POSITION PAPER FITNESS-CHECK OF THE WATER FRAMEWORK DIRECTIVE (WFD)

Transcription

1 Copa-Cogeca EN(17)3758:5 VO/fb Brussels, 12th April 2018 POSITION PAPER FITNESS-CHECK OF THE WATER FRAMEWORK DIRECTIVE (WFD)

2 POSITION PAPER FITNESS-CHECK OF THE WATER FRAMEWORK DIRECTIVE (WFD) There is no food without water water is an essential production resource for agriculture, critical for feeding the growing population and for providing safe, high-quality, nutritious food produced sustainably throughout the EU territory. Especially in the context of a rapidly changing environment and a world population expected to reach nearly 9 billion in the year 2050, providing water in sufficient quality and quantity to agriculture is essential. This must be acknowledged by EU policies. Several policies are in place to improve the water conditions across the EU, such as the Water Framework Directive (WFD), the Nitrates-, Floods-, and Drinking Water Directive. But also the recent EU circular economy package, the revised EU regulation on fertilizers and EU climate policies improve the sustainable management of water across all sectors. The Common Agricultural Policy (CAP) establishes strong links with these policies. Through a large set of complementary instruments, the sustainable management of natural resources has become a priority of the CAP: cross-compliance, green direct payments and agri-environment climate measures. With these instruments in place, significant environmental progress has been made by EU farmers throughout the last decades and the farming sector will continue to contribute to an overall more sustainable use of water. In light of the current evaluation of the WFD under Art 19, COPA and COGECA call for the following points to be taken into consideration: 1. Art 14 - Stakeholder involvement COPA and COGECA welcome the broad involvement of stakeholders foreseen under the WFD. Public participation is one of the Directive s cornerstones and has the potential to contribute significantly to an integrated approach to water management. However, it turns out that the participatory approaches that Member States offer are in many cases too technical and require significant preliminary preparation work and a high level of technical understanding of the topic. COPA and COGECA ask for simplified and more targeted participatory activities to lower the threshold of expertise required and to foster real participation of stakeholders. 2. Art 4 Overambitious targets and the One-out, all-out principle Significant progress has been made for the large majority of EU water bodies. Unfortunately, this is not reflected by the Directive s reporting systems. With regards to achieving good status of water, the one-out, all-out principle is not properly reflecting reality or community perceptions about the quality of water, masking improvements and eventually discouraging ambitions. As a result, a general picture of the state of the waters is poorer than what they are in practice. Under this principle, substantial financial resources are needed for achieving only minor additional benefits.

3 COPA and COGECA call for replacement of the one-out, all-out principle by a more flexible system in assessing water quality. A stepwise approach where gradual improvements are being recognized is very much needed. This implies that qualitative assessments of water bodies should take the economic aspect more into account. In light of overambitious environmental goals, realistic targets need to be established, especially taking into account natural conditions, different water uses, and the effects of climate change. Historical loads and their effects to the water quality need to be clearly recognized. Otherwise, the widespread use of exemptions must be forced. 3. Art 9 Water-pricing and the polluter-pays principle As a result of compliance with EU environmental standards in the fields of water protection, fertilization, plant protection, livestock, cross compliance and greening, farmers are bearing significant costs and shortfalls in revenues. Therefore, environmental and resource costs are already largely accounted for by the farming sector. COPA and COGECA strongly oppose any endeavour to further valorise water and are also against any the monetarization of the ecosystem service of provision of freshwater for agricultural purposes. Water for agricultural purposes from wells owned by farmers must be free of charge. Environmental and resource costs can neither be expressed in monetary terms nor individually allocated according to the Directive s polluter-pays principle. Existing approaches for water pricing are costly, time-consuming and highly administrative, making a practical implementation impossible. Increased water costs would harm agricultural irrigation as a particularly sustainable form of agriculture. 4. Nutrients The EU Nitrates Directive aims at protecting water quality across Europe by preventing nitrates polluting ground and surface waters. Through the designation of "Nitrate Vulnerable Zones" and the establishment of Action Programmes to be implemented by farmers on a compulsory basis, adverse impact of agriculture on water quality has significantly been reduced. With high costs to farmers, requirements within the Member States action programs have considerably been stepped up. Spreading techniques are becoming more and more sophisticated, spreading windows have been narrowed, storage capacities increased and the maximum amount of nitrogen and phosphorus fertilizers / ha limited. Nevertheless, nutrient leaching from broken, old or undersized sewage systems into the groundwater is a problem, which is not sufficiently recognized. In addition, untreated rainwater from urban areas and medicinal residues from human use also contain high concentrations of substances harmful to the water quality. COPA and COGECA call for a comprehensive evaluation of all possible nutrient sources into waterbodies. We especially consider that more attention has to be payed to these nonagricultural, non-point pollution sources and to pollutants that urban waste water treatment plants are currently not able to remove. COPA and COGECA consider that the limitation of fertilizer use including manure has reached a level where any additional tightening must be rejected. Demand-based plant nutrition and thus food security should not be restricted by water protection.

