Select Committee on Environmental Audit Minutes of Evidence

Annex 1

Letter from Water UK to Tax Policy Team, HM Treasury


  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.


  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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