed discussion among experts and policy ures, in combination with the strict adherence to the eco- makers about what actually constitutes a “necessary min- nomic threshold principle, before a chemical PPP is used imum” (“notwendiges Maß”) for the use of PPPs from a [28, 33]. societal perspective. Te requirement can be anchored in Frische et al. Environ Sci Eur (2018) 30:8 Page 7 of 17

Fig. 4 Basic principles of Integrated Plant Protection (from a talk on “Nutzen und Risiken von Pestiziden” by Dr. Eva Reinhard, BLW, Bern, 10.11.2014 at Oekotoxzentrum Dübendorf, Switzerland)

However, this “pure doctrine” has obviously slipped under the EC regulation on organic production and label- into the background, as can be seen from the increasing ling of organic products [35], nor under the guidelines of preventative use of pesticides (e.g., in the form of seed the organic farming associations. Much smaller amounts coating) and in uses not primarily relating to plant pro- of PPPs are used developed on the basis of natural sub- tection (e.g., herbicides to accelerate ripening and to kill stances (e.g., sulphur, copper, and pyrethrum), although of foliage before harvesting). For “real” Integrated Plant this does not necessarily mean that they are not harmful Protection, it is, therefore, essential to formulate specifc to the environment. Organic farming, therefore, already minimisation requirements in the “Code of good practice meets the requirements of the EU “Sustainable Use for plant protection” and combine these with a consul- Directive” 2009/128/EC for a cultivation system using tancy and inspection system [34]. It is crucial that a uni- smaller amounts of pesticides [28]. Another advantage versally applicable minimisation requirement does not is that an efective certifcation and monitoring system justify any use of pesticides—for example on grounds of is already in place (EU organic logo and Germany’s eco- fnancial constraints and competition—which is not in label as well as various association seals). accordance with Integrated Plant Protection (i.e., “Te Increasing numbers of environmentally aware and frst to reduce spraying is the loser.”). health-conscious consumers approve of the goals of Te implementation of the minimisation requirement organic farming and place their trust in organic products, in Integrated Plant Protection can be reinforced by set- as can be seen by the steadily rising demand in recent ting up an agricultural equalisation fund—with the ini- years. Meanwhile, the demand for organically produced tial state support if applicable. Te idea is to cushion the food in Germany exceeds the supply, thus requiring efects of loss of earnings or yield risks for the individual considerable amounts to be imported [36]. Te fact that farmers who adopt plant protection methods aimed at Germany’s organic farming lags behind demand is attrib- minimising the use of pesticides. Relevant experience is utable to the current economic and agro-political climate already available from Italy [33]. In addition, increased which apparently makes the conventional crop produc- support must be provided for research and development tion more proftable. work on Integrated Plant Protection—in particular non- To promote organic farming as an efective way to chemical methods. reduce the environmental risks of and dependence on chemical PPPs, the framework conditions for those con- Supporting the expansion of organic farming ventional farms that are willing to convert to organic Te minimisation requirement must of course apply farming must be improved. In particular, further train- equally for plant protection in organic farming. Organic ing and assistance with conversion should be ofered; farming has already adopted these principles inasmuch improved fnancial support for organic farming is also as the use of chemical-synthetic PPPs is not permitted needed. Te Sustainability Strategy of the German Frische et al. Environ Sci Eur (2018) 30:8 Page 8 of 17

Federal Government of 2000 set a target of 20% organic has taken a big step towards implementing the measures farmland by 2010, but it is currently still only slightly under the EU “Sustainable Use Directive” 2009/128/EC above 6% [3]. It is urgently necessary to review whether to minimise or ban the use of pesticides in places such as the increased incentives ofered in recent times in some public parks and gardens, playing felds and sports facili- German Federal States (agro-environmental measures ties, schools and children’s playgrounds, and in the vicin- fnanced through the CAP “second pillar”) for convert- ity of healthcare facilities [28]. ing to or staying with organic farming are sufcient to reach the target in the medium term. In 2014, the BMEL Defning clear policy targets for the reduction of pesticide use initiated the formulation of a “Strategy For Te Future In view of the prospective revision of Germany’s NAP, Of Organic Farming” [37] to provide more impetus for UBA recommends a debate at policy-making level about the expansion of organic farming in Germany. Together a specifc quantitative target for the reduction of the use with representatives of the organic food sector and par- of chemical PPPs. Germany would thus be following the ticipants from the Federal States, science and various examples of Denmark, which targeted a 40% reduction associations, the BMEL proposed strategies and recom- in PPP use from 2011 to 2015, and France, which has set mendations for key felds which aim at achieving the specifc reduction targets for 53 active substances [30]. A target of “20% organic farming” anchored in the Sustain- suitable starting point for the discussion about a pesticide ability Strategy of the German Federal Government (see use reduction target for conventional cultivation could be also: http://www.ti.bund.de/de/thema/oekologischer- the experience gained in the “Demonstration farms for landbau/zukunftsstrategie-oekologischer-landbau/). Te Integrated Plant Protection” (http://demo-ips.jki.bund. UBA welcomes this and calls for the vigorous expansion de/). Even under the current economic and agro-political of organic farming in Germany, not least as an important conditions, they used up to 20% less PPPs than in com- element for sustainable plant protection. Tis endeavour parable standard operating farms in the region as a result will also require the strengthening of research and devel- of expert counselling and adherence to the “threshold of opment for plant protection in organic farming. damage” principle [43].

