In particular, further training and assistance with conversion should be offered; improved financial support for organic farming is also needed.
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The UBA welcomes this and calls for the vigorous expansion of organic farming in Germany, not least as an important element for sustainable plant protection. This endeavour will also require the strengthening of research and development for plant protection in organic farming. The call to minimise the use of chemical PPPs also applies for public green spaces, private gardens and allotments. Giving preference to non-chemical alternatives in these cases is, therefore, both practicable and reasonable. Information is already available on how to minimise the use of chemical pesticides in gardens and allotments e.
In addition to the voluntary avoidance of chemical plant protection, UBA also advocates a complete ban on herbicides in gardens and allotments. The background for this is the repeated occurrence of inputs of herbicides into public sewers and wastewater treatment systems, which in many cases is likely due to inappropriate application by private users, for example on paved areas [ 39 , 40 ]. In France, a nationwide ban on chemical PPPs in public green spaces will come into effect from [ 42 ].
For example, the assessment currently fails to pay sufficient attention to the impacts on amphibians, reptiles, wild pollinators, soil arthropods, aquatic and soil fungi, or the indirect effects on biodiversity for the latter, see also below. There is also considerable uncertainty about how representative the results of model calculations are of the PPP residues expected in the soil, groundwater, and surface water bodies.
Improvement of the environmental risk assessment requires the continuous further development of the principles on which it is based as well as implementation of the scientific developments in appropriate testing requirements and assessment concepts. Responsibility for this development in Germany lies with UBA, in parallel to the processing of authorisation applications.
Research projects commissioned by UBA for this purpose, the results of which are frequently introduced into the further development of the testing and assessment procedures at the European level. This revision process is initiated primarily by UBA for Germany and by EFSA with the goal of meeting the requirement to implement the state-of-the-art. Scientific progress is thus one of the reasons for the marked increase in the complexity of environmental risk assessment for PPPs in recent decades.
The investment in such a refinement of the risk assessment, e. This is either because it is the only way to obtain an authorisation or because it makes it possible to avoid stricter requirements for risk management e. Refined risk assessment for environmentally critical but heatedly justified PPPs in particular is becoming increasingly complex.
This trend is questionable from a scientific point of view, because the more realistic risk assessment is still carried out in isolation for the individual PPP for which the application has been made. It ignores the fact that the exposure regime for the given crop will usually involve the multiple applications of various PPPs over the growing season.
The relevance of common forms and intensities of PPP application in tank mixtures and spraying with a series of PPPs compared to the evaluation and management of the environmental risks for individual PPPs has been and is being addressed in research projects commissioned by UBA e. Generally speaking, UBA sees the need to discuss the extent to which the trend towards increasingly refined risk assessment for individual PPPs i is appropriate or is as a rule disadvantageous for the environment, ii causes unnecessary societal costs, and iii places excessive demands on the risk communication see further below.
For an initial exchange on these questions, a working meeting initiated by UBA was held in November , attended by experts from the relevant assessment authorities of a number of European countries. Considerable scientific expertise is required for PPP producers to be able to further refine the risk assessment and for the assessment authority bodies to understand the measures involved. Quite frequently applicants do commission renowned scientists to prepare a scientific report for a refined assessment which is then submitted to defend the authorisation of the PPP or to argue that fewer management measures are required.
Even if the assessment authority is able to respond with equal expertise which becomes more difficult the smaller the agency of an EU Member State is , this development is problematic. In general, the more important the expert judgements become, the less transparent the decisions become for the public. The decision-making process becomes more susceptible to the influence of parties with special interests due to the relatively small numbers of actors involved.
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Many experts with earlier or existing connections to the chemical industry are believed to have conflicts of interests. In the future, a significant step towards more transparency would be to make all the relevant data about the environmental behaviour and ecotoxicology of the active substance or PPP, including the results of confidential studies commissioned by the applicant, available in an open database.
As explained, the increasing complexity of the environmental risk assessment of PPPs is to some extent an unavoidable consequence of scientific progress. However, this does not apply for the complexity of the refined risk assessments for individual PPP enforced by applicant companies. For a PPP that could already be authorised, all justifiable options for the management of the environmental risks should first be exploited before the authorities approve and accept highly complex refinements of the risk assessment whose only aim is to create more favourable conditions for application of the PPP e.
A further exclusion criterion is targeting endocrine disruptors. These criteria have been introduced by policy-makers and require a paradigm shift in the decision-making process. The decision on an approval or ban should in future only be based on the undesirable substance properties and not, as previously, on a quantitative risk assessment i. Experts justify the hazard-based regulation by referring to the high level of uncertainty in the risk assessment for the targeted hazardous properties.
The cut-off criteria provide an impulse to develop and use active substances and PPPs that have lower environmental impacts. However, a practical implementation is currently not possible, because the scientific and technical details of the cut-off criteria have not yet been developed and specified in subordinate regulations.
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The delays in implementation have been due not least to the massive interventions of the European PPP industry, which categorically rejects hazard-based regulation and demands a return to risk assessment, even for undesirable substance properties [ 50 ]. The UBA believes that the cut-off criteria are in principle well suited to improve the protection of the environment against particularly hazardous PPPs.
Because of this conviction and in accordance with its responsibilities, UBA is also involved in the discussion about the specification and implementation of the cut-off criteria [ 51 , 52 ]. One particular challenge is that it is not always clear from an environmental point of view whether an alternative active substance really is better than the banned active substance it is meant to replace.
The methodology of comparative assessment of the environmental hazard or risks of PPPs is—both from a scientific and regulatory viewpoint—challenging and has not been sufficiently tested so far [ 53 ].
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However, the general public and users rightly demand that in future the assessment authorities should make increased use of their expertise to provide information about the more environmentally favourable alternatives. It remains to be seen how effective the instrument of comparative assessment will prove in terms of making environmental impacts measurable. A further challenge is the description of the environmental risks and environmental impacts that result from the overall intensity of chemical plant protection in Germany.
There is a need for scientifically relevant indicators that are understood by the public and can be used for their information and for policy-making. Some environmental indicators were used to review the progress of the German NAP. Comparable to the risk assessment for individual PPPs, the SYNOPS indicator calculates a generic risk index for plant protection intensity in Germany for selected non-target organisms, e.
Ideally, data from environmental measurements and environmental monitoring allow conclusions to be drawn about: i the plausibility of the risk assessment in the approval procedure, ii the efficacy of PPP-specific environmental risk management, and iii changes to the environmental status through the general use trend of PPPs. At present, there is no representative PPP-specific monitoring in Germany for all potentially affected environmental compartments, ecosystems, and organisms. The German NAP only collates existing monitoring programmes, giving an incomplete overview of the current environmental impacts of chemical plant protection.
The UBA sees a clear need for improvements and has commissioned an on-going research project within the framework of the German NAP to develop of a strategy for monitoring the pesticide loads of small surface water bodies in the agricultural landscape [ 55 ]. The small surface water bodies make up a large proportion of the overall network of surface waters and are at greatest risk of pollution with PPPs due to their proximity to the application areas. However, they are currently underrepresented in the monitoring scheme pursuant to the EU Water Framework Directive.
The UBA also initiated a research project to test whether and how integrated monitoring could improve the description of the environmental impacts of chemical plant protection. Integrated monitoring records both the fate and exposure of PPPs or PPP residues in the environment as well as their impacts on organisms, ecosystems, and ecological processes. This parallel registration is necessary to be able to identify the specific contribution of the chemical plant protection to changes in the environmental status, in particular if the processes are influenced by a number of different factors e.
The simplest and most effective way to avoid the risks and impacts of chemical PPPs is not to use them. UBA believes that PPPs should not be applied on public green spaces, private gardens, and allotments, nor—wherever possible—also in nature conservation and drinking water protection areas. This recommendation is in accordance with the EU Sustainable Use Directive, which stipulates a minimisation of or ban on the use of PPPs for nature conservation areas protection areas for birds, FFH areas and drinking water protection areas [ 28 ].
However, this is not transposed into a national regulation in Germany; rather the Plant Protection Act passes on the responsibility for introducing the appropriate measures to the Federal States Article 22 of [ 9 ]. If the use of chemical PPPs is unavoidable, they should be applied making the best possible use of the available technology and economically justifiable options for risk management. The goal is to stop PPP residues—to the extent possible—from entering into or spreading to non-target areas, natural assets e.
Although this will never be completely feasible, further improvements are possible through technical risk management. Technology should ensure that the PPPs are applied as accurately as possible and without losses and spillage—whether they are in solid form seed coating and granulates or in liquid form for spraying.
In contrast, aerial applications e. There are a few exceptions, for example treating the crown zone of forests or steep vineyard slopes [ 9 , 56 ]. When applying PPPs on arable land and for special crops fruits, vines, and hops , it is usually necessary to use mobile spraying gear with drift-reducing nozzle technology.
Introducing the best available nozzle technologies is thus an effective way to reduce environmental pollution by PPP residues. The German NAP formulates the same target but without specifying any measures to be adopted. Possible options include the introduction of an appropriate innovation and subsidy programme or granting tax credits for the adoption of modern technology.
Farmers who fail to comply with the legally binding PPP-specific risk mitigation measures for the protection of the environment are subject to fines. Key requirements concern the maintenance of untreated margins of fields adjacent to bodies of water and terrestrial habitats e.
As a rule, however, the yield and crop quality is lower for these untreated areas of farmland, resulting in financial losses as a consequence of compliance with result from observing the spacing requirements [ 57 ]. However, the extent to which plant protection products are applied in accordance with the regulations in Germany is unclear. The results of the checks carried out by the Federal States are documented in annual reports on the plant protection monitoring programme www. The report shows that relatively few checks were carried out.
