Annex 1
Letter from Water UK to Tax Policy Team,
HM Treasury
INTRODUCTION
Water UK is the trade organisation representing
the water suppliers and waste water operators of the UK. We have
a clear commitment to fully meet all drinking water standards,
including those for pesticides, at the lowest practicable cost
and using approaches which are environmentally sustainable.
The pesticide standard for drinking water is
0.1 µg/l for any individual pesticide and 0.5 µg/l in
total. These standards are based on Drinking Water Directive 80/778/EC,
and have recently been reaffirmed in the adopted update of the
Directive 98/83/EC. It is of particular significance to note that
these standards are not based on toxicological criteria,
but are an effective surrogate for zero.
In the UK drinking water is derived from a variety
of sources including rivers, upland reservoirs and groundwater.
Many river sources, particularly in lowland areas, can regularly
contain pesticide residues in excess of the drinking water standards.
In some areas ground water and upland reservoir sources have also
suffered from pesticide contamination.
In consequence water companies have invested
heavily in expensive pesticide removal technology to ensure that
water supplied to customers meets the required quality. However,
relying on treatment to correct raw water contamination is not
in accord with the "polluter pays" principle nor is
it compatible with long-term environmental sustainability.
Therefore the objective of water suppliers is
to promote agricultural and land use practices which ensure that
raw water resources meet the pesticide standard for drinking
water without the need for special treatment. It is recognised
that in some areas this will not be achievable in the short-term,
and in consequence a targeted and prioritised approach is necessary
based on:
— preventing further degradation of
existing unpolluted resources;
— progressive restoration of contaminated
resources.
To this end water companies have developed close
working partnerships with pesticide manufacturers and users, farmers,
regulatory agencies and others to jointly develop and promote
best practice in pesticide use which minimises the risks of pesticide
pollution.
However, it is recognised that voluntary best
practice must be accompanied by a clear and effective regulatory
regime which, when necessary, restricts the use of certain pesticides
completely, or imposes stringent conditions on use. This approach
has been effective in the past, for example the ban on atrazine
for non-agricultural purposes has significantly reduced contamination
from this product.
THE PROPOSED
PESTICIDE TAX
It is not appropriate for Water UK to comment
as such on the broader fiscal implications of the proposed pesticide
tax and in particular on the likely effect on agricultural practices.
However, from our extensive practical experience
of researching, monitoring and working on pesticide pollution
we do wish to offer the following technical observations:
1. Diffuse pesticide pollution pathways
are complex in the extreme and depend on a variety of interactions
between crops, soil and water bodies. The pathways will vary extensively
between different geographic areas and also in time. They can
be particularly influenced by variable climatic factors.
2. There is growing evidence that pesticides
detected in water resources derive both from diffuse parthways
and from point sources, particularly spillage and run off from
mixing areas. Pesticide contamination can also derive from non-agricultural
use, for example control of weed on roads or railways.
3. An overall net reduction in total pesticide
use would have some general intrinsic value, but would
not necessarily lead to an equivalent reduction in pollution of
water resources. In fact a situation could theoretically arise
in which the total rate of pesticide application decreased
but the pollution effect on water resources increased.
This is for the reasons set out in (1) above.
4. From the perspective of water suppliers
and particularly in relation to the drinking water standard for
pesticides, we have significant reservations about whether the
proposed tax would in practice achieve its objectives. This is
for the following reasons:
(a) Because the Drinking Water standard is
non-toxicologically based, the use of a banded tax based on toxicity
criteria is irrelevant. Indeed most of the pesticides causing
problems for water supplies are cereal herbicides of relatively
low eco and mammalian toxicity.
(b) Even if the tax does have an impact on
reducing the amount of usage of some pesticides, any corresponding
beneficial environmental input will be unpredictable and could
be non existent. This is because application rate is only one
of a complex series of factors that impact on pesticide fate at
a local level.
(c) A pesticide tax might distort the use
of certain products to the disbenefit of the environment, for
example those older and thuse cheaper products might increase
in use even though they are potentially more likely to cause water
pollution.
5. In our view, a preferred way forward
to reduce water pollution from pesticides would be based on a
twin track approach involving:
(a) Active promotion of voluntary best practice
in environmentally sustainable crop protection;
(b) A firm but fair regulatory system controlling
and, when necessary, restricting the use of specific products
or ingredients known to cause problems.
The existing system for pesticide management
is already based on this approach and with appropriate enhancements
is likely to prove a much more cost effective way of achieving
an environment with minimal adverse effects from pesticides.
June 1999
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