Doing without chemicals in private gardens and public green Point 2: Identifying, quantifying, and communicating risks spaces Eliminating “blind spots” in the environmental risk Te call to minimise the use of chemical PPPs also applies assessment of PPPs for public green spaces, private gardens and allotments. Being basically committed to the state-of-the-science, In contrast to farming, the economic benefts in this case the authorisation process for PPPs demands that “blind are usually negligible and, accordingly, priority is placed spots” and weaknesses in the environmental risk assess- on aesthetic considerations (“weed-free lawns”). Giving ment be eliminated. For example, the assessment cur- preference to non-chemical alternatives in these cases rently fails to pay sufcient attention to the impacts on is, therefore, both practicable and reasonable. Informa- amphibians, reptiles, wild pollinators, soil arthropods, tion is already available on how to minimise the use of aquatic and soil fungi, or the indirect efects on biodiver- chemical pesticides in gardens and allotments (e.g., [38]), sity (for the latter, see also below). Tere is also consider- and further advice was quite recently released by UBA able uncertainty about how representative the results of (http://www.umweltbundesamt.de/pflanzenschutz-im- model calculations are of the PPP residues expected in garten-startseite). In addition to the voluntary avoidance the soil, groundwater, and surface water bodies. Improve- of chemical plant protection, UBA also advocates a com- ment of the environmental risk assessment requires the plete ban on herbicides in gardens and allotments. Te continuous further development of the principles on background for this is the repeated occurrence of inputs which it is based as well as implementation of the scien- of herbicides into public sewers and wastewater treat- tifc developments in appropriate testing requirements ment systems, which in many cases is likely due to inap- and assessment concepts. Responsibility for this develop- propriate application by private users, for example on ment in Germany lies with UBA, in parallel to the pro- paved areas [39, 40]. cessing of authorisation applications. Research projects Regarding PPP use in public spaces, many German commissioned by UBA for this purpose, the results of towns and local communities in the initiative “Pesticide which are frequently introduced into the further devel- Free Communities” (Pestizidfreie Kommunen) have com- opment of the testing and assessment procedures at the mitted themselves to avoiding the use of chemical PPPs European level. Tis revision process is initiated primar- either completely or to the greatest extent possible [41]. ily by UBA for Germany and by EFSA with the goal of In France, a nationwide ban on chemical PPPs in public meeting the requirement to implement the state-of-the- green spaces will come into efect from 2020 [42]. France art. Scientifc progress is thus one of the reasons for the Frische et al. Environ Sci Eur (2018) 30:8 Page 9 of 17

marked increase in the complexity of environmental risk Improving transparency and risk communication assessment for PPPs in recent decades. Further objections raised against this “refnement trend” in risk assessment concern the increasing loss of trans- Critically reviewing “refned” risk assessment for individual parency and greater susceptibility to the infuence of spe- PPPs cial interests. Considerable scientifc expertise is required A further driver of the growing complexity of environ- for PPP producers to be able to further refne the risk mental risk assessment for PPPs lies in the EU Regulation assessment and for the assessment authority bodies to on Plant Protection Products. In the event of a negative understand the measures involved. Quite frequently assessment result at a lower assessment tier based on applicants do commission renowned scientists to pre- standard data and conservative assumptions, the appli- pare a scientifc report for a refned assessment which is cant can use a so-called “refned assessment” to show then submitted to defend the authorisation of the PPP or that no unacceptable environmental impacts of a PPP to argue that fewer management measures are required. are to be expected under realistic application conditions. Even if the assessment authority is able to respond with Te investment in such a refnement of the risk assess- equal expertise (which becomes more difcult the smaller ment, e.g., in the form of mathematical models or more the agency of an EU Member State is), this development complex experimental studies (aquatic mesocosms, and is problematic. In general, the more important the expert feld studies) is usually worthwhile for the applicant com- judgements become, the less transparent the decisions pany. Tis is either because it is the only way to obtain become for the public. Te decision-making process an authorisation or because it makes it possible to avoid becomes more susceptible to the infuence of parties with stricter requirements for risk management (e.g., concern- special interests due to the relatively small numbers of ing margins to adjoining surface water bodies). Refned actors involved. Te independence of “super experts” and risk assessment for environmentally critical but heat- the democratic legitimation of their decisions, with their edly justifed PPPs in particular is becoming increasingly far-reaching implications, is a sensitive topic in modern complex. knowledge societies [47, 48]. An indicator of the rel- Tis trend is questionable from a scientifc point of evance and political sensitivity of this development has view, because the more realistic risk assessment is still been the public criticism expressed regularly in recent carried out in isolation for the individual PPP for which years about the composition of EFSA’s panels of experts the application has been made. It ignores the fact that the [49]. Many experts with earlier or existing connections exposure regime for the given crop will usually involve to the chemical industry are believed to have conficts the multiple applications of various PPPs over the grow- of interests. To maintain or increase the public’s trust in ing season. Increasingly, doubts are being expressed the authorisation procedure for PPPs, the understandable about the “refned” acceptability of the environmental call for the independence, transparency, and clarity of the impacts and whether the management requirements for decision-making processes must be answered. As a step an individual PPP are sufcient when the “total” exposure in this direction, the German Federal Ofce of Consumer regime during a growing season is considered [44, 45]. Protection and Food Safety (BVL) has been making pub- Te relevance of common forms and intensities of PPP lic its authorisation decisions, including concise summa- application in tank mixtures and spraying with a series ries of the evaluations, since 2009 (see http://www.bvl. of PPPs compared to the evaluation and management of bund.de). In the future, a signifcant step towards more the environmental risks for individual PPPs has been and transparency would be to make all the relevant data is being addressed in research projects commissioned by about the environmental behaviour and ecotoxicology of UBA (e.g., [46]). the active substance or PPP, including the results of con- Generally speaking, UBA sees the need to discuss the fdential studies commissioned by the applicant, available extent to which the trend towards increasingly refned in an open database. Tis is being considered both by risk assessment for individual PPPs (i) is appropriate UBA and EFSA. or is as a rule disadvantageous for the environment, (ii) causes unnecessary societal costs, and (iii) places exces- Avoiding the complexity dilemma sive demands on the risk communication (see further As explained, the increasing complexity of the environ- below). For an initial exchange on these questions, a mental risk assessment of PPPs is to some extent an una- working meeting initiated by UBA was held in November voidable consequence of scientifc progress. However, 2015, attended by experts from the relevant assessment this does not apply for the complexity of the refned risk authorities of a number of European countries. assessments for individual PPP enforced by applicant companies. In such cases, the principle of “risk man- agement before risk refnement” ofers a suitable way Frische et al. Environ Sci Eur (2018) 30:8 Page 10 of 17

out of the looming complexity dilemma. For a PPP that be replaced by a PPP with a lower environmental impact. could already be authorised, all justifable options for Te methodology of comparative assessment of the envi- the management of the environmental risks should frst ronmental hazard or risks of PPPs is—both from a scien- be exploited before the authorities approve and accept tifc and regulatory viewpoint—challenging and has not highly complex refnements of the risk assessment whose been sufciently tested so far [53]. However, the general only aim is to create more favourable conditions for public and users rightly demand that in future the assess- application of the PPP (e.g., narrower margins to adjacent ment authorities should make increased use of their surface waters). expertise to provide information about the more envi- A further regulatory alternative is ofered by the “cut- ronmentally favourable alternatives. It remains to be seen of criteria” of the EU Regulation on Plant Protection how efective the instrument of comparative assessment Products [10], which provide for a ban on active sub- will prove in terms of making environmental impacts stances with particularly hazardous properties, the so- measurable. called PBT substances [persistent (P), bio-accumulative (B), and toxic (T)]. A further exclusion criterion is target- Describing the overall risks and impacts of PPPs ing endocrine disruptors. Te cut-of criteria represent a A further challenge is the description of the environmen- very progressive instrument in several pieces of Europe’s tal risks and environmental impacts that result from the chemicals legislation, which is oriented more towards the overall intensity of chemical plant protection in Ger- precautionary principle than other international regula- many. Tere is a need for scientifcally relevant indica- tions. Tese criteria have been introduced by policy-mak- tors that are understood by the public and can be used ers and require a paradigm shift in the decision-making for their information and for policy-making. Some envi- process. Te decision on an approval or ban should in ronmental indicators were used to review the progress future only be based on the undesirable substance prop- of the German NAP. Comparable to the risk assess- erties and not, as previously, on a quantitative risk assess- ment for individual PPPs, the SYNOPS indicator calcu- ment (i.e., the comparison of the expected environmental lates a generic risk index for plant protection intensity exposure concentrations with (eco)toxicological thresh- in Germany for selected non-target organisms, e.g., for old concentrations/doses for the harmful impacts on aquatic and soil organisms, and bees [54]. In addition to non-target organisms). Experts justify the hazard-based this “theoretical” SYNOPS risk, the German NAP also regulation by referring to the high level of uncertainty includes indicators for the actual environmental status in the risk assessment for the targeted hazardous prop- (e.g., pollution of surface water bodies by PPP residues, erties. Te cut-of criteria provide an impulse to develop development trends of bird species populations in the and use active substances and PPPs that have lower envi- agricultural landscape). Ideally, data