Royal Commission on Environmental Pollution

Summary of recommendations

1.    The conservation agencies have concerns over long-term chemical effects due to their known impacts as well as potential risks to designated sites, and due to their effects in the environment more widely. We would like to recommend that the study covers the following areas.

2.    The study should examine the long-term policy framework within which goals for dealing with the long-term effects of chemicals are set.

3.    The study should investigate the role of important new drivers, in particular Biodiversity Action Plan targets and Habitats Regulations, in setting a framework within which long-term risks of chemicals to nature conservation are assessed.

4.    The study should be broad enough to encompass non-synthetic chemicals which are having serious long-term effects on the environment, including nutrients, in addition to persistent and bioaccumulative synthetic chemicals.

5.    Categories of chemical pollutants, and issues relating to these which we particularly wish to bring to the attention of the RCEP because of their long-term or potentially long-term effects are:

. understanding the ecosystem effects of atmospheric sources of nitrogen, sulphur and ozone and controls over diffuse atmospheric pollution sources;

. effects of persistent organic pollutants (especially PCBