UNDP/GEF Danube Regional Project
Policies for the Control of Agricultural Point
and Non-point Sources of Pollution
&
Pilot Projects on Agricultural Pollution Reduction
(Project Outputs 1.2 and 1.3)
Recommendations for Policy Reforms for the
Introduction of Best Agricultural Practice (BAP) in
Central and Lower Danube River Basin Countries
February 2004
Final Report
GFA Terra Systems
in co-operation with Avalon
Your contact person
with GFA Terra Systems is
Dr. Heinz-Wilhelm Strubenhoff
Danube Regional Project - Project RER/01/G32
"Policies for the control of agricultural point and non-point sources of pollution"
and "Pilot project on agricultural pollution reduction"
(Project Outputs 1.2 and 1.3)
Recommendations for Policy Reforms and for the Introduction of Best Agricultural
Practice (BAP) in the Central and Lower Danube River Basin Countries
Address
GFA Terra Systems GmbH
Eulenkrugstraße 82
22359 Hamburg
Germany
Telephone: 00-49-40-60306-170
Telefax: 00-49-40-60306-179
E-mail: hwstrubenhoff@gfa-terra.de
UNDP/GEF Danube Regional Project
Preface
The UNDP/GEF Danube Regional Project supports through this Project Component the development
of policies for the control of agricultural point and non-point sources of pollution and the development
and implementation of pilot projects on agricultural pollution reduction in line with the requirements
of the EU Water Framework Directive.
The Overall Objective of the Danube Regional Project is to complement the activities of the ICPDR
required to strengthen a regional approach for solving transboundary problems in water management
and pollution reduction. This includes the development of policies and legal and institutional
instruments for the agricultural sector to ensure reduction of nutrients and harmful substances with
particular attention to the use of fertilizers and pesticides.
According to the mandate of the Project Document:
Objective 1 stipulates the "Creation of Sustainable Ecological Conditions for Land Use and Water
Management" and under
Output 1.2 is the "Reduction of nutrients and other harmful substances from agricultural point and
non-point sources of pollution through agricultural policy changes".
One of the main aims of Output 1.2 is to support the integration of measures for pollution control into
the day-to-day management of crops, animals and land by farmers through the promotion of "best
agricultural practice" (BAP).
The first phase of Output 1.2 is preparatory and is being undertaken by GFA Terra Systems
(Germany) in co-operation with Avalon (Netherlands). The GFA Terra Systems/Avalon consultancy
team consists of 6 international consultants and a network of 35 national experts in the 11 central and
lower DRB countries eligible for UNDP/GEF assistance a key focus of their work has been the
development of policy recommendations for the introduction of BAP in the central and lower DRB
countries.
The present document introduces the concept of BAP and the opportunities for promoting it through
agricultural policy changes. The recommendations in the report are founded upon the review and
analysis presented in four other key documents produced within the framework of Output 1.2:
· Inventory of Agricultural Pesticide Use in the Danube River Basin Countries
· Inventory of Fertiliser and Manure Use (with reference to Land Management Practices) in the
Danube River Basin Countries
· Inventory of Policies for Control of Water Pollution by Agriculture in the Danube River Basin
Countries
· Draft Concept for Best Agricultural Practice for the Danube River Basin Countries
Finally, the report sets the framework for agricultural policy reforms and for the practical introduction
of BAP in selected demonstration pilot projects in central and lower Danube countries to be
implemented in Phase 2 of the UNDP/GEF Danube Regional Project.
The findings and analysis in the present report have been prepared by Dr Mark Redman, supported by
Lars Neumeister and Jaroslav Prazan.
The report also draws upon the conclusions from an international workshop held in Zagreb in October
2003 that brought together a comprehensive cross-section of policy-makers in agriculture and water
resource management from all eleven central and lower DRB countries to participate in discussion of
the problems and potential practical solutions associated with agriculture and water pollution in the
region.
UNDP/GEF Danube Regional Project
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin
Table of Content
List of Tables
List of Figures
Acronyms and Abbreviations
1
The Concept of Best Agricultural Practice (BAP) ........................................................................ 1
1.1 Introduction ................................................................................................................................... 1
1.2 Developing the BAP Concept........................................................................................................ 3
2
Policy Instruments and Measures for Promoting BAP.................................................................. 5
3
Current Status of Policies for Agricultural Pollution Control in DRB Countries ....................... 10
4
Opportunities for Policy Reform in Relation to EU Enlargement............................................... 11
4.1 Harmonisation of National Legislation with EU Regulatory Instruments .................................. 11
4.2 Implementation and Reform of the Common Agricultural Policy (CAP)................................... 14
4.3 Developing the Concept of "Environmental Cross Compliance" ............................................... 15
5
DRB-wide Strategic Aims, Objectives and Measures for Policy Reform................................... 16
6
Aim 1: To Reduce Pollution from Mineral Fertilisers and Manure ........................................... 17
7
Aim 2: To Reduce Pollution from Pesticides ............................................................................. 18
8
Aim 3: To Improve Regulatory Instruments for Agricultural Pollution Control........................ 20
9
Aim 4: To Develop Appropriate Economic Instruments for Agricultural Pollution Control..... 21
10
Aim 5: To Develop the Capacity of Agricultural Extension Services for Agricultural
Pollution Control ......................................................................................................................... 22
11
Aim 6: To Promote Organic Farming and other Low Input Farming Systems .......................... 24
12
Summary of Policy Recommendations ....................................................................................... 25
13
Adapting Policy Aims, Objectives and Measures to National/Regional Context ....................... 27
13.1 Introduction ................................................................................................................................. 27
13.2 Key Issues for Selection of Priority Policy Recommendations................................................... 27
13.3 Developing the "Policy Mix" ...................................................................................................... 29
14
Conclusions and Proposals for Implementation of Recommendations for Policy Reform ......... 33
14.1 Conclusions ................................................................................................................................. 33
15
Proposals for Further Actions...................................................................................................... 34
15.1 Further Development and Introduction of Policy Instruments Adapted to National Conditions 34
15.2 Practical Demonstration of BAP in the Framework of Pilot Projects ......................................... 35
UNDP/GEF Danube Regional Project
Annexes
Annex 1 Review of Agricultural Water Pollution Control Policy and Practice in the
Danube River Basin
Annex 2 Bosnia & Herzegovina
2.1
Federation of Bosnia & Herzegovina
2.1.1
Policy Strategy and Objectives
2.1.2
Policy Instruments, Measures and Institutional Arrangements
2.1.3
Existing Programmes and Projects Promoting "Good/Best Agricultural
Practice"
2.1.4
Summary and Assessment of the Effectiveness of the "POLICY MIX"
2.1.5 Information
Sources
2.2 Republic
od
Srpska
2.2.1
Policy Strategy and Objectives
2.2.2
Policy Instruments, Measures and Institutional Arrangements
2.2.3
Existing Programmes and Projects Promoting "Good/Best Agricultural
Practice"
2.2.4
Summary and Assessment of the Effectiveness of the "POLICY MIX"
2.2.5 Information
Sources
Annex 3 Bulgaria
3.1
Policy Strategy and Objectives
3.2
Policy Instruments, Measures and Institutional Arrangements
3.2.2
Economic Instruments and Measures
3.2.3 Advisory/Information
Instruments and Measures
3.2.4
Project-based Instruments and Measures
3.3
Existing Programmes and Projects Promoting "Good/best Agricultural
Practice"
3.4
Summary and Assessment of the Effectiveness of the "POLICY MIX"
3.5
Information Sources
Annex 4 Croatia
4.1
Policy Strategy and Objectives
4.2
Policy Instruments, Measures and Institutional Arrangements
4.2.1
Regulatory Instruments and Measures
4.2.2
Economic Instruments and Measures
4.2.3
Advisory/Information Instruments and Measures
4.2.4
Project-based Instruments and Measures
4.3
Exintings Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
4.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
4.5 Information
Sources
Annex 5 Czech Republic
5.1
Policy Strategy and Objectives
5.2
Policy Instruments, Measures and Institutional Arrangements
5.2.1
Regulatory Instruments and Measures
5.2.2
Economic Instruments and Measures
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin
5.2.3
Advisory/Information Instruments and Measures
5.2.4
Project-based Instruments and Measures
5.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
5.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
5.5 Information
Sources
Annex 6 Hungary
6.1
Policy Strategy and Objectives
6.2
Policy Instruments, Measures and Institutional Arrangements
6.2.1
Regulatory Instruments and Measures
6.2.2
Economic Instruments and Measures
6.2.3 Advisory/Information
Instruments and Measures
6.2.4
Project-based Instruments and Measures
6.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
6.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
6.5 Information
Sources
Annex 7 Moldova
7.1
Policy Strategy and Objectives
7.2
Policy Instruments, Measures and Institutional Arrangements
7.2.1
Regulatory Instruments and Measures
7.2.2
Economic Instruments and Measures
7.2.3 Advisory/Information
Instruments and Measures
7.2.4
Project-based Instruments and Measures
7.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
7.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
7.5 Information
Sources
Annex 8 Romania
8.1
Policy Strategy and Objectives
8.2
Policy Instruments, Measures and Institutional Arrangements
8.2.1
Regulatory Instruments and Measures
8.2.2
Economic Instruments and Measures
8.2.3 Advisory/Information
Instruments and Measures
8.2.4
Project-based Instruments and Measures
8.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
8.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
8.5 Information
Sources
Annex 9 Serbia and Montenegro
9.1
Policy Strategy and Objectives
9.2
Policy Instruments, Measures and Institutional Arrangements
9.2.1
Regulatory Instruments and Measures
9.2.2
Economic Instruments and Measures
9.2.3
Advisory/Information Instruments and Measures
UNDP/GEF Danube Regional Project
9.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
9.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
9.5 Information
Sources
Annex 10 Slovakia
10.1
Policy Strategy and Objectives
10.2
Policy Instruments, Measures and Institutional Arrangements
10.2.1
Regulatory Instruments and Measures
10.2.2
Economic Instruments and Measures
10.2.3
Advisory/Information Instruments and Measures
10.2.4
Project-based Instruments and Measures
10.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
10.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
10.5 Information
Sources
Annex 11 Slovenia
11.1
Policy Strategy and Objectives
11.2
Policy Instruments, Measures and Institutional Arrangements
11.2.1
Regulatory Instruments and Measures
11.2.2
Economic Instruments and Measures
11.2.3 Advisory/Information
Instruments and Measures
11.2.4
Project-based Instruments and Measures
11.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
11.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
11.5 Information
Sources
Annex 12 Ukraine
12.1
Policy Strategy and Objectives
12.2
Policy Instruments, Measures and Institutional Arrangements
12.2.1
Regulatory Instruments and Measures
12.2.2
Economic Instruments and Measures
12.2.3 Advisory/Information
Instruments and Measures
12.2.4
Project-based Instruments and Measures
12.3
Existing Programmes and Projects Promoting "GOOD/BEST
AGRICULTURAL PRACTICE"
12.4
Summary and Assessment of the Effectitiveness of the "POLICY MIX"
12.5 Information
Sources
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin
List of Tables
Table 1: Summary of the "Mix" of Policy Instruments used in the UK in 2002 for Controlling Diffuse
Pollution from Agriculture ....................................................................................................... 9
Table 2: Summary of EU Legislation Relevant to Agricultural Pollution Control............................. 13
Table 3: Summary of the "Policy Mix" of Measures Proposed for Promoting BAP in the Central
and Lower DRB Countries.................................................................................................... 26
Table 4: "Policy Mix" for EU Accession Countries: Czech Republic, Slovakia, Hungary and
Slovenia................................................................................................................................. 30
Table 5: "Policy Mix" for EU Pre-accession Countries: Romania, Bulgaria and Croatia ................. 31
Table 6: EU Non-accession Countries: Bosnia-Herzegovina, Serbia-Montenegro, Moldova and
Ukraine.................................................................................................................................. 32
List of Figures
Figure 1: The difference between BAP and BAT .................................................................................. 2
Figure 2: Hypothetical Example of the "Mix" of Policy Tools used to Promote Best Agricultural Practice
for the Management of Manure ................................................................................................ 8
Acronyms and Abbreviations
BAP
Best Agricultural Practice
BAT
Best Available Techniques
CAP
Common Agricultural Policy
DRB
Danube River Basin
DRP
Danube Regional Project
EC
European Commission
EU
European Union
GEF
Global Environmental Facility
GFP
Good Farming Practice
ICM
Integrated Crop Management
ICPDR
International Commission for the Protection of the Danube River
IPM
Integrated Pest Management
UNDP
United Nations Development Programme
WFD
Water Framework Directive
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 1
1
The Concept of Best Agricultural Practice (BAP)
1.1 Introduction
Good/best practices for agriculture have been under development for many years and in many
different countries in response to the concerns of a wide-range of stakeholders about many different
issues, including food production methods, food safety and quality, and the environmental impact of
agriculture.