from environmental ronmental impacts. However, a practical implementa- measurements and environmental monitoring allow con- tion is currently not possible, because the scientifc and clusions to be drawn about: (i) the plausibility of the risk technical details of the cut-of criteria have not yet been assessment in the approval procedure, (ii) the efcacy of developed and specifed in subordinate regulations. Te PPP-specifc environmental risk management, and (iii) delays in implementation have been due not least to the changes to the environmental status through the general massive interventions of the European PPP industry, use trend of PPPs. At present, there is no representative which categorically rejects hazard-based regulation and PPP-specifc monitoring in Germany for all potentially demands a return to risk assessment, even for undesir- afected environmental compartments, ecosystems, able substance properties [50]. Te UBA believes that the and organisms. Te German NAP only collates existing cut-of criteria are in principle well suited to improve the monitoring programmes, giving an incomplete overview protection of the environment against particularly haz- of the current environmental impacts of chemical plant ardous PPPs. Because of this conviction and in accord- protection. Te UBA sees a clear need for improvements ance with its responsibilities, UBA is also involved in the and has commissioned an on-going research project discussion about the specifcation and implementation within the framework of the German NAP to develop of of the cut-of criteria [51, 52]. One particular challenge a strategy for monitoring the pesticide loads of small sur- is that it is not always clear from an environmental point face water bodies in the agricultural landscape [55]. Te of view whether an alternative active substance really is small surface water bodies make up a large proportion better than the banned active substance it is meant to of the overall network of surface waters and are at great- replace. Te same task of comparative assessment applies est risk of pollution with PPPs due to their proximity to for PPP approval: Te EU regulation provides that a PPP the application areas. However, they are currently under- containing so-called substitution candidates (e.g., active represented in the monitoring scheme pursuant to the substances with two out of three PBT properties) should EU Water Framework Directive. Te UBA also initiated Frische et al. Environ Sci Eur (2018) 30:8 Page 11 of 17

a research project to test whether and how integrated few exceptions, for example treating the crown zone of monitoring could improve the description of the environ- forests or steep vineyard slopes [9, 56]. When applying mental impacts of chemical plant protection. Integrated PPPs on arable land and for special crops (fruits, vines, monitoring records both the fate and exposure of PPPs or and hops), it is usually necessary to use mobile spraying PPP residues in the environment as well as their impacts gear with drift-reducing nozzle technology. Introducing on organisms, ecosystems, and ecological processes. Tis the best available nozzle technologies is thus an efec- parallel registration is necessary to be able to identify the tive way to reduce environmental pollution by PPP resi- specifc contribution of the chemical plant protection to dues. Te German NAP formulates the same target but changes in the environmental status, in particular if the without specifying any measures to be adopted. Possible processes are infuenced by a number of diferent factors options include the introduction of an appropriate inno- (e.g., the changes in population of bird or amphibian spe- vation and subsidy programme or granting tax credits for cies in the agricultural landscape). the adoption of modern technology.

Point 3: Optimising risk management Efectively monitoring compliance with legal risk mitigation Limiting PPP applications in protected areas measures Te simplest and most efective way to avoid the risks Farmers who fail to comply with the legally binding and impacts of chemical PPPs is not to use them. UBA PPP-specifc risk mitigation measures for the protection believes that PPPs should not be applied on public green of the environment are subject to fnes. Key require- spaces, private gardens, and allotments, nor—wherever ments concern the maintenance of untreated margins possible—also in nature conservation and drinking water of felds adjacent to bodies of water and terrestrial habi- protection areas. Tis recommendation is in accordance tats (e.g., marginal biotopes and forest margins). As a with the EU Sustainable Use Directive, which stipulates rule, however, the yield and crop quality is lower for a minimisation of or ban on the use of PPPs for nature these untreated areas of farmland, resulting in fnancial conservation areas (protection areas for birds, FFH areas) losses as a consequence of compliance with result from and drinking water protection areas [28]. However, this observing the spacing requirements [57]. Just as road is not transposed into a national regulation in Germany; speed limits tend to be ignored if there are no regular rather the Plant Protection Act passes on the responsibil- speed checks, there is a risk here too that without regu- ity for introducing the appropriate measures to the Fed- lar checks and the prosecution of transgressions, these eral States (Article 22 of [9]). As in an information paper “inconvenient” regulations will lose their efectiveness on emergency approval for the use of PPPs in nature con- and the number of transgressions will increase. How- servation areas [56] which was published by UBA and the ever, the extent to which plant protection products are German Federal Agency for Nature Conservation (BfN), applied in accordance with the regulations in Germany is UBA also urges the Federal States to put