The main reason for this is the understaffing of the Federal States plant protection services. Intentional breaches of the legal requirements must be countered with increased controls and the penalisation of all transgressions. However, if a lack of specialist knowledge is the root cause, then this calls for a review of the further training courses offered for professional PPP users seeking to obtain the legally required certificate of competence.
A central module of the curriculum should explain the importance of nature conservation and environmental protection and the obligation to comply with the relevant legal stipulations. In the opinion of UBA, additional risk management options should be implemented that are as independent from the behaviour of individual PPP users as possible. Agricultural landscape management is an effective measure as it would at the same time simplify risk management and in part make it unnecessary to monitor compliance with risk mitigation measures here: spraying distances.
The basic idea is to separate the treated area from the adjacent environment. By establishing permanent green margins and buffer strips or permanent three-dimensional vegetation structures e. A similar regulation has also been in place in Denmark since [ 59 ]. However, no timeline is specified in the action plan, and the implementation is the responsibility of the individual Federal States e. Some Federal States have already initiated appropriate measures [ 60 ], but there is currently no systematic overview of the progress made in creating permanent green waterside margins for Germany as a whole.
The German NAP has set an ambitious target for the creation of buffer zones by for all surface waters in protected areas for drinking water, nature reserves, and in sensitive areas identified by hot-spot analyses. There is general consensus that the greening requirement should be applicable which is valid since under the EU Common Agricultural Policy CAP for such landscape-based risk management. UBA expressly supports this recommendation and argues for the implementation of this effective approach to PPP risk management optimisation in Germany as widely and as quickly as possible.
As already explained for the example of glyphosate, the indirect effects of the use of chemical PPPs are one of the factors responsible for the decline of biological diversity in the German agricultural landscape [ 22 ]. Indirect effects arise, because the intended rigorous elimination of the field weeds by herbicides and of farmland insects by insecticides also leads to a reduction in the food supplies for wild animals. As a result, they are unable to reproduce successfully and their populations decline. In the past, such effects on food webs and habitats were ignored or their relevance was underestimated, despite the fact that the EC Plant Protection Products Regulation EC No.
However, there are not yet any harmonised methods at the EU level to assess the indirect impacts of PPPs on biodiversity. Risk management must be improved promptly if the legal requirement for the protection of biodiversity from the indirect effects of PPPs is to be met. UBA recommends the introduction of special risk mitigation measures: Prerequisite for the use of PPPs with a high risk of indirect effects on biodiversity should be the existence of ecological compensation areas where PPPs are not applied at farm level. Such compensation areas could include set-aside areas, flowering margins, and untreated thinly sown areas.
This landscape-related requirement aims at a compensatory reduction of risk. The ecological compensation areas should offset the unavoidable direct effects of the PPPs on the treated areas to the extent that they are reduced to an acceptable level. The ecological compensation areas should offer typical farmland fauna at least the space needed for foraging and retreat.
This new application requirement should be included in the approval procedure using a risk-based approach. This means that the requirement should be imposed not as a blanket measure for all PPPs but based on the risk assessment for the individual PPP. Such a requirement should only be imposed for PPPs with a high risk of indirect impacts on biodiversity. Each PPP would have to be examined as to whether the application in question would reduce food organisms or plants on the treated areas, such that their habitat function for higher organisms is impaired in particular birds and mammals.
This assessment can be conducted quantitatively on the basis of the existing data. Based on a preliminary estimate, a large number of PPPs would be affected by the new requirement nearly all herbicides and insecticides and about a third of fungicides. However, this is not particularly relevant for conventional holdings or those which have integrated measures, because the application requirements will be the same for all the affected PPPs.
Once a farm has complied with these requirements, it will be able to use all PPPs. The UBA also favours the introduction of such new risk mitigation measures initially only for field crops and primarily for those regions with a high proportion of land used for agricultural purposes i. Another issue is the necessary minimum proportion of ecological compensation areas at the level of the individual holdings. They draw attention in a joint position paper to the fact that the greening requirements of the EU Common Agricultural Policy CAP also serve to protect biodiversity, e.
It is true that the ecological focus areas in accordance with CAP can also be effective for the proposed PPP-specific application requirement for the protection of biodiversity. Despite the critical reactions, the UBA is convinced that its proposal can provide an important contribution to the implementation of the German National Strategy on Biological Diversity [ 64 ]. The chemical plant protection sector as a significant player must also make a contribution, not least in its own interests. Public confidence in the possibility of a plant protection that is compatible with nature and the environment should not be further endangered, and trust should be restored, even if this means acknowledging the necessity of self-limitation and a future with less intensive use of PPPs.
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Welches Alter hat der Dorsch? Altersvalidierung an wildlebenden Ostseedorschen. Pulsbaumkurre in der Krabbenfischerei. Weiterentwicklung von Mehrartenmodellen im Fischereimanagement. Koordination der Datenerhebung aus kommerziellen Fischereien der Ostsee.
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