Stakeholders involved in the development of good/best practices typically include governmental and
non-governmental organisations, farmers, consumers, food processors and retailers etc. all of who
seek to meet a variety of objectives for food quality, production efficiency, rural livelihoods and
environmental benefits. The definition of good/best practices offers a means for these different
stakeholders to promote their objectives within a clear framework that communicates the best
available knowledge on a particular issue or issues. For example, a growing number food processors
and retailers increasingly require farmers to follow Codes of Practice for the production of fresh fruit
and vegetables, cereal crops and livestock in order to achieve their required standards for quality
assurance, consumer satisfaction and profit.
The general concept of good/best practice is also an increasingly important part of introducing and
maintaining minimum environmental standards as the basis of promoting more sustainable agricultural
systems.
Environmental standards are becoming a key part of the European model of agriculture due to
international trade agreements, public environmental concerns and market forces, and are likely to
play a significant role in future agriculture policy. Such standards are necessary to ensure minimum
environmental protection on farmland and comparable production conditions (preventing uneven
competition) across Europe.
Different countries implement such minimum environmental standards in various ways using a variety
of different policy measures and instruments, but conceptually there are three main levels of
environmental performance in agriculture that relate to good/best practice:
"Red
These are the practices by farmers that are considered unacceptable and therefore
Zone"
commonly prohibited by law to protect natural resources, human health etc.
"Blue
This includes the minimum level of environmental management that it is considered
Zone"
"reasonable" to expect a farmer to undertake as part of "usual" farm management and
without expecting any form of compensation/financial assistance. There are significant
variations in the way that "good practice" is defined in different countries, but it is likely to
include respect for environmental legislation (i.e. avoidance of the "red zone"), following
advice from extension services, taking into account scientific and technical progress etc.
"Green This involves a higher level of environmental management practice that delivers greater
Zone"
environmental benefit, but usually at greater "cost" to the farmer which may require some
form of compensatory payment
Best Agricultural Practice in the DRB Context
A significant proportion of the nutrients (nitrogen and phosphorus) that are discharged in the ground
and surface waters of the Danube river catchment come from agriculture. Additionally, the majority
of pesticides detected in water resources in the DRB catchment also come from agricultural non-point
sources.
2
UNDP/GEF Danube Regional Project
The objective of developing a concept of "best agricultural practice" (BAP) under Output 1.2 is to
support the design of new agricultural pollution control policies for the central and lower DRB
countries as well as encouraging compliance with existing and emerging national legislation
(including that driven in many countries by the process of EU accession) that will promote the
greater integration of pollution control considerations into the day-to-day management of crops,
animals and agricultural land by farmers in the central and lower DRB.
For the purposes of this project, the term "best agricultural practice" (BAP) is used only to describe
farm management practices that reduce the risk of pollution occurring from agricultural non-point
sources in the DRB this includes:
1. diffuse pollution occurring as a result of agricultural land-use activities (e.g. application of
mineral fertilisers, manure and pesticides) that are dispersed across a catchment or sub-catchment
with no single discrete source
2. "small point source" pollution arising from multiple, small-scale (and often accidental)
discharges that occur from the many different farming activities that are also dispersed across a
catchment or sub-catchment (e.g. effluent leakage from small-scale livestock farming, poor
disposal of pesticides, run-off of manure from sloping land etc.)
Agricultural point source pollution on the other hand arises from single, discrete sources which are
commonly associated with large-scale animal production units/installations that are regulated by
discharge consent or control.
Because of the industrial nature of these larger livestock units - plus the argument about whether they
should actually be classified as "industrial" emissions it seems appropriate to refer to these farms as
"agro-industrial units" (defined according to criteria based on number of animals) and therefore to also
refer to agro-industrial point source pollution.
The management practices used to control pollution from such units/installations are commonly
referred to as "best available techniques" (BAT) rather than "best agricultural practice" (BAP). These
differences are summarised in Figure 1 below.
Figure 1: The difference between BAP and BAT
Agricultural Non-Point Source
Agricultural Point
Pollution
Source Pollution
Diffuse pollution from
"Small point source"
Controlled/uncontrolled
agricultural land use activities
pollution from multiple,
discharges directly to
undifferentiated sources
water from large-scale
agro-industrial livestock
units/installations
Control through Best Agricultural Practice (BAP)
Control through Best
for fertiliser, manure and pesticide management
Available Techniques
(BAT)
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 3
1.2
Developing the BAP Concept
There are no concrete and universal definitions available for what is or is not best agricultural practice
indeed, there is a risk that it is a potentially confusing term because it is so prone to being interpreted
by different people in many different ways. For example, in the context of the DRB it is important to
clearly distinguish between the concept of BAP and the existing EU concepts of Codes of Good
Agricultural Practice (under the EC Nitrate Directive) and verifiable standards of Good Farming
Practice (under the EC Rural Development Regulation, 1257/1999).
A strict or prescriptive definition of BAP for Output 1.2 has therefore been avoided in this project
instead we have proceeded with the understanding that BAP actually encompasses a broad spectrum or
hierarchy of activities that must be interpreted according to local agronomic, environmental, social
and economic context. It is this hierarchy of activities that forms a clear and common concept for
BAP throughout the DRB countries as shown below:
The higher levels of the hierarchy will involve more sophisticated actions
that:
· entail a significantly greater undertaking by farmers than simple
compliance with prevailing legislation and regulations
· encompass the whole farm and/or agricultural production system, not
just the management/optimisation of inputs
· promote a fundamental re-appraisal of farming's relationship with the
environment that involves the development of more environmentally-
friendly, ecologically-based farming systems
The intermediate levels of the hierarchy are founded upon the
r
c.
understanding that BAP largely involves "common sense" about the need
to apply certain basic principles and practices to the management of a
r
eate
g
y et
successful farming enterprise.
nolo
These basic principles and practices have certain characteristics that
iring g
e
ch
distinguish them:
qu
· they begin with a respect for and compliance with prevailing legislation
y
re
t" to the farmer
and regulations
· they are often common knowledge amongst farmers, but are easily
s, better t
overlooked during the day-to-day challenges of making a living from
mplexit
i
ng "cos
working on the land (especially in the more economically-
n
t skill
disadvantaged rural areas)
ng co
r
eas
· they are capable of being undertaken by any reasonable farmer within
a
si
eme
Inc
the context of his/her local circumstances (cultural, social, economic
and environmental)
Incre
·
manag
· they usually involve some cost for the farmer, but this is minimal and
·
should not require any financial incentive to encourage their uptake
· they often require inputs of information and know-how rather than
inputs of capital or technology
The lowest levels of the BAP hierarchy involve:
· awareness amongst farmers of the polluting effects of certain of their
activities and
· an understanding and willingness by farmers to comply with all
relevant legislation
· no cost for the farmer
4
UNDP/GEF Danube Regional Project
For example, the following simple hierarchy relating to BAP for the collection, storage and application
of manure can be developed:
Prepare a "whole farm" waste management plan
Invest in new manure storage/treatment facilities
Restrict manure application to a maximum rate
that is equivalent to 170 kg N/ha
Only apply manure during or immediately before
periods of active crop growth
When applying manure ensure that an adequate
distance is kept from surface waters
Increasing complexity
requiring greater
Do not apply manure to frozen or snow-covered
management skills etc.
ground
Do not apply manure to sloping land next to a
river
Collect manure from cows housed in the village
do not discard with other household rubbish
Do not discharge manure directly to water
courses, such as rivers, streams and ponds
Obviously not all elements of this hierarchy are relevant in all countries of the central and lower DRB
there has to be some interpretation according to local context. To be effective, any BAP must not
only be technically and economically feasible, it must also be socially acceptable to the farming
community. For example, the social and economic circumstances of many rural communities in
Moldova are very difficult and this will inevitably limit the ability of farmers to adopt the full BAP
hierarchy above indeed, even basic action such as ensuring that manure is collected and returned to
the land rather than discarded in the village rubbish dump with other household waste can be difficult
to encourage when local farmers cannot afford the cost of transporting manure to their fields.
On the other hand, in the Czech Republic we might expect the more commercially-orientated farmers
there to have the willingness and ability to prepare a "whole farm waste management plan" and make
the necessary calculations for restricting manure application to specified, matching fertiliser use to soil
N supply etc. When viewed like this, the proposed concept of Best Agricultural Practice is quite
straightforward and easy to define as:
"...the highest level of pollution control practice that any farmer can reasonably be expected to
adopt when working within their own national, regional and/or local context in the Danube
River Basin"
As such, BAP can be applied as a uniform concept across the whole DRB, but the level of
environmental management/performance that can be expected from farmers in different
regions/countries will vary significantly according to:
a) the agronomic, environmental and socio-economic context in which they are operating
b) the availability of appropriate policy instruments for encouraging farmers to "move up" the
hierarchy and adopt more demanding pollution control practices
c) the availability of appropriate knowledge and other technical resources for supporting farmers to
"move up" the hierarchy and adopt more demanding pollution control practices
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 5
2
Policy Instruments and Measures for Promoting BAP
The ultimate aim of policy-making for agricultural pollution control is to reduce the risk of pollution by
influencing the behaviour of farmers and to improve the management practices they choose to adopt on a
day-to-day basis.
As implied above, the objective of policy strategies for agricultural pollution control in the different
DRB countries should therefore be to encourage farmers to "move up" the BAP hierarchy as far as
possible in the context in which they operate and deliver the highest level of pollution control that it is
feasible for them to do.
The function of available policy instruments and measures for achieving this "shift" can be
summarised as follows:
a) Disincentives for dropping below the minimum level of environmental management practice that
is acceptable in other words, to avoid as many farmers as possible from staying in or entering the
"red zone" of environmental performance
b) Appropriate interventions for promoting and sustaining the minimum level of environmental
management practice (the "blue zone") on as many farms as possible, and
c) Incentives to go beyond the minimum level of environmental management practice and deliver a
higher level of environmental performance in other words, to encourage farmers improve their
management practices still further and enter the "green zone"
Since it is unlikely that a single policy instrument will achieve the necessary "shift" in farmer behaviour,
strategies for agricultural pollution control commonly use a combination of policy instruments the so-
called "policy mix". The different elements of the "policy mix" need to work together to solve the
specific pollution problems that exist with some elements of the "mix" having and effect in the long-term
and others in the short-term. A number of additional factors will also influence the selection of
instruments for the "policy mix", including environmental effectiveness, economic efficiency, equity and
accessibility to farmers, administrative feasibility and cost, and political acceptability. It is also important
to note that the composition of the "policy mix" may need to change over time.
Figure 1 gives a hypothetical example for the "mix" of policy instruments that might be used for
promoting different elements of BAP associated with the collection, storage and management of manure.
These policy instruments include:
1. Regulatory Instruments - these involve the traditional "command and control"-type policy
mechanisms, such as statutory prohibitions and legal sanctions, which form the basis of state
intervention and control in most developed and developing countries. The principal roles of
regulation in agricultural pollution control are to:
a) prohibit those practices with a high risk of causing unacceptable levels of harmful and polluting
substances to be released into the natural environment
b) establish maximum ceilings or standards for acceptable levels of pollution e.g. drinking water
standards for nitrates and pesticides.
2. Advisory/Informative Instruments - these are based upon "communication", including the
provision of information and advice as well as the opportunity for discussion and negotiation
between farmers, policy-makers and other stakeholder groups. Advisory/Informative instruments
are particularly important for controlling agricultural pollution because of the need for farmers to
use information, management ability and ecological understanding to replace or rationalise the use
of agro-chemical inputs and/or other management practices indeed, sustainable agriculture is
often described as "information intensive, rather than chemical intensive".
3. Economic Instruments - these involve the use of financial incentives and disincentives to encourage
or discourage the adoption or continuation of specific agricultural practices.
6
UNDP/GEF Danube Regional Project
Financial Incentives
Financial incentives are potentially very powerful instruments for modifying the behaviour of farmers
- they are flexible, easily-targeted and can be linked to the implementation of both regulatory and
communicative policy instruments to help achieve specific objectives. Furthermore they are unlikely
to require any re-orientation of farmers' attitudes.
Examples of financial incentives include compensatory payments, capital grants, credit or low-interest
loans, as well as the market advantage and/or premium prices obtained for certified and labelled
products from environmentally-friendly farming systems.
Obviously, the success of the financial incentives outlined above at modifying the behaviour of
farmers depends very much upon the ability and willingness of national governments to pay for the
environmental benefits that are accrued. Other incentives can be pursued directly from the general
public as consumers. Environmentally-friendly practices can be encouraged through the adoption of
production methods according to prescribed environmental standards or codes of practice which have
a strong 'market-linkage'. Accredited products with recognisable labels often have a market
advantage and in some cases (e.g. organic food) may attract premium prices which significant
numbers of consumers are willing to pay.
Financial Disincentives
Financial disincentives, such as penalties and fines for non-compliance with legislation, are
commonly designed "...to confront the user (or polluter) of the environment with the full economic
consequences of his/her actions" 1. This approach is derived from the so-called 'Polluter-Pays
Principle' whereby those responsible for causing the negative externalities generated by the harmful
effects of economic activity upon the environment (mainly, but not exclusively, by pollution) are
forced to bear the cost of this damage and/or the costs incurred in controlling the damage.
The "Polluter-Pays Principle" may be applied in agriculture via the government imposition of taxes
on fertilisers and pesticides. In theory this means that the external costs of using these agro-chemicals
(e.g. cost of water treatment by water supply companies) are 'internalised' to become part of the
normal business costs incurred by farmers, thereby encouraging the adoption of less polluting
practices/technologies.
As an example, Table 1 summarises the "mix" of policy instruments (2002) used in the United Kingdom
changing farm management practices and controlling diffuse pollution from agriculture.
Additionally there is the implementation structure to consider - this is the organisational arrangement
within which policy strategies are implemented. The 'actors' within this structure may include farmers and
their representative organisations (e.g. farmers' unions), governmental agencies, sector authorities, private
interest groups and even the general public, while their success at implementing policy will depend upon
the way in which they organise themselves to solve problems of policy implementation, their degree of
power and authority, and the level of resources they are allocated.
1 Scheele, M. (1997). The Decomposition Approach: Spatially Differentiated Analysis and Implementation of
Environmental Strategies. In: Controlling Mineral Emissions in European Agriculture (Eds. Romstad, E.,
Simonsen, J. and Vatn, A.), 41-58. CAB International, Wallingford.
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 7
The implementation structure will obviously vary depending upon the policy strategies and instruments
adopted. For example, regulatory instruments tend to be associated with centralised decision-making and
'top-down' policy implementation. Advisory/informative instruments on the other hand are much more
flexible and offer the potential to encourage decentralised decision-making and 'bottom-up' policy
implementation by:
a) developing common knowledge and understanding between the policy makers, farmers and/or their
representative organisations, and;
b) leaving the final decisions on specific management practices and actions to individual farmers or
groups of farmers.
Many EU Member States increasingly emphasise the need for a "partnership approach" with farmers and
attempt to facilitate changes in the management practices of farmers using more innovative and
participatory advisory tools2.
2 See Annex 2 (LANDCARE Pilot Project) of Project Output 1.3 Report on Developing Pilot Projects for the
Promotion of Best Agricultural Practice in the Danube River Basin (held in Bucharest, 19-20 January 2004)
8
UNDP/GEF Danube Regional Project
Figure 2: Hypothetical Example of the "Mix" of Policy Tools used to Promote Best Agricultural Practice for the Management of Manure
Impact on Farm
Typical Management Practices
Examples of Relevant
Level of Environmental Management
Necessary Policy Intervention
Business
(e.g. manure management)
Policy Tools
"Green Zone"
· Preparation of "whole farm"
· Agri-environment
Incentives to go
Higher level of level of environmental
waste management plan
payments
beyond minimum level
management practice that delivers greater
· Investment in new
· Capital grants for
of environmental
environmental benefit, but usually at greater
storage/treatment facilities
better technology
management practice
"cost" to the farmer
· Premium prices for
quality products etc.
"Blue Zone"
· Restrict manure application to
· Advisory services
Minimum level of environmental
Increasing
a maximum rate of 170 kg N
linked to progressive
management practice that it is "reasonable"
management
per hectare per year
and well-funded R&D
to expect a farmer to undertake as part of
complexity
· Restrict manure application to
programmes
"usual" farm management and without
requiring more
periods of active crop growth
· Specialist extension
expecting any form of compensation or
information,
· Do not apply manure to
techniques e.g. "local
financial assistance. There are likely to be
greater skill,
sloping land next to a river
catchment
significant variations in the way that this is
better
· Collect manure from all cows
Appropriate
management groups"
defined in different countries, but it is likely
technology etc.
in the village and apply to
interventions for
· Decision-making tools
to include respect for environmental
and often
farmland (do not discard
promoting minimum
· "Cross-compliance"
legislation, following advice from extension
greater cost for
manure with other household
level of environmental
with government
services, taking into account scientific and
the farmer
rubbish)
management practice
support payments
technical progress etc.
· Codes of Good
Practice
"Red Zone"
· Discharging manure directly
Disincentives for
· Legislation including
dropping below minimum
Unacceptable management practices that
to water courses
improved enforcement
level of environmental
are commonly prohibited by law to protect
· Financial penalties and
management practice
natural resources, human health etc.
other sanctions
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 9
Table 1: Summary of the "Mix" of Policy Instruments used in the UK in 2002 for Controlling Diffuse
Pollution from Agriculture
Disincentives for Dropping Below Minimum Level of Environmental Management
Advisory
· On-farm Advice - Environment Agency provides advisory support to farmers in high risk
Instruments
areas to promote awareness of pollution control legislation and the likely cost of non-
compliance
Economic
· Enforcement Fines - Environment Agency imposes fines (up to 30,000 EURO) on farmers
Instruments
prosecuted for causing water pollution
Regulatory
· Regulatory Controls numerous national legislation regulating agricultural emissions,
Instruments
activities, technologies and substances in relation to water pollution. Key items of EU
legislation transposed into national legislation include: Nitrates Directive, IPPC Directive,
Groundwater Directive, Environmental Impact Assessment Directive, Sewage Sludge
Directive and preparations for the Water Framework Directive
Interventions to Promote Minimum Level of Environmental Management
Advisory
· On-farm Advice a variety of on-farm advice is currently provided free of charge, including
Instruments
advice on farm waste management plans within selected river catchments and advice on
nutrient planning to farms going through organic conversion
· Codes of Good Agricultural Practice these are aimed at the protection of soil, water and
air. They are designed to help farmers avoid causing pollution from different agricultural
sources and include a range of advice and information that is specifically relevant to the
control of diffuse pollution from agriculture
· Other Written Advice - various advice booklets on the subject of nutrient and waste
management, including regularly updated fertilizer recommendations for all crops
· Training - a vocational training scheme for land managers offering part-funding for courses
provided by approved trainers, exchange visits, etc.
· Decision tools - a number of decision tools have been developed to help farmers with different
aspects of nutrient management (e.g. fertiliser application rates, N availability in manures,
etc.).
· Promote/facilitate information exchange between farmers the Government facilitates
exchange of information through demonstration farms (e.g. there are four that are used to
promote better manure management) and sponsorship of local workshops etc.
· Local diffuse pollution initiatives - a number of local advisory and awareness-raising
initiatives have operated in areas where diffuse pollution is a problem. These initiatives adopt
a participatory/partnership approach, focus on local issues, and integrate a range of advisory
approaches (awareness-raising, information exchange, demonstrating best practice, offering
on-farm advice)
· Research & Development the Government sponsors scientific research into diffuse
pollution and nutrient management as policy and information needs arise
Economic
· Grant Scheme - farmers within Nitrate Vulnerable Zones are eligible for a "farm waste
Instruments
capital grant" to meet the costs of complying with regulatory requirements
· Cross Compliance farmers receiving agri-environment and LFA payments must follow
verifiable standards of Good Farming Practice on their whole farm these which include some
reference to manure management
· Product labelling/environmental branding - a number of quality assurance schemes exist
for different types of farming. These include some environmental requirements and give
farmers some market advantage, particularly with the large multiple retailers
Incentives to go Above Minimum Level of Environmental Management
Economic
1. Agri-environment Payments some agri-environment schemes promote landscape and
Instruments
biodiversity features (e.g. conversion of arable land to permanent pasture) that have benefits
for reducing diffuse pollution
10
UNDP/GEF Danube Regional Project
3
Current Status of Policies for Agricultural Pollution Control in DRB
Countries
In order to be effective at improving the management practices of farmers, policies for reducing
agricultural pollution should include three effective components - a policy strategy (or number of
strategies), policy instruments and an implementation structure. A review3 was undertaken to develop
understanding of the existing policy context regarding agricultural pollution control in the 11 central
and lower DRB countries the main findings were:
Strategies - all national experts reported some goals for water protection in their countries, although
there is a general lack of clear and targeted strategies for water protection that integrate different
policy measures and show the necessary path to the achievement of indicated goals. Most progress
towards the development of comprehensive water protection strategies is made in those countries
preparing for EU accession from May 2004.
Regulatory Instruments many of the main agricultural pollution issues are addressed by existing
regulatory instruments in the DRB countries, with the most extensive coverage of issues in those
countries preparing for EU accession in 2004. In most other countries, existing regulatory instruments
tend to be rather general with relatively few specific regulatory instruments in place. Consequently
there is much potential to prepare more targeted instruments to prevent water pollution through the
control of specific farming practices also to improve compliance and enforcement.
Economic Instruments - economic instruments may be incentives or disincentives and can be an
important tool for modifying the management practices of farmers and reducing agricultural pollution.
However, effective measures (or packages of measures) need to be well-designed and balanced as
well as successfully implemented. Not surprisingly, the economic instruments used in the DRB
countries are mainly disincentives due to the lack of financial resources to introduce incentive
schemes. Where economic instruments are in place they do not currently address all pollution issues
in all countries. The number of incentive measures in the four acceding countries (Czech Republic,
Slovakia, Slovenia and Hungary) is expected to increase in 2004 with EU accession and the
availability of EU co-financing for rural development measures, such as agri-environment
programmes.
Advisory/Information Instruments - the transfer of knowledge and information to farmers via
advisory/informative instruments can play a key role in changing the management practices of farmers
and reducing agricultural pollution. However, the most frequent limitation upon this type of
instrument for controlling agricultural pollution in the DRB is that the actions taken are too small with
insufficient staff and financial resources. There is large potential to further develop
advisory/information instruments in all countries.
Based upon the results of the policy review, the following general recommendations were made for all
central and lower DRB countries:
· to design more targeted and integrated strategies for the control of agricultural pollution
· to improve the control and enforcement of regulatory instruments for agricultural pollution control
· to put more emphasis upon the design and implementation of advice/information measures for
agricultural pollution control
· to develop within available resources financial incentives as appropriate economic instruments for
promoting agricultural pollution control
3 Report from Project Output 1.2: Inventory of Policies for Control of Water Pollution by Agriculture in the Danube
River Basin Countries
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 11
· to promote organic farming and integrated crop management techniques as viable alternatives to
the use of agrochemicals
· to design and implement national codes of good agricultural practice for fertilizer, manure and
pesticide use
· to increase farmer and advisor awareness of the importance of agricultural pollution control
· to support capacity building amongst relevant stakeholders for the implementation of agricultural
pollution control policies
4
Opportunities for Policy Reform in Relation to EU Enlargement
This project work is undertaken during a period of great change in the countries of the central and
lower Danube River Basin (DRB) with Hungary, Czech Republic, Slovakia and Slovenia in the final
stages of preparation for accession to the EU in May 2004, followed by Bulgaria and Romania and
possibly Croatia preparing for EU accession in 2007 or later4. The policy-making context for
agricultural pollution control in these DRB countries is therefore undergoing significant change and
preparation for joining the EU is currently a major driving force for the reform of agricultural
pollution control policies in the 6 countries mentioned. This includes the requirement to:
· harmonise national legislation with EU regulatory instruments
· prepare to implement the Common Agricultural Policy (CAP), including rural development
measures
· develop the principle of "environmental cross compliance" in other words, to set certain
environmental standards that farmers must meet in order to be eligible for CAP support
4.1
Harmonisation of National Legislation with EU Regulatory Instruments
The DRB countries preparing to join the EU have the huge task of harmonising their national
legislation with the complex range of EU regulatory instruments.
Table 2 presents a summary of the legislation relevant to reducing the risk and impact of agricultural
pollution. It should be noted that some of this legislation has so-far had relatively little impact upon
reducing agricultural pollution for example, the EU Nitrates Directive (No. 91/676) has consistently
failed to meet its environmental objectives because of both considerable resistance by the EU
agricultural community and poor implementation by many Member States5.
It is now hoped that the rules of the Water Framework Directive (No. 2000/60)6 will provide a more
comprehensive framework for agricultural pollution control, as well as assisting the implementation of
existing "single issue" legislation such as the Nitrate Directive. The Water Framework Directive
(WFD) was adopted in December 2000 and arises out of a long debate concerning the limitations of
existing EU water legislation. The Directive requires that all surface waters (rivers, lakes and coastal
waters) and ground waters are managed in order to meet `good ecological status'. This should be
through the use of River Basin Management Plans7 which will integrate existing EU measures into a
programme of basin-specific measures which are appropriate to protecting the local water environment
from the human pressures upon it.
4 Croatia is also preparing its preliminary application for EU membership
5 European Commission (2002). Implementation of Council Directive 91/676/EEC concerning the protection of
waters against pollution caused by nitrates from agricultural sources: Synthesis from year 2000 Member States
reports. Report No. COM(2002) 407 final, Brussels, 17.07.2002
6 EC Directive No. 2000/60/EC establishing a framework for Community action in the field of water policy, OJ
L327 (22.12.2000)
7 Bloch, H. (2000). EU policy on nutrients emissions: legislation and implementation. In: Wastewater and EU-
Nutrient Guidelines, pp 52-59. International Water Association, London.
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UNDP/GEF Danube Regional Project
There is debate within many Member States on what the implications of the WFD will mean for
agriculture - in particular, how the Member States (including the new Member States from the DRB)
will use appropriate policy instruments to tackle the significant pressures upon water resources that
arise from agriculture, including the risk of pollution. Currently there is much interest in using the
policy tools available in the Common Agricultural Policy (CAP) to support and implement the WFD8
including agri-environment payments and "environmental cross-compliance" (see below).
8 DG Environment (2003) - Working Document on The Water Framework Directive (WFD) and tools within the
Common Agricultural Policy (CAP) to support its implementation
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 13
Table 2: Summary of EU Legislation Relevant to Agricultural Pollution Control
Pollution
Title of Legislation
Obligations
Issue
Directive 76/464/EEC on pollution
The Directive sets a framework for the elimination of reduction of
Pesticides
caused by certain dangerous
pollution of inland, coastal and territorial waters by particularly
substances discharged into the aquatic
dangerous substances. It identifies 129 dangerous substances and
environment of the Community
requires Member States to eliminate or reduce pollution by these
substances, including a large number of active ingredients used in
agricultural pesticides.
Directive 79/117/EEC prohibiting the
Directive 79/117 - the 'Prohibition Directive' - bans or restricts the Pesticides
placing on the market and use of plant
use of pesticides containing certain active ingredients and to
protection products containing certain
ensure that those that are marketed are of a specified quality and
active ingredients
appropriately classified, packaged and labelled.
Directive 80/68/EEC on the protection
The Groundwater Directive establishes a framework for the
Pesticides
of groundwater against pollution
protection of EU groundwater by prohibiting discharge to ground
caused by certain dangerous
water of the most detrimental substances. It places mandatory
Point Source
substances (the Groundwater
obligations on farmers relating to the disposal of pesticide and
Pollution
Directive)
other farm wastes.
Directive 80/778/EEC on the quality of The Drinking Water Directive (80/778) lays down standards for
Pesticides
water intended for human consumption the quality of water intended for drinking or for use in food and
(the Drinking Water Directive) to be
drink manufacture in order to protect human health. It does not
Nutrients
replaced by Directive 98/83/EC from
impact upon farmers directly, but sets maximum admissible
(including
2003
pesticide residue levels and maximum admissible concentrations
fertilisers and
of nitrate in drinking water that water suppliers must comply with. manures)
Directive 91/414/EEC concerning the
Directive 91/414 - the 'Authorisation Directive' - introduces a
Pesticides
placing of plant protection products on Community system to harmonise the authorisation and placing on
the market
the market of plant protection products, i.e. pesticides, to protect
human health and the environment. It places no mandatory
obligations on farmers. The obligation is on the regulatory system
to only approve products that pose an acceptable risk to human
health and the environment. Detailed criteria and protocols have
been devised.
Directive 2000/60/EC establishing a
The Water Framework Directive (WFD) has the overall
Pesticides
framework for Community action in
environmental objective of achieving 'good water status'
the field of water policy (the Water
throughout the EU by 2010 and for it to be maintained thereafter.
Nutrients
Framework Directive)
It sets out to establish a Community framework for the protection
(including
of surface and ground waters across the EU through a common
fertilisers and
approach, objectives, principals and basic measures based upon
manures)
the river basin as the primary administrative unit for the purposes
of water management. The Directive will have widespread and
Point Source
significant impacts and although it places no direct obligation on
Pollution
farmers, they will have to met certain new standards.
Directive 91/676/EEC concerning the
The objectives of the Directive are to ensure that the nitrate
Nutrients
protection of waters against pollution
concentration in freshwater and groundwater supplies does not
(including
caused by nitrates from agricultural
exceed the limit of 50 mg NO3- per litre as imposed by the EU
fertilisers and
sources
Drinking Water Directive (above) and to control the incidence of
manures)
eutrophication. The Directive requires individual Member States
to develop a Code of Good Agricultural Practice; designate zones
vulnerable to pollution by nitrates, and establish and implement
Action Programmes within these zones to prevent further nitrate
pollution.
Directive 96/61/EC on Integrated
This Directive aims to reduce air and water pollution by applying
Point Source
Pollution Prevention and Control
stronger controls to the regulation of emissions from a broad
Pollution
(IPCC Directive)
range of industrial activities, including pig and poultry producers.
All new or substantially altered pig and poultry units housing
more than 750 sows, 2,000 finishers over 30 kg or 40,000 birds
will require an operating permit that will detail those practices on
the unit that may give to polluting emissions, their environmental
impact and the `Best Available Techniques' required to control
emissions.
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4.2
Implementation and Reform of the Common Agricultural Policy (CAP)
The main policy instrument for supporting farmers in the EU is the Common Agricultural Policy
(CAP). This is a very important policy instrument that continues to undergo a series of radical reforms
that will impact upon all farmers in the EU, including those in the new Member States of the DRB.
The first major reform of the CAP was the so-called `Agenda 2000' proposals which took effect for
the period of 2000 2006. The Agenda 2000 proposals established a range of rural development
measures to the CAP for the first time the so-called "second pillar" of the CAP as defined by the
Rural Development Regulation No. 1257/19999. Amongst other things, this makes provision for
Member States to encourage more environmentally-friendly farming methods, including practices that
reduce the risk of agricultural pollution, by:
a) offering farmers grant-aided investment (up to 50%) in equipment and facilities that helps to
"...preserve and improve the natural environment" for example, by:
· purchasing up-to-date equipment to spread manure and apply fertilisers or pesticides in a more
environmentally-friendly way
· improving manure storage facilities (e.g. to meet the requirements of the Nitrate Directive)
b) training farmers for the "...application of production practices compatible with the maintenance
and enhancement of the landscape and the protection of the environment" this includes:
· training for organic farming or integrated crop management practices
· training for farming management practices with a specific environmental protection objective
c) funding national/regional agri-environment schemes that offer payments to farmers to adopt
"...agricultural production methods designed to protect the environment and to maintain the
countryside" this is a very important tool for introducing environmentally-friendly farming
methods and includes support for a range of actions contributing to the control of agricultural
pollution, including conversion to organic farming.
EU Member States began implementing the first agri-environment programmes in the 1980s and
1990s, and today such programmes cover over 20% of all agricultural land in the EU. Agri-
environment payments are not a subsidy - they are effectively promoting a form of "alternative
economic activity" with farmers paid as "environmental managers" in addition to their usual role
as food producers.
The potential for agri-environment schemes to contribute to a wide range of rural development
objectives, including agricultural pollution control, is recognised by the fact that they are now the only
compulsory measures for EU Member States to introduce under Regulation 1257/1999. It will
therefore be obligatory upon accession for all new Member States to introduce an EU co-financed
agri-environment scheme that offers payments per hectare to farmers (for a minimum of 5 years) who
voluntarily change their methods of farming in ways to benefit the environment.
Of all the tools of the CAP, agri-environment measures seem the most useful for supporting
implementation of the WFD however, EC rules currently prevent agri-environment payments being
made to farmers for complying with the requirements of EC legislation. This is a key issue that needs
to be resolved since the resources available for agri-environment measures, including those with a role
in controlling diffuse pollution from agriculture, are proposed to increase following the recent "mid-
term review" of the CAP10.
9 Council Regulation (EC) No 1257/1999 of 17 May 1999 on support for rural development from the framework,
taking account of experience gained using European Agricultural Guidance and Guarantee Fund (EAGGF) and its
implementing regulation Commission Regulation (EC) No 445/2002 of 26 February 2002 laying down detailed
rules for the application of Council Regulation (EC) No 1257/1999 on support for rural development from the
European Agricultural Guidance and Guarantee Fund (EAGGF)
10 In June 2003, EU agriculture ministers agreed a further package of fundamental reforms following the "Mid-
term Review" of the CAP that it is claimed will completely change the way that the EU supports its farm sector.
The key elements of the new, reformed CAP that will enter into force during 2004 and 2005 are: i) a single farm
payment for EU farmers that is independent from production and linked ("cross-compliance") with defined
environmental, food safety and animal welfare standards, as well as the requirement to keep all farmland in good
agricultural and environmental condition; ii) a strengthened rural development policy with more EU money and
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 15
Additionally, the "mid-term review" of the CAP introduces a new "meeting standards" measure that
will aim to help farmers adapt to the introduction of EU standards concerning the environment, public,
animal and plant health, animal welfare and occupational safety. This may also be useful for
promoting pollution control by farmers in the new Member States of the DRB.
While the 4 DRB countries (Czech Republic, Slovakia, Hungary and Slovenia) joining the EU in 2004
will shortly be implementing national agri-environment programmes, 2 DRB countries (Romania and
Bulgaria) are unlikely to join the EU until at least 2007. In these latter countries, financial assistance
is also available for developing and implementing "pilot" agri-environment measures with SAPARD
co-funding the Special Pre-accession Programme for Agriculture and Rural Development.
4.3
Developing the Concept of "Environmental Cross Compliance"
The concept of "environmental cross-compliance" in agriculture (setting conditions which farmers
have to meet in order to be eligible for direct government support) has been growing in importance
since the 1970s, but was not introduced in the EU until the "Agenda 2000" reforms. This included:
a) allowing Member States, if they chose, to attach environmental conditions to direct payments
made to farmers under the `first pillar' (market support measures) of the CAP
b) requiring Member States to define "verifiable standards of Good Farming Practice (GFP)"11 that
all farmers receiving agri-environment and less-favoured payments under the Rural Development
Regulation must follow across the whole of their farm. GFP is a relatively new concept to emerge
within the EU12 and its practical implementation is still being tested in many Member States with
the interpretation of what constitutes a "reasonable" standard of farming varying from country to
country.
There is currently little information available on the implementation of voluntary cross-compliance by
Member States, but following the "mid-term review" of the CAP all Member States will in future be
required to issue farmers with a list of "minimum environmental requirements" that must be followed
if they want to receive direct support payments under the Single Area Payment Scheme (SAPS)
proposed from 2004.
This will be a potentially useful tool for reducing certain pollution risks although inevitably the true
extent of its influence upon reducing pollution will depend upon Member State's commitment and
willingness to fully and effectively implement this new policy instrument.
measures to promote environmentally-friendly farming methods, as well as a new measure specifically intended
to help farmers to meet EU production standards, and; iii) a reduction in direct payments ("modulation") for bigger
farms to finance the new rural development policy
11 Under Section 9 of EC Regulation No. 1750/1999, which sets out the rules for several measures including agri-
environment, it is stated that: "Usual good farming practice is the standard of farming which a reasonable farmer
would follow in the region concerned.....Member states shall set out verifiable standards in their rural development
plans. In any case, these standards shall entail compliance with general mandatory environmental requirements."
12 It should be noted that GFP is not equivalent to the Code of Good Agricultural Practice (CoGAP) that Member
States must introduce in accordance with the requirements of the EU Nitrates Directive 676/91.
16
UNDP/GEF Danube Regional Project
5
DRB-wide Strategic Aims, Objectives and Measures for Policy
Reform
The following strategic aims, policy objectives and measures for policy reform and the introduction of
best agricultural practice (BAP) in the central and lower DRB countries are formulated on a basin-
wide context and should be adopted and adapted according to national/regional level context.
There are six Strategic Aims proposed:
1. To reduce pollution from mineral fertilisers and manure
2. To reduce pollution from pesticides
3. To improve compliance and enforcement of regulatory instruments for agricultural pollution
control
4. To develop appropriate economic instruments for agricultural pollution control
5. To develop the capacities of agricultural extension services for agricultural pollution control
6. To promote organic farming and other low input farming systems
Policy Objectives are listed under each Strategic Aim. There are a total of eleven Policy Objectives
proposed for national governments to adopt:
1. Develop greater understanding at a national/regional level of the relationship between agricultural
practice (fertiliser, manure and land management) and the risk of diffuse nutrient pollution
2. Develop appropriate policy instruments and institutional arrangements for promoting better
management of fertilisers and manures
3. Reduce the levels of harmful active substances used for crop protection by prohibiting and/or
substituting the most dangerous priority pesticides with safer (including non-chemical) alternatives
4. Improve controls on the use and distribution of pesticides
5. Encourage the proper use of pesticides by farmers and other operators
6. Improve the use of regulatory instruments to prevent water pollution through the control of
specific farming practices
7. Develop and introduce appropriate economic instruments to encourage implementation of BAP
8. Review and adapt the mandate and structure of agricultural extension and advisory services
9. Develop the capacity of agricultural extension and advisory services for the promotion of BAP
10. Develop and support pilot projects for the promotion of BAP by agricultural extension and
advisory services
11. Promote certified organic farming and other low input farming systems as viable alternatives to
the conventional use of mineral fertilisers and pesticides
Appropriate measures for policy reform and the introduction of best agricultural practice (BAP) are
listed under each of the Policy Objectives and the overall "policy mix" arising from these measures is
summarised in Table 3.
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 17
6
Aim 1: To Reduce Pollution from Mineral Fertilisers and Manure
Despite the relatively low levels (compared to many EU Member States) of mineral fertiliser and
manure currently applied to agricultural land in the central and lower DRB region, national
governments should take seriously the risk of diffuse pollution arising from fertiliser and manure
application particularly as the economic conditions of agriculture in the region improve.
The following objectives relating to fertiliser and manure application are recommended for all national
strategies aiming to control nutrient pollution from agriculture. Comments are also included on policy
instruments that should be adopted where appropriate to national context13:
Objective 1: Develop greater understanding at a national/regional level of the relationship
between agricultural practice (fertiliser, manure and land management) and the
risk of diffuse nutrient pollution
1.1 Establish Progressive and Well-funded Research Programmes whilst scientific
understanding of nutrient losses from agricultural land and the related transport processes to
ground and surface waters has increased in recent years this cannot be applied uniformly across
the DRB for the development of good/best practice. Country/regional specific guidance for
farmers must be based upon an understanding of the behaviour of nutrients in the specific
agronomic, environmental and socio-economic context of each country. For example:
· the nutrient content of animal manures need to be quantified to aid more precise application
· the nutrient losses from different components of the farm system to be measures and the
causes of these losses established
· the underlying soil processes affecting nutrient availability (e.g. soil mineralisation) need to
be better understood
Objective 2: Develop appropriate policy instruments and institutional arrangements for
promoting better management of fertilisers and manures
2.1 Raise Farmer Awareness of Good Practice for Fertiliser and Manures - simple and easy to
understand information materials, combined with well-targeted publicity campaigns, can be very
effective at raising farmers' awareness of the importance of improving the management of
fertilisers and manures a key message to communicate is that better nutrient management
increases productivity, saves money and improves profitability.
2.2 Develop and Promote National Codes of Good Practice for Fertiliser and Manure Use
national authorities should agree upon clear and simple codes of voluntary good practice for
fertiliser and manure management. This should be specific to national context and ideally linked
to/derived from progressive and well-funded research programme (see 1.1 above)
13 Not all policy instruments are appropriate to all countries
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UNDP/GEF Danube Regional Project
7
Aim 2: To Reduce Pollution from Pesticides
The national governments of all central and lower DRB countries should aim to effectively control
pesticide pollution in order to minimise the risks presented to human health, the quality of
environmental resources and the integrity of natural ecosystems in the region.
The following objectives are recommended for all national strategies aiming to control pesticide
pollution from agriculture, together with comments on policy instruments that should be adopted
where appropriate to national context (not all policy instruments are appropriate to all countries):
Objective 3: Reduce the levels of harmful active substances used for crop protection by
prohibiting and/or substituting the most dangerous priority pesticides with safer
(including non-chemical) alternatives
3.1 Pesticide Ban - the use of Atrazine, Lindane, Diuron and Endosulfan need to be banned
immediately. Atrazine is the pesticide most often detected in the Danube basin, Lindane, Diuron
and Endosulfan are toxic and persistent pesticides
3.2 Pesticide Phase-out - the use of all other priority pesticides, which are authorised should be
reduced to a minimum, and their use should be phased out if possible and substituted by less-
dangerous pesticides, including non-chemical alternatives. Considering the current low levels of
pesticide use and a lower dependency of farmers upon these chemicals in the DRB regions, the
targets for further pesticide reduction can be ambitious
3.3 Pesticide Cut-off Criteria - in order to prevent the replacement of the priority pesticides which
are going to be banned or phased out with other hazardous pesticides, cut-off criteria for the
approval of other pesticides need to be defined. Pesticides with distribution coefficients (Koc )
below 300g/l (low absorption to soil, prone to leaching and run-off) and a half life greater than
20 days need to be regulated (prohibition, taxes and transferable permits are possible policy
tools). Persistent pesticides should not receive authorisation.
Objective 4: Improve controls on the use and distribution of pesticides
4.1 Monitor Pesticide Trade - retailers, importers and distributor should be required to supply
information on the amounts of all pesticide sold. Retail sellers need to keep records of their sales
of pesticide products and to submit annual reports to national authorities
4.2 Control Pesticide Trade - all central and lower DRB countries must work towards stopping the
uncontrolled and illegal trade of pesticides. The authorities on the borders should receive
training on the issue of illegal pesticide trade. National legislation should enable authorities to
effectively prosecute those selling illegal pesticides and to penalise them with high fines
4.3 Monitor Pesticide Use effective monitoring of pesticide use at a farm level is an essential tool
for improving the control of pesticide use and distribution, as well as assessing environmental
risks, developing non-chemical alternatives etc. Uniform record keeping by farming is essential
for a functioning pesticide monitoring system. National regulation must require that pesticide use
records are a) kept by all pesticide applicators (as in the Czech Republic and Slovakia)
according to certain minimum standards and b) reported to the relevant authorities
4.4 Elimination of Obsolete Pesticides all effort must be made to immediately secure and remove
stockpiles of obsolete pesticides
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 19
Objective 5: Encourage the proper use of pesticides by farmers and other operators
5.1 Raise Awareness about Pesticide Misuse simple and easy to understand information
materials, combined with well-targeted publicity campaigns, can be very effective at raising
farmers' awareness of the dangers of improper pesticide use and the importance of key issues
such as the safe storage, handling and disposal of pesticide products. Retail stores, extension
services and other organisation working with farmers can serve as effective distributors of
information material.
5.2 Develop National Codes of Good Practice for Pesticide Use national authorities should
agree upon clear and simple codes of good crop protection practice when using pesticides.
There are numerous frameworks for such codes, but as a minimum they should provide guidance
to farmers on:
· Basic elements of crop protection
· Choice of available chemicals for crop protection, including obsolete/illegal pesticides
· Integrated crop management and non-chemical alternatives for weed, pest and disease
control
· Quantity and types of pesticide product to use
· Pesticide storage
· Use of spray equipment, including cleaning equipment
· Disposal of surplus pesticides and spray mixture (diluted pesticide)
· Disposal of empty pesticide containers
· Records of application
· Protective clothing and emergency procedures
5.3 Mandatory Farmer Training on Pesticide Use - comprehensive training is the most important
instrument to prevent pesticide pollution at a farm level. All farmers and other operators (e.g.
contract workers) who wish to purchase and apply pesticides should be required to have a license
confirming that they have participated in an approved training programme. As a minimum,
training should highlight the possible adverse effects of pesticides and promote the National
Code of Good Practice for the storage of pesticides, safe handling and application of pesticides,
correct use of spraying equipment, disposal of unused pesticide and containers, and record
keeping (see above)
20
UNDP/GEF Danube Regional Project
8
Aim 3: To Improve Regulatory Instruments for Agricultural
Pollution Control
Many of the main agricultural pollution problems in the DRB countries are addressed by existing
regulatory instruments, with the most extensive coverage of issues in those countries preparing for EU
accession in 2004. In many countries there is therefore much potential to prepare more targeted
instruments to prevent water pollution through the control of specific farming practices. Additionally,
a major problem reported in all countries is the low level of compliance by farmers and the limited
enforcement of legislation by statutory agencies.
The following objective is recommended for all national strategies aiming to reduce agricultural
pollution and should be adapted to national context:
Objective 6: Improve the use of regulatory instruments to prevent water pollution through the
control of specific farming practices
6.1 Develop More Targeted Regulatory Instruments for Agricultural Pollution Control
instead of addressing the causes of agricultural pollution through general environmental or water
protection legislation, more targeted regulatory instruments should be developed to prevent
water pollution through the control of specific farming practices. The introduction of new
regulations for the control of agricultural pollution often requires the re-orientation of traditional
attitudes within the farming community in order to accept the new "moral authority" (sanctions
and controls) being imposed upon their businesses. All new regulations should therefore be
introduced in combination with appropriate information and advice
6.2 Promote Greater Compliance with Agricultural Pollution Control Legislation farmers
must be made more aware via information campaigns and publications, extension and advisory
services etc. of the prevailing pollution control legislation in their countries, including the
reasons for the existence of this legislation and the consequences of non-compliance
6.3 Improve Enforcement of Agricultural Pollution Control Legislation even where well-
developed regulatory instruments exist, their impact upon agricultural pollution control
commonly remains limited by the poor level of enforcement by statutory agencies.
Consequently many farmers choose to ignore the restrictions upon certain practices because the
risk of conviction is very low, whereas the cost of compliance and appropriate alternative action
is often relatively high. National governments must allocate adequate resources to the statutory
agencies responsible for the enforcement of pollution control legislation, this is a particular
priority in those regions where water resources are at greatest risk of pollution from agriculture
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 21
9
Aim 4: To Develop Appropriate Economic Instruments for
Agricultural Pollution Control
Economic instruments (financial incentives and disincentives) are potentially powerful tools for
modifying the behaviour of farmers and promoting the adoption of more environmentally-friendly
farming methods although the use of financial incentives inevitably remains limited by the ability
and willingness of national governments to pay for the incentives provided.
The following objectives are recommended for all national strategies aiming to reduce agricultural
pollution and should be adapted to national context (particularly with regard to EU accession and
the availability of resources for the introduction of financial incentives):
Objective 7: Develop and introduce appropriate economic instruments to encourage
implementation of BAP
7.1 Use Capital Grant Schemes to Promote Good Practice an important obstacle to improving
the management of fertiliser, manures and pesticides in the central and lower DRB countries is
the outdated farm machinery and poor manure storage facilities found on many farms. Capital
grants normally involve one-off payments for investment in specific tasks or facilities (e.g. waste
handling and storage) that have environmental benefits for example, the purchase of more
modern farm machinery and better manure storage and handling facilities that improve the
ability of farmers to a) comply with regulatory obligations and b) adopt better management
practices. However, unless grant rates are 100% (i.e. none of the cost is shared by the farmers)
their uptake can be limited by the reluctance of farmers to meet the additional costs that are not
covered by the grant under these circumstances it is also important to identify the economic
benefits to the farmer
7.2 Use "Cross Compliance" to Promote Good Practice where government schemes are
providing support to farmers then the principle of "environmental cross-compliance" can be
applied. This is most relevant in those countries joining the EU in May 2004 and involves the
establishment of certain conditions/standards that farmers have to meet in order to be eligible to
receive government support. This approach can easily be adapted to the promotion of good
practice for fertiliser and manure management.
7.3 Use Compensatory Payments to Promote Good Practice where resources are available,
regional/national schemes should be developed to compensate farmers for the income lost and
additional costs accrued arising from the adoption of more environmentally-friendly farming
practices including improvements in fertiliser, manure and pesticide use and management.
This is particularly relevant in those countries joining the EU in May 2004 since these countries
will obliged under EU to implement such schemes under the so-called EU Rural Development
Regulation
7.4 Use Economic Instruments to Promote Organic Farming and ICM farmers converting to
organic farming and ICM techniques can incur certain significant additional costs associated
with reductions in input, establishment of new crop rotations, adoption of new technologies etc.
These costs can be a significant obstacle to farmers deciding making the transition from a
conventional farming system. Where funds are available, national governments should
encourage farmers to convert to organic farming and ICM by offering appropriate levels of
compensatory payment. Since organic farmers often have problems to sell or export their
products, the marketing of organically-grown products should also be supported by
governmental campaigns and action.
7.5 Apply Appropriate Financial Disincentives including penalties and fines for non-compliance
with legislation
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10
Aim 5: To Develop the Capacity of Agricultural Extension Services
for Agricultural Pollution Control
The national governments of all central and lower DRB countries should review the mandate and
structure of agricultural extension service to respond to the new requirements of best agricultural
practices to assure rational application of mineral fertiliser and manure and to effectively control
pesticide use. Extension services should be aware of new legislation, be able to advise farmers on
economic incentives (but also on fines in case of non-compliance) and where appropriate promote
organic farming.
The following objectives are recommended for all national strategies aiming at reinforcing the
capacity of agricultural extension services to support the promotion of best agricultural practice and
should be adapted to national context:
Objective 8: Review and adapt the mandate and structure of agricultural extension and
advisory services
8.1 Re-orientate Agricultural Extension and Advisory Services Towards the Promotion of BAP
- agricultural extension services play a key role in raising awareness and improving the technical
skills of farmers and therefore have the potential as key actors in the promotion of good practice
for fertiliser and manure management, pesticide use and land management. However, most
agricultural extension services and advisors are orientated towards the encouragement of
increased farm output and enhanced business profitability rather than environmental protection
and sustainable resource management. Governments need to re-orientate national agricultural
extension services and advisers towards the promotion of more environmentally-friendly
management practices, including those that reduce the risk of water pollution.
Objective 9: Develop the capacity of agricultural extension and advisory services for the
promotion of BAP
9.1 Increase Financial Support for Agricultural Extension and Advisory Services under-
funding is one of the key limitations upon the capacity of most agricultural extension and
advisory services in the central and lower DRB countries
9.2 Develop Appropriate Institutional Frameworks for the Promotion of BAP - including the
link to progressive and well-funded research programmes (see 1.1 above)
9.3 Training for Extension Workers/Advisers national funding should be provided for the
training of advisers in good agricultural practice, as well as modern extension techniques
9.4 Develop Appropriate Advisory Messages for the Promotion of BAP the implementation of
pollution control measures at the farm level will only be successful and sustainable if the farmer
can determine that it is in his/her economic interest to undertake such measures. For example,
farmers should be advised that the use of an alternative practice is not only better for the
environment, but can also save on agrochemical inputs and therefore improve the profitability of
their farm businesses. These economic benefits must be clearly identified. However, note that
large amounts of money can be wasted on poorly designed information campaigns for
agricultural pollution control information materials must be well-written and attractively
presented with clear and simple advisory messages
9.5 Develop Alternative/Innovative Approaches to Working with Farmers there is potential in
all countries of the central and lower DRB for the development of more innovative approaches to
working with farmers in order to more effectively communicate messages about the need for
reducing agricultural pollution. One low-cost approach to implementing environmental policy is
the government funding of voluntary and community assistance programmes to build the
'capacity' of local people to address local environmental problems with locally-developed
solutions e.g. catchment-based "partnership groups" etc.
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 23
Objective 10: Develop and support pilot projects for the promotion of BAP by agricultural
extension and advisory services
10.1 Develop and Implement BAP Pilot Projects as already noted, most agricultural extension
and advisory services are traditionally concerned with providing agronomic advice and can be
difficult to re-orientate towards providing information and advice to farmers on the
environmental impact pf their farming activities and the adoption of alternative, more
environmentally-friendly farming practices. Pilot projects are useful tools to support a) the re-
orientation of extension/advisory services, b) the training of advisers and extension workers, c)
the development of appropriate advisory messages for BAP and d) the development of more
innovative approaches to working with farmers to promote BAP, particularly in high risk areas
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UNDP/GEF Danube Regional Project
11
Aim 6: To Promote Organic Farming and other Low Input Farming
Systems
Organic farming is the most well-developed of all alternative farming systems and has good potential
to reduce nutrient losses through the avoidance of the most soluble forms of mineral fertiliser, more
rational use of manures and use of more diverse crop rotations (e.g. increased winter crop cover) -
whilst also contributing to the reduction of pesticide pollution etc. There are also a number of market
opportunities available to organic farmers in the DRB countries.
The following objectives are recommended for all national strategies aiming at reinforcing organic
farming and should be adapted to national context:
OBJECTIVE 11: Promote certified organic farming and other low input farming systems as
viable alternatives to the conventional use of mineral fertilisers and pesticides
11.1 Raise Farmer Awareness of Organic Farming viable alternatives to conventional pesticide
and fertiliser use, such as organic farming and ICM, should be actively promoted to farmers
through the preparation of simple and easy to understand information materials, combined with
well-targeted publicity campaigns. Organic farming has high potential for the reduction of the
use of toxic pesticides (especially since the former intense use of copper compounds in organic
vegetable and fruit has been controlled)
11.2 Develop Relevant Legislation for Organic Farming national legislation for the certification
and inspection of organic farming systems in compliance with internationally recognised
standards (particularly those in accordance with EC legislation) should be developed and
implemented as a high priority in order to promote the development of domestic markets and
international trade
11.3 Develop Appropriate Extension Capacity for Promoting and Supporting Organic Farming
agricultural extension services and farm advisers play a fundamental role in the re-orientation
of farmers towards alternative production systems, particularly those such as organic farming,
which require higher levels of technical knowledge and management. National funding should
be provided for the development of appropriate extension capacity as Objectives 8 and 9 above
11.4 Use Economic Instruments to Promote Organic Farming and ICM farmers converting to
organic farming techniques can incur certain additional costs associated with reductions in input,
establishment of new crop rotations, adoption of new technologies etc. These costs can be a
significant obstacle to farmers making the transition from a conventional farming system.
Where funds are available, national authorities should encourage farmers to convert to organic
farming by offering appropriate levels of compensatory payment. Since organic farmers often
have problems to sell or export their products, the marketing of organically-grown products
should also be supported by governmental campaigns and action.
11.5 Develop On-farm "Quality Assurance Schemes" - in addition to their growing interest in
organic food and farming, the food processing and retail sectors of many European countries are
developing additional "on-farm quality assurance schemes" that offer promote integrated crop
management and the sale of food products that have been grown with reduced or minimal
pesticide inputs. National authorities in the DRB should support the development of such
"market-led" initiatives since they offer both a potential market opportunity for DRB farmers
and will contribute to reducing the risk pesticide pollution now and in the future
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 25
12
Summary of Policy Recommendations
The following Table 3 summarises the consultant's recommendations for the "Policy Mix" of
measures for promoting BAP in the Central and Lower DRB Countries.
The Summary Table is structured in accordance with the three main areas of policy intervention that
were identified previously in Figure 2, namely:
a) disincentives for dropping below the minimum level of acceptable environmental management
practice
b) appropriate interventions for promoting the minimum level of acceptable environmental
management
c) incentives to go beyond the minimum level of acceptable environmental management practice
Other priority policy interventions, including improvements in implementation structure, are also
listed.
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UNDP/GEF Danube Regional Project
Table 3: Summary of the "Policy Mix" of Measures Proposed for Promoting BAP in the Central and
Lower DRB Countries
Disincentives for Dropping Below Minimum Level of Environmental Management
Economic
· Apply Appropriate Financial Disincentives
Measures
Regulatory
· Develop More Targeted Regulatory Instruments for Agricultural Pollution Control
Measures
Interventions to Promote Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Good Practice for Fertiliser and Manures
Measures
Develop and Promote National Codes of Good Practice for Fertiliser and Manure Use
· Raise Awareness about Pesticide Misuse
· Develop National Codes of Good Practice for Pesticide Use
· Mandatory Farmer Training on Pesticide Use
· Promote Greater Compliance with Agricultural Pollution Control Legislation
· Develop Appropriate Advisory Messages for the Promotion of BAP
· Develop and Implement BAP Pilot Projects
Economic
· Use Capital Grant Schemes to Promote Good Practice
Measures
· Use "Cross Compliance" to Promote Good Practice
Regulatory
· Pesticide Ban
Measures
· Pesticide Phase-out
· Pesticide Cut-off Criteria
· Control Pesticide Trade
Incentives to go Above Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Organic Farming
Measures
Economic
· Use Compensatory Payments to Promote Good Practice
Measures
· Use Economic Instruments to Promote Organic Farming and ICM
· Develop On-farm "Quality Assurance Schemes"
Regulatory
· Develop Relevant Legislation for Organic Farming
Measures
Other Measures including Improvements in Implementation Structure
· Establish Progressive and Well-funded Research Programmes
· Monitor Pesticide Trade
· Monitor Pesticide Use
· Elimination of Obsolete Pesticides
· Improve Enforcement of Agricultural Pollution Control Legislation
· Re-orientate Agricultural Extension and Advisory Services Towards the Promotion of
BAP
· Increase Financial Support for Agricultural Extension and Advisory Services
· Develop Appropriate Institutional Frameworks for the Promotion of BAP
· Training for Extension Workers/Advisers
· Develop Alternative/Innovative Approaches to Working with Farmers
· Develop and Implement BAP Pilot Projects
· Develop Appropriate Extension Capacity for Promoting and Supporting Organic
Farming
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 27
13
Adapting Policy Aims, Objectives and Measures to National/Regional
Context
13.1 Introduction
The preceding section concludes with a summary (Table 3) of the overall "policy mix" of measures
appropriate for promoting Best Agricultural Practice (BAP) in the Central and Lower DRB
countries14. However, when considering this "policy" mix it is important to remember that it cannot
be applied uniformly across the whole of the DRB since as already noted - the level of
environmental management/performance that we can expect from farmers in different
regions/countries will vary significantly according to:
a) the agronomic, environmental and socio-economic context in which they are operating and
b) the feasibility of introducing the necessary appropriate policy instruments/measures for
encouraging farmers to "move up" the BAP hierarchy and adopt more demanding pollution
control practices.
Two key factors influencing the feasibility of introducing appropriate policy instruments/measures are
the availability of:
· necessary financial resources for introducing economic incentives to encourage farmers to go
above the minimum level of environmental management
· appropriate knowledge and other technical resources for supporting farmers to "move up" the
BAP hierarchy and adopt more demanding pollution control practices
Although the huge diversity of the 11 central and lower DRB countries must be taken into account
when making recommendations for the necessary agricultural policy changes to promote BAP in a
national/regional context, it is not possible to make recommendations on a country-by-country basis.
Instead, since a key driving forces for policy reform in the area of agricultural pollution control is
preparation for joining the EU, the recommendations for policy reform are made according to the
following different status of DRB countries regarding EU accession:
· EU Acceding Countries entering in May 2004: Czech Republic, Hungary, Slovakia and
Slovenia.
· EU Candidate Countries entering after May 2004: Bulgaria and Romania and possibly
Croatia (preparing application to join EU).
· Non-EU Accession Countries: Bosnia-Herzegovina, Serbia-Montenegro, Moldova and Ukraine.
13.2 Key Issues for Selection of Priority Policy Recommendations
The policy recommendations for Phase 2 of the DRP are formulated in Tables 4, 5 and 6 as a summary
of the "mix" of policy measures considered a priority for each of the three country groups. Each
Summary Table is structured in accordance with the three main areas of policy intervention that were
identified previously in Figure 2 and used in Table 3.
The following key issues were considered when selecting the priority recommendations for each
country group:
1. Representatives and experts from all lower and central DRB countries stressed that:
· there is a significant lack of information at national, regional and local level on the causes of
agricultural pollution and the practical measures available to farmers for reducing the risk of
pollution from their farming activities
· an urgent need exists for awareness-raising and information to be targeted at all stakeholders
levels from farmers to policy-makers
14 Where BAP for the central and lower DRB countries is defined as "...the highest level of pollution control
practice that any farmer can reasonably be expected to adopt when working within their own national, regional
and/or local context in the Danube River Basin"
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UNDP/GEF Danube Regional Project
· since farmers are economically-motivated it is important to link the promotion of more
environmentally-friendly farming methods to economic benefits such as improvements in
yield and savings in the cost of agrochemical inputs. The development of appropriate
agricultural advisory messages is therefore essential, including well-written and appropriate
advisory materials, demonstration plots/farms, training for advisors and other capacity
building of agricultural extension services
2. The late 1990s saw the introduction of many new environmental laws (or revisions to existing
regulations) in those countries preparing for accession to the EU in May 2004 and to a lesser
extent in Bulgaria and Romania. These developments were stimulated largely by the need to
adopt the acquis communautaire rather than domestic pressures. Unfortunately, while legal
harmonisation has progressed rapidly, the ability to enforce and monitor the resulting new
regulations has often lagged behind
3. At the same time, preparation for implementation of the EU Common Agricultural Policy (CAP),
including the Rural Development Regulation that currently forms the so-called "second pillar" of
the CAP, represents a great opportunity for policy reforms to promote BAP (also the SAPARD
programme in Bulgaria and Romania). This includes the availability of EU co-financing for
economic incentives to promote more environmentally-friendly farming practices, as well as the
concept of "environmental cross-compliance" on agricultural support payments. It is unrealistic to
expect similar financial resources to be available in those countries not joining, or preparing to
join, the EU
4. During the 1990s, land privatisation and restitution policies were implemented in the majority of
central and lower DRB countries leading to a large increase in the number of agricultural holdings
that are in private ownership. This now represents a major challenge to the promotion of BAP -
both in terms of the enforcement of agricultural pollution control legislation (as mentioned above)
and the dissemination of appropriate advisory messages regarding BAP to an agricultural
community that consists of an extremely diverse set of actors with contrasting farm sizes, degrees
of specialisation and levels of education. The capacity-building of local, regional and national
agricultural and extension services therefore remains a major challenge, especially in those
countries dominated by small farms where the managerial skills of the farmers are at present still
relatively poor. This challenge is accentuated by the further observation that in many countries:
· the level of usage of agricultural extension and advisory services is still very low
· the advisory services are mainly focused upon technical issues and are less-oriented towards
economic and environmental advice, and
· existing extension services do not yet have the capabilities and capacities to provide the
expected quality of advice.
5. It must also be taken into account that the levels of fertilizer and pesticide use in the central and
lower DRB countries are still relatively low, although there are indications of increasing use again
in those countries where the economic circumstances of agriculture are improving most rapidly
notably in those countries joining the EU in 2004. The priorities for improvements in the
management of agro-chemical inputs (fertilizers and pesticide) therefore vary across the DRB
region
6. It is also widely acknowledged that there should be more emphasis upon a "farming systems"
approach to agricultural pollution control rather than simply an "input reduction" approach in
other words, it is necessary to promote not only the reduced use of agrochemicals inputs etc., but
also the re-design of farming systems to make them more environmentally sustainable. A good
example of this approach is the promotion of organic farming which involves much more than
prohibiting the use of pesticides and mineral fertilisers to include changes in crop rotation, soil
manure, the storage and management of manure etc.
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 29
7. In the lower DRB countries especially it is important to consider the pre-conditions or "framework
factors" for the successful promotion of BAP in particular how to overcome the obstacles to
BAP that arise from the fragmentation of land ownership, lack of financial resources, lack of
institutional capacity, lack of basic business skills amongst farmers (e.g. keeping records), poor
standards of education and training etc.
13.3 Developing the "Policy Mix"
As already discussed, it is unrealistic to expect a single policy instrument to do the whole job of
tackling water pollution from agricultural non-point sources. Equally it is unrealistic to attempt to
implement all of the policy recommendations contained in the following tables at the same time or in
the same place. It will be necessary to use certain policy instruments to encourage and facilitate short-
term changes in farmer behaviour, whilst using other instruments to incentivise even greater changes
in the longer-term
Policy reform is therefore a set-wise and iterative process that takes time and often involves on-going
modification of the original "policy mix" selected. To assist this process it is advisable to:
a) set quantitative targets for pollution control which provide a clear focus for the planning,
implementation, monitoring and evaluation of the policy reforms introduced
b) allow farmers some time to modify and adapt their farming activities to take account of the
changing regulatory pressures upon them, available advice and information, and potential fiscal
opportunities (e.g. cost saving).
The result of policy reforms should then be a progressive improvement in the environmental
performance of agriculture.
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UNDP/GEF Danube Regional Project
Table 4:
"Policy Mix" for EU Accession Countries: Czech Republic, Slovakia, Hungary and
Slovenia
Disincentives for Dropping Below Minimum Level of Environmental Management
Economic
c) Apply Appropriate Financial Disincentives
Measures
Interventions to Promote Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Good Practice for Fertiliser and Manures
Measures
· Raise Awareness about Pesticide Misuse
· Develop National Codes of Good Practice for Pesticide Use
· Mandatory Farmer Training on Pesticide Use
· Promote Greater Compliance with Agricultural Pollution Control Legislation
· Develop Appropriate Advisory Messages for the Promotion of BAP
Economic
· Use Capital Grant Schemes to Promote Good Practice
Measures
· Use "Cross Compliance" to Promote Good Practice
Regulatory
· Pesticide Ban
Measures
· Pesticide Phase-out
· Pesticide Cut-off Criteria
· Control Pesticide Trade
Incentives to go Above Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Organic Farming
Measures
Economic
· Use Compensatory Payments to Promote Good Practice
Measures
· Use Economic Instruments to Promote Organic Farming and ICM
· Develop On-farm "Quality Assurance Schemes"
Other Measures including Improvements in Implementation Structure
· Establish Progressive and Well-funded Research Programmes
· Monitor Pesticide Trade
· Monitor Pesticide Use
· Elimination of Obsolete Pesticides
· Improve Enforcement of Agricultural Pollution Control Legislation
· Re-orientate Agricultural Extension and Advisory Services Towards the Promotion of
BAP
· Increase Financial Support for Agricultural Extension and Advisory Services
· Develop Appropriate Institutional Frameworks for the Promotion of BAP
· Training for Extension Workers/Advisers
· Develop Alternative/Innovative Approaches to Working with Farmers
· Develop Appropriate Extension Capacity for Promoting and Supporting Organic
Farming
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 31
Table 5: "Policy Mix" for EU Pre-accession Countries: Romania, Bulgaria and Croatia
Disincentives for Dropping Below Minimum Level of Environmental Management
Economic
d) Apply Appropriate Financial Disincentives
Measures
Regulatory
e) Develop More Targeted Regulatory Instruments for Agricultural Pollution Control
Measures
Interventions to Promote Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Good Practice for Fertiliser and Manures
Measures
Develop and Promote National Codes of Good Practice for Fertiliser and Manure Use
· Raise Awareness about Pesticide Misuse
· Promote Greater Compliance with Agricultural Pollution Control Legislation
· Develop Appropriate Advisory Messages for the Promotion of BAP
· Develop and Implement BAP Pilot Projects
Economic
· Use Capital Grant Schemes to Promote Good Practice
Measures
Regulatory
· Pesticide Ban
Measures
· Pesticide Phase-out
· Pesticide Cut-off Criteria
· Control Pesticide Trade
Incentives to go Above Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Organic Farming
Measures
Economic
· Use Compensatory Payments to Promote Good Practice
Measures
· Use Economic Instruments to Promote Organic Farming and ICM
Regulatory
· Develop Relevant Legislation for Organic Farming
Measures
Other Measures including Improvements in Implementation Structure
· Establish Progressive and Well-funded Research Programmes
· Monitor Pesticide Trade
· Monitor Pesticide Use
· Elimination of Obsolete Pesticides
· Improve Enforcement of Agricultural Pollution Control Legislation
· Re-orientate Agricultural Extension and Advisory Services Towards the Promotion of
BAP
· Increase Financial Support for Agricultural Extension and Advisory Services
· Develop Appropriate Institutional Frameworks for the Promotion of BAP
· Training for Extension Workers/Advisers
· Develop Alternative/Innovative Approaches to Working with Farmers
· Develop and Implement BAP Pilot Projects
· Develop Appropriate Extension Capacity for Promoting and Supporting Organic
Farming
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UNDP/GEF Danube Regional Project
Table 6: EU Non-accession Countries: Bosnia-Herzegovina, Serbia-Montenegro, Moldova and
Ukraine
Disincentives for Dropping Below Minimum Level of Environmental Management
Economic
f) Apply Appropriate Financial Disincentives
Measures
Regulatory
g) Develop More Targeted Regulatory Instruments for Agricultural Pollution Control
Measures
Interventions to Promote Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Good Practice for Fertiliser and Manures
Measures
Develop and Promote National Codes of Good Practice for Fertiliser and Manure Use
· Raise Awareness about Pesticide Misuse
· Promote Greater Compliance with Agricultural Pollution Control Legislation
· Develop Appropriate Advisory Messages for the Promotion of BAP
· Develop and Implement BAP Pilot Projects
Regulatory
· Pesticide Ban
Measures
· Pesticide Phase-out
· Pesticide Cut-off Criteria
· Control Pesticide Trade
Incentives to go Above Minimum Level of Environmental Management
Advisory
· Raise Farmer Awareness of Organic Farming
Measures
Regulatory
· Develop Relevant Legislation for Organic Farming
Measures
Other Measures including Improvements in Implementation Structure
· Establish Progressive and Well-funded Research Programmes
· Elimination of Obsolete Pesticides
· Improve Enforcement of Agricultural Pollution Control Legislation
· Re-orientate Agricultural Extension and Advisory Services Towards the Promotion of
BAP
· Increase Financial Support for Agricultural Extension and Advisory Services
· Develop Appropriate Institutional Frameworks for the Promotion of BAP
· Training for Extension Workers/Advisers
· Develop Alternative/Innovative Approaches to Working with Farmers
· Develop and Implement BAP Pilot Projects
· Develop Appropriate Extension Capacity for Promoting and Supporting Organic
Farming
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 33
14
Conclusions and Proposals for Implementation of Recommendations
for Policy Reform
14. Conclusions
The policy recommendations contained within this report:
a) are based on the results of in-depth analyses of the present use of pesticides, fertilizers and manure
in the central and lower DRB countries;
b) involve the introduction of new legal and institutional instruments for the reduction and control of
water pollution from non-point sources of agricultural activities, and;
c) are intended to support the practical introduction of BAP and the greater integration of pollution
control considerations into the day-to-day management of crops, animals and agricultural land by
farmers.