in place a gen- unclear. Te results of the checks carried out by the Fed- eral ban on the use of PPPs in these areas. eral States are documented in annual reports on the plant protection monitoring programme (www.bvl.bund.de/ Minimising distribution in the environment with modern psmkontrollprogramm), but these do not provide a basis application technology for drawing conclusions. Te 2013 report shows that If the use of chemical PPPs is unavoidable, they should relatively few checks were carried out. Compliance with be applied making the best possible use of the avail- the spacing requirements for the protection of surface able technology and economically justifable options for water bodies was only checked for 423 application areas risk management. Te goal is to stop PPP residues—to of 421 agricultural holdings in Germany—less than 1% of the extent possible—from entering into or spreading to all German farms. Te main reason for this is the under- non-target areas, natural assets (e.g., groundwater and stafng of the Federal States plant protection services. surface waters) and habitats adjacent to the application However, the results from 2013 also point to non-compli- areas. Although this will never be completely feasible, ance with legal requirements: Transgressions were iden- further improvements are possible through technical risk tifed in 10% of the inspections, but the report does not management. Technology should ensure that the PPPs specify whether these were intentional or due to a lack are applied as accurately as possible and without losses of relevant knowledge. Intentional breaches of the legal and spillage—whether they are in solid form (seed coat- requirements must be countered with increased controls ing and granulates) or in liquid form (for spraying). In and the penalisation of all transgressions. However, if a contrast, aerial applications (e.g., by helicopter) are dif- lack of specialist knowledge is the root cause, then this fcult to control and are, therefore, generally banned in calls for a review of the further training courses ofered Germany under the Plant Protection Act. Tere are a for professional PPP users seeking to obtain the legally Frische et al. Environ Sci Eur (2018) 30:8 Page 12 of 17

required certifcate of competence. A central module of landscape.” [61]. UBA expressly supports this recommen- the curriculum should explain the importance of nature dation and argues for the implementation of this efective conservation and environmental protection and the obli- approach to PPP risk management optimisation in Ger- gation to comply with the relevant legal stipulations. many as widely and as quickly as possible.

Reducing PPP risks through landscape management Point 4: Compensating for unavoidable efects In the opinion of UBA, additional risk management Taking indirect efects of PPPs on biological diversity options should be implemented that are as independ- into account in environmental risk assessment ent from the behaviour of individual PPP users as pos- As already explained for the example of glyphosate, the sible. Agricultural landscape management is an efective indirect efects of the use of chemical PPPs are one of measure as it would at the same time simplify risk man- the factors responsible for the decline of biological diver- agement and in part make it unnecessary to monitor sity in the German agricultural landscape [22]. Indirect compliance with risk mitigation measures (here: spray- efects arise, because the intended rigorous elimination ing distances). Te basic idea is to separate the treated of the feld weeds by herbicides and of farmland insects area from the adjacent environment. By establishing per- by insecticides also leads to a reduction in the food sup- manent green margins and bufer strips or permanent plies for wild animals. As a result, they are unable to three-dimensional vegetation structures (e.g., hedges, reproduce successfully and their populations decline. waterside margins with bushes, and trees), the airborne In the past, such efects on food webs and habitats were transmission and run-of of PPPs to adjacent non-target ignored or their relevance was underestimated, despite areas or bodies of water is avoided or at least considera- the fact that the EC Plant Protection Products Regulation bly reduced. Switzerland is a role model in Europe in this (EC No. 1107/2009) expressly calls for impacts on bio- regard, requiring 3 or 6 m-wide green bufer zones along diversity to be taken into consideration for the approval surface waters [58]. A similar regulation has also been in of PPPs [10]. However, there are not yet any harmonised place in Denmark since 2012 [59]. methods at the EU level to assess the indirect impacts of Te NAP has set a long-term target for Germany to PPPs on biodiversity. create bufer zones, permanently covered with vegeta- tion and at least 5 m in width, for all surface waters in the Using ecological focus areas for risk management agricultural landscape. However, no timeline is specifed Risk management must be improved promptly if the legal in the action plan, and the implementation is the respon- requirement for the protection of biodiversity from the sibility of the individual Federal States (e.g., by including indirect efects of PPPs is to be met. UBA recommends support for the creation of waterside margins in agro- the introduction of special risk mitigation measures: Pre- environmental programmes). Some Federal States have requisite for the use of PPPs with a high risk of indirect already initiated appropriate measures [60], but there is efects on biodiversity should be the existence of eco- currently no systematic overview of the progress made logical compensation areas where PPPs are not applied in creating permanent green waterside margins for Ger- at farm level. Such compensation areas could include set- many as a whole. Te German NAP has