4 More focus must be set on the adaptation to climate change which is consequently reducing the capacity of groundwater bodies to recharge and causing less dilution of nutrients, thus leading to higher concentrations. Different nitrate gradients call for gradually different measures to be taken on the ground. 5. Plant protection products Since more than a decade the EU has been applying a more and more restrictive approach to chemicals and especially to Plant Protection Products (PPPs). This hazard-based approach results in removal of active substances from the market, whilst at the same time, few substances are coming in. For instance, the number of active substances has been cut by 50% since the year Furthermore, new substances have to undergo a deep assessment procedure, which ensures not only a high level of human and animal health but also a high level of environmental protection. At the same time, under the Sustainable Use Directive 2009/128/EC, all farmers have to undergo compulsory trainings in safe use of PPPs. Also spraying equipment has to be checked regularly to minimize drift and leakage into surface water. Finally, as part of the daily practices EU farmers apply Integrated Pest Management (IPM). Indeed, the over-whelming majority of pests and diseases in crops are controlled with cultural or physical measures (crop rotation, cultivation practices, sowing densities, seed varieties and selection...). The refinement of methods of measurements and water analyses allow the detection of ever-smaller amounts of PPPs. This must not lead to ever-lower thresholds. We consider that the use of pesticides is already sufficiently controlled, also by other legislation. No further regulation through the WFD is needed. 6. Water storage & water reuse To further reduce abstraction of groundwater and surface water, farmers already pursue a whole set of adaptive strategies at farm level. For instance, strategies to increase soil capacity to store water, the use of plant varieties with high water productivity and that are regionally adapted are more and more becoming the reality. Also smart farming solutions, big data and precision irrigation and the continuous electrification of wells largely contribute to an increased water use efficiency in agriculture. Water storage and water reuse are important strategies to reduce abstraction of freshwater and to further improve on-farm water use efficiency. Furthermore, both tools are important measures to tackle the impact of climate change, bringing benefits to the environment and to farm economics. The development of water storage, starting from small on-farm storage up to bigger storage infrastructures, is the single most important means to improving water security. COPA and COGECA call for greater fiscal and financial support and incentives (grants, tax incentives, skills) to foster water storage and irrigation. Also a reduction of administrative red tape when applying for reservoirs (licensing, planning, permits) is necessary. COPA and COGECA consider that a fit for purpose criteria has to be applied when utilizing reused water in irrigation. Also, bottlenecks have to be overcome. For instance, consumers perception and legal liabilities are still slowing down the further uptake of such water.

5 7. Underestimation of climate change impact for achieving good status Primary production is the economic sector, which is hardest hit by climatic changes. Climate change is affecting water resources through its impact on the quantity, variability, timing, form, and intensity of precipitation. More than ever, climate change negatively affects European freshwater ecosystems, their biodiversity and ecological status, putting seriously at risk the targets set out by the WFD and the significant improvements that have been made so far. As a result of air temperature increase, water temperatures have been observed to increase accordingly and will continue to do so. Higher temperatures are likely to decline oxygen concentrations in water bodies, an increase in the population of harmful algae. Reduction in precipitations and decreased summer flows will further reduce the capacity of groundwater bodies to recharge and will cause less dilution of nutrients. On the other side, an increase in heavy rainfalls will lead to more erosion and surface runoff of nutrients. For this, drainage of soils (on and outside farmland) must remain a high priority. Also increased pressures from Invasive Alien Species and pathogenic micro-organisms can be observed. Despite all efforts undertaken by the farming sector, climate change is significantly affecting biodiversity and the ecological status of water bodies, resulting in a degradation trend of water quality. In this context, the adverse impact of agriculture on water quality is in many cases overrated and has to be objectified. COPA and COGECA call for more flexibility in the application of targets and standards, with respect to the effects of climate change, meeting agricultural demands and achieving environmental goals. By solely focusing on agriculture we risk to oversee other and recently evolving sources of pressure on water quality and quantity. The Fitness-Check should especially take into consideration that the WFD currently lacks to properly address the negative impacts of climate change.