The objective of Phase 2 of Output 1.3 of the Danube Regional Project should be to promote the
necessary agricultural policy reforms to implement these recommendations and to support the design
of the new agricultural pollution control policies that are necessary to promote BAP. This support
should be provided on the basis of the three country groups identified: EU Acceding Countries
(entering in May 2004), EU Candidate Countries (entering after May 2004), and the Non-EU
Accession Countries.
The agricultural policy changes, to be introduced in Phase 2 of the UNDP/GEF Danube Regional
Project will be to encourage farmers to "move up" the BAP hierarchy and adopt more demanding
pollution control practices. The specific environmental benefits arising directly from this will depend
upon national/regional context, but across the DRB region as a whole will be a general reduction in the
risk of water pollution caused by fertilisers, manures and pesticides. This will be due to:
· the avoidance of bad practice on farms regarding the storage and application of fertilisers, manures
and pesticides
· more efficient management of fertilisers and manures by farmers, including improvements in the
collection and storage of manure, timing and rate of fertiliser/manure application, avoidance of
run-off from sloping land, better planning of nutrient management etc.
· a reduction in the amount of harmful substances used as pesticides for crop protection due to the
prohibition and phasing-out of the most dangerous priority pesticides, as well as improved controls
on the use and distribution of pesticides
· more environmentally-friendly and efficient management of pesticides by farmers, including the
appropriate selection of available chemicals, improved sparing equipment and techniques, careful
disposal of waste pesticides and use of integrated control methods
· an increased uptake of alternative, low input farming methods such as organic farming
The necessary steps for implementation of the proposed policy reforms and for the introduction of
measures for BAP at the national level in Phase 2 of the UNDP/GEF Danube Regional Project are
described in the final sections of this report.
34
UNDP/GEF Danube Regional Project
15 Proposals
for
Further Actions
15.1 Further Development and Introduction of Policy Instruments Adapted to
National Conditions
In order to be effective at improving farm management practices, policies for reducing agricultural
pollution should include three effective components that should be taken into account in the review and
further development of the legal and institutional frame for the introduction of BAP at the national level:
· a policy strategy (or number of strategies)
· policy instruments and
· an implementation structure.
In the present report six Strategic Aims with eleven Objectives for measures for control and reduction
of agricultural pollution have been identified related to:
1. Use of mineral fertilisers and manure
2. Use of pesticides
3. Compliance and enforcement of regulatory instruments
4. Development of appropriate economic instruments
5. Development of capacities of agricultural extension services
6. Promotion of organic farming and other low input farming systems.
The described policy aims and objectives have to be adapted to national and regional conditions
focusing on the review and further development of the legal and institutional frame at the national
level. In this context, the needed assistance should be provided to EU Candidate Countries due to
join the EU after 2004: Bulgaria and Romania and possibly Croatia (preparing application to join the
EU) and to non-EU Accession Countries: Bosnia-Herzegovina, Serbia-Montenegro, Moldova and
Ukraine. Most of these countries should also benefit from agricultural demonstration project for the
introduction of BAP in the Danube River Basin.
For practical implementation of proposed policies a two-step approach is anticipated:
STEP 1 - specific guidelines should be developed for each of the above mentioned countries to
facilitate reviews of national agricultural policies and legislation and to strengthen institutional
arrangements for the introduction of BAP:
· to improve agricultural practice (fertiliser, manure and land management) and to reduce the risk of
diffuse nutrient pollution through better management of fertilisers and manures,
· to reduce the levels of harmful active substances used for crop protection by prohibiting and/or
substituting the most dangerous pesticides with safer (including non-chemical) alternatives,
· to encourage the proper use of pesticides by farmers and other operators, and to assure compliance
with regulatory instruments through the control of specific farming practices,
· to develop and introduce appropriate economic instruments to encourage implementation of BAP,
· to review and adapt the mandate and structure of agricultural extension and advisory services,
· to develop the capacity of agricultural extension and advisory services for the promotion of BAP,
· to develop and support pilot projects for the promotion of BAP by agricultural extension and
advisory services,
· to promote certified organic farming and other low input farming systems as viable alternatives to
the conventional use of mineral fertilisers and pesticides.
Recommendations for Policy Reforms for the Introduction of Best Agricultural Practice in the Danube River Basin 35
This first step should be carried out by national consultants in close cooperation with international
assistance. Specific outlines for the review of existing national legislation and proposals for changes
and/or amendments of the legal and institutional frame should be prepared to facilitate the introduction
of the concept of Best Agricultural Practice (BAP) at the national level. Policy reviews should also
take into account transboundary issues to enhance regional cooperation as well as the requirements of
the process of EU integration in adopting relevant EU directives and regulations into national law.
STEP 2 - twinning projects should be developed (TOR and outline of project description) and sources
of financial and technical support for projects implementation should be identified to assure effective
introduction of new concepts for agricultural pollution control in national policies and legislation.
Review and amendment of national policies and development of respective legislation should be
considered as an iterative process that takes into account the opinions and needs of the stakeholders
concerned as well as transboundary issues related to land management and environmental protection.
In this context, particular attention should also be paid to reviewing institutional mechanisms for
promotion of BAP focusing on the mandate and the needed support of agricultural extension services.
The financial support for twinning projects should be mobilized in the frame of bilateral and
multilateral assistance relating to the EU enlargement process and assistance to NIS countries. This
approach is in line with GEF operational principles to generate additional financial and technical
support for national capacity building and further implementation of GEF proposed measures for
nutrient reduction in the DRB countries.
15.2 Practical Demonstration of BAP in the Framework of Pilot Projects
Within Output 1.3 of the Danube Regional Project (DRP), seven countries of the central and lower
DRB region (Croatia, Bosnia-Herzegovina, Serbia-Montenegro, Bulgaria, Romania, Moldova and
Ukraine) have been identified as a priority for the development and implementation of pilot projects to
promote the concept of Best Agricultural Practice.
The pilot projects will be implemented in Phase 2 of the DRP (2004-2006) and it is anticipated that
they will involve 18-24 months of practical implementation. The immediate beneficiaries of the pilot
projects will be the agricultural extension and advisory services in the selected countries. The ultimate
beneficiaries of the results will be the farmers' community (environmental and economic benefits), the
consumers (healthy and organic food products) and in the final analysis the society as a whole (healthy
environment and unpolluted surface and ground waters).
The specific objectives of the pilot projects will be to: "demonstrate how improvements can be
made in the capacity/effectiveness of agricultural advisers/extension services to provide appropriate
information and advice that supports the highest level of pollution control practice by farmers
according to local context".
The potential impact of improving the effectiveness of agricultural advisers/extension services in the
central and lower DRB countries is:
· raised awareness of pollution risks amongst farmers
· increased avoidance of bad practice including improved compliance with relevant legislation
· increased adoption of good practice including utilization of economic incentives.
Pre-requisites and selection criteria taken into account in identifying pilot projects for demonstration
of BAP responding to a specific pollution issue included:
· Coherence with Government policies and/or the political commitment to introduce BAP;
· Existence of a reliable counterpart organisation, credible to the agricultural community;
· Location in a specific geographical area, if possible reinforcing transboundary cooperation with
neighbouring communities;
36
UNDP/GEF Danube Regional Project
· Response to a specific pollution issue fertiliser and manure handling, pesticides use and
agricultural run-off, as identified by stakeholders;
· Potential for replication at national and/or regional levels;
· Reinforcement of other GEF interventions and promoting cooperation with existing international
and bilateral projects in agricultural development.
The proposed pilot projects for introduction of BAP should demonstrate the practical implementation
of revised agricultural policies at the farmers' community level and the technical and economic
feasibility of proposed agricultural practices for fertiliser and manure handling, use of pesticides and
run-off control to reduce water pollution from agricultural activities while improving the economic
situation of farmers.
For effective project implementation the following points should be considered:
· Specific concepts and outlines for the implementation of selected pilot projects should be
developed in consultation with the stakeholders concerned (farmers' community) and in
cooperation with related Government institutions and extension services. Further, relevant ToR
and scope of work for international assistance and national project management should be
prepared;
· Competent extension services should be identified, having the required experience as service
provider and being accepted by the agricultural community as well as by Government;
· Financial support should be made available for project implementation in particular to facilitate
the work of national extension services and to promote awareness raising in the farmers'
community;
· International assistance should be contracted to provide technical advice in introducing BAP
adapted to the local or regional context and to assure follow-up on project activities that includes
(i) regional coordination of pilot project activities, (ii) dissemination of results, (iii) organization
of training workshops, and (iv) cooperation with other projects of bilateral, EU and international
assistance in related subjects (agricultural policy development, introduction of BAP and other
measures for nutrient reduction from agricultural non-point sources of pollution).
In implementing the agricultural project components (1.2 and 1.3) of the UNDP/GEF Danube
Regional Project, particular attention should be paid to assuring effective coordination with other
UNDP/GEF project activities (Black Sea) as well as with EU projects in EU accession countries, in the
Balkan countries as well as in NIS countries aiming to reinforce national capacities and to adapt
national legislation in line with EU requirements (EU Water Framework Directive and other related
directives for nutrient reduction and priority substances) and to create the appropriate mechanisms for
compliance.
Document Outline