set an ambi- aside areas, fowering margins, and untreated thinly sown tious target for the creation of bufer zones by 2023 for areas. Tis landscape-related requirement aims at a com- all surface waters in protected areas for drinking water, pensatory reduction of risk. Te ecological compensa- nature reserves, and in sensitive areas identifed by hot- tion areas should ofset the unavoidable direct efects of spot analyses. Tere is general consensus that the green- the PPPs on the treated areas to the extent that they are ing requirement should be applicable which is valid since reduced to an acceptable level. Te ecological compensa- 2015 under the EU Common Agricultural Policy (CAP) tion areas should ofer typical farmland fauna at least the for such landscape-based risk management. To receive space needed for foraging and retreat. the full CAP area-based payments, farmers are required to dedicate 5% of arable land to ‘ecological focus areas’. Introducing PPP‑specifc risk mitigation measures Te NAP Forum (December 2014) concluded: “Te NAP for authorisation Forum is of the opinion that the primary use of ‘eco- Tis new application requirement should be included logical focus areas’ to create bufer strips, feld margins in the approval procedure using a risk-based approach. and forest peripheries where the application of PPPs is Tis means that the requirement should be imposed banned under the Greening rules can provide an impor- not as a blanket measure for all PPPs but based on the tant contribution for the protection of surface waters and risk assessment for the individual PPP. Such a require- the preservation of biodiversity by increasing the pro- ment should only be imposed for PPPs with a high risk portion of habitats and sanctuaries in the agricultural of indirect impacts on biodiversity. Each PPP would have Frische et al. Environ Sci Eur (2018) 30:8 Page 13 of 17

to be examined as to whether the application in question ecological focus areas in accordance with the CAP green- would reduce food organisms or plants on the treated ing, nor the agro-environment measures from the CAP areas, such that their habitat function for higher organ- “second pillar” are sufcient to protect biodiversity in isms is impaired (in particular birds and mammals). landscapes which are heavily afected by agriculture, as is Tis assessment can be conducted quantitatively on the required under German plant protection legislation ([63], basis of the existing data. Based on a preliminary esti- see also: 21). It is true that the ecological focus areas in mate, a large number of PPPs would be afected by the accordance with CAP can also be efective for the pro- new requirement (nearly all herbicides and insecticides posed PPP-specifc application requirement for the pro- and about a third of fungicides). However, this is not tection of biodiversity. Terefore, the UBA supports the particularly relevant for conventional holdings or those corresponding recommendation of the NAP Forum from which have integrated measures, because the application December 2014 (see further above). requirements will be the same for all the afected PPPs. Despite the critical reactions, the UBA is convinced Once a farm has complied with these requirements, it that its proposal can provide an important contribution will be able to use all PPPs. Te UBA also favours the to the implementation of the German National Strategy introduction of such new risk mitigation measures ini- on Biological Diversity [64]. Tis includes the following tially only for feld crops and primarily for those regions target: “By 2015, the populations of most species typi- with a high proportion of land used for agricultural pur- cal of agriculturally cultivated landscapes will have been poses (i.e., “agricultural steppes”) which have particu- secured and will have begun to increase again.” Efec- larly poor “ecological infrastructure” (hedges, waterside tive action is now urgently needed as this goal has not bufer zones, forest margins, feld verges, and extensive yet been achieved, in part due to the growing pressure grassland) in terms of the protection of biodiversity as on farmland which among others is due to the increased a consequence of rural restructuring. Te UBA and the cultivation of energy crops and fodder crops for inten- German Federal Ofce of Consumer Protection and Food sive livestock farming [22]. Te chemical plant protection Safety (BVL) have discussed the need for compensation sector as a signifcant player must also make a contribu- measures to protect biodiversity against the indirect tion, not least in its own interests. Public confdence in impacts of PPPs. Whereas a concept for their implemen- the possibility of a plant protection that is compatible tation has been drafted important questions of detail with nature and the environment should not be further remain to be clarifed concerning the lack of a standard- endangered, and trust should be restored, even if this ized assessment method in the EU, legally valid evidence means acknowledging the necessity of self-limitation and of a PPP’s potential to harm biodiversity, and methods to a future with less intensive use of PPPs. ensure compliance. Another issue is the necessary mini- mum proportion of ecological compensation areas at Learning from models for biodiversity conservation the level of the individual holdings. Te UBA sees that in conventional agriculture while taking economic viability into consideration, the Te Swiss production label “IP-Suisse” (http://www. ecological compensation areas without PPP application ipsuisse.ch) is a model for the successful implementa- should comprise no less than 10% of the cultivated area tion of voluntary measures to protect and promote bio- of a holding. Tis proportion has already been shown to diversity in the conventional crop production. Certifed be reasonable, because there was a minimum set-aside farms adopt various measures to promote biodiversity quota of 10% in the EU until 2006 [21]. (e.g., lark nesting gaps, multi-year fallow, extensively used grassland, planting hedgerows, etc.). Compliance with Insisting on a contribution from PPP risk management the biodiversity requirements of the IP-Suisse guidelines to protect biodiversity is regularly assessed according to a points-based sys- Te UBA’s thoughts regarding compensation measures tem. A network of advisers supports the farmers with for the indirect efects of PPPs on biodiversity have been the planning and implementation of measures to pro- vehemently rejected by the conventional farming associa- mote biodiversity. In addition to area-based compensa- tions and PPP producers. Tey draw attention in a joint tory measures, there is also a marked reduction in the position paper to the fact that the greening requirements use of PPPs for various crops, e.g., cereal crops are free of the EU Common Agricultural Policy (CAP) also serve of growth regulators, fungicides, and insecticides. Tis is to protect biodiversity, e.g., the requirement for 5% eco- economically viable, frst, because less vulnerable varie- logical focus areas. Tey also argue that “the protection ties are used, and second, because higher prices can be of biodiversity is already addressed in a variety of ways charged under the IP-Suisse label. by the environmental and agricultural policies.” [62]. However, neither the dedication of 5% of arable land as Frische et al. Environ Sci Eur (2018) 30:8 Page 14 of 17

Point 5: Internalising external costs societal costs will either have to be met now or may be Paying more attention to the social dimension borne by future generations who have not had none of of sustainability the current benefts. Private sector activities may, in many cases, gener- ate macroeconomic benefts, but they can also result in Various types of external costs have to be taken into account costs for the general public. Ideally, sustainability should Te main external efects or costs to be taken into involve a just distribution of the benefts and costs of account for a comprehensive analysis include in commercial activities so as to maximise the common particular: good—for today’s society and for future generations. Whether current chemical plant protection meets this •• Survey, monitoring, and repair costs: requirement is a topic of heated debate. Te central ques- tions are: Do the social benefts outweigh the social costs? –– For PPP residues in groundwater and surface Are the benefts and costs distributed fairly between the waters: costs incurred for monitoring, avoidance relevant stakeholders (PPP producers, farmers, trade, measures, and for water treatment are borne by the consumers) and the afected parties (all citizens, tax pay- relevant authorities, by water suppliers and their ers, and future generations)? customers. –– For PPP residues in agricultural produce or pro- Raising awareness about the “external” social costs cessed food commodities. Te costs for monitor- of chemical plant protection ing levels of residues are incurred for the ofcial As described in the introductory chapter, the use of monitoring programmes and for the extensive test- chemical PPPs ofers clear short-term benefts for the ing in food retailing. Ofcial testing is tax-funded, farmers (high, stable yields, and marketable quality) and whereas the food industry passes the costs on to the also for consumers (secure supplies and low shop prices). consumer. Te producers, suppliers, and users of PPPs regularly –– Other ofcial monitoring costs that are not fully point out that in addition to the directly measurable ben- passed on to the PPP authorisation holder or PPP efts for agricultural operators, chemical plant protection users in the form of fees and are instead tax-funded also provides considerable macroeconomic benefts. A (e.g., the portion of costs for ofcial authorisation study commissioned by the German Agricultural Indus- procedures that are not refnanced, consultancy, try Association (IVA) emphasises the “special role of and monitoring costs of the plant protection ser- plant protection for specifc socially relevant objectives” vices of the Federal States, costs of PPP-specifc and estimates the overall annual beneft of chemical plant research by public research institutions). protection for society at between one and four billion •• Health costs as a result of acute or chronic exposure euros [65]. However, a crucial weakness of this study is of PPP users, local residents, or third parties and con- that it only takes into account macroeconomic benefts sumers to PPPs or their residues. Tese include costs without considering the societal costs. Te “positive wel- for medical treatment, lost working time, and the fare efects” of chemical plant protection identifed by the non-material costs of health impairments (sufering). authors should be contrasted with the negative external •• Costs for agricultural production: impacts and costs to provide a more complete picture. Tese costs are borne by the whole of society (“socialised” –– Direct costs (bee-keeping, honey production) and costs) for the necessary monitoring and testing apparatus indirect costs (pollination services) as a result of as well as for the impacts on human health and the envi- acute or chronic pollution of honey bees with PPP ronment. Tese costs are “external”, because they are not residues. fully refected in the market prices of the plant protection –– Costs for the impairment of ecosystem services, products, the harvested crops, and foodstufs. Tis cost e.g., natural biological plant protection by benefcial externalisation is cited as one of the main reasons why insects, pollination by wild pollinators (e.g., bumble the retail prices for conventionally produced food are bees and solitary bees), or the production function much lower than prices for organic food products [66]. of soil by soil organisms (e.g., earthworms). Most consumers are not aware when they choose lower •• Costs of impacts on nature and the environment: cost, conventionally produced goods that they ultimately pay an indirect price which is considerably more than the –– Impacts on aquatic organisms and the biodiversity price at the cash till. Tis is explained partly by farm sub- of surface water bodies by PPP residues as a result sidies funded through taxation and in part to the exter- of accidents, inappropriate use, or unavoidable dif- nalised costs of conventional cultivation systems. Te fuse inputs (dust or spray drift). Frische et al. Environ Sci Eur (2018) 30:8 Page 15 of 17

–– Impacts on biodiversity in soil as a result of una- necessary to discuss the scope for political actions con- voidable PPP inputs in the soil. cerning the “societal dimension” of chemical plant pro- –– Impacts on the biodiversity of wild plants and tection. Tis should also address the potential options invertebrates (insects, spiders, etc.) in the agricul- for political action to compensate for the efects of mar- tural landscape as a result of difuse inputs of PPPs ket distortions and to internalise external costs. Politi- (via dust or spray drift) in habitats adjacent to the cal infuence could be exerted by means of reforms to treated areas. the EU and national farm payments (e.g., increased pay- –– Direct efects of PPP applications (acute or chronic ments for farms with low PPP use) or a levy on PPPs poisoning) and indirect impacts (food web) on ver- (which is common practice in some EU Member States, tebrates (birds, mammals, amphibians, reptiles, and e.g., in Denmark). A study on the introduction of a levy fsh) and the biodiversity of vertebrates in the agri- or tax on PPPs in Germany carried out on behalf of the cultural landscape. Federal States Schleswig-Holstein, Baden-Wurttemberg, and Rhineland-Palatinate recently reignited a discussion Tackling the methodological challenges on this topic [70]. Te UBA expressly welcomes the dis- For various reasons, the quantifcation of the costs of cussion about the prospects and the limits of this instru- impacts on nature and the environment represents a ment—both with regard to the internalisation of external considerable challenge. First, the methodology for mon- costs and to providing incentives to minimise the use of etary assessment of environmental impacts is still in its chemical plant protection products. early stages. Tis is not surprising, because it involves fundamental questions that cannot be answered objec- Abbreviations tively (e.g., “What is the value of a partridge?”). Second, BfN: German Federal Agency for Nature Conservation; BMEL: German Federal a suitable database is often lacking for the assessment Ministry for Food and Agriculture; BMUB: German Federal Ministry for the Environment, Nature Conservation, Building and Nuclear Safety; BVL: Ger‑ of environmental costs. Tis is the case in particular for man Federal Ofce of Consumer Protection and Food Safety; CAP: Common the description or quantifcation of the specifc/relative Agricultural Policy (EU); EFSA: European Food Safety Authority; EU: European contributions of chemical plant protection to adverse Union; IPM: Integrated Plant Protection (often also referred to as Integrated Pest Management); IVA: German Agricultural Industry Association; JKI: Julius impacts or general trends observable in the environ- Kühn Institute (German Federal Research Centre for Cultivated Plants); ment, e.g., efects on water organisms of pollution with NAP: German National Action Plan on Sustainable Use of Plant Protection both PPP residues and nutrients. Currently, the data and Products; PPP: Plant Protection Products; UBA: German Environment Agency (Umweltbundesamt). analyses needed for a rational and fact-based discussion are not available. Te only comprehensive, independent Authors’ contributions cost–beneft analysis for Germany was commissioned TF wrote the frst draft of the manuscript. All authors contributed on specifc aspects. All authors read and approved the fnal manuscript. in 1991 by the Agriculture Ministry [67]. Tis study still has a model character, because no analyses of compara- Acknowledgements ble scope have since been carried out in Germany. Mean- This position paper was jointly written by the authors based on the scientifc and regulatory work of the UBA, especially within the Section Plant Protection while, however, conventions and proposals regarding the Products. criteria for socio-economic assessments of environmen- tal impacts have been developed, e.g., at the international Competing interests The authors declare that they have no competing interests. level [68] and also by UBA [69]. Finally, monetary assessment also raises fundamen- Availability of data and materials tal ethical questions. For example, would humanity be A German language version of this position paper is available via: https:// www.umweltbundesamt.de/sites/default/fles/medien/377/publikationen/ justifed in allowing the extermination of individual ani- uba-positionspapier_5-punkte-programm_nachhaltigkeit_pfanzenschutz_ mal and/or plant species if this provided an economic web.pdf. beneft? Consent for publication Not applicable. Discussing the need for political action on the basis of sound data Declarations Not applicable. Te UBA sees a need for a systematic review of and a political discussion about both the external costs of Ethics approval and consent to participate chemical plant protection in Germany and the distri- Not applicable. bution of the costs within society. UBA commissioned Funding a study drawing on the work of Waibel and Fleischer Not applicable. [67] to provide scientifc clarity. In a second step, it is Frische et al. Environ Sci Eur (2018) 30:8 Page 16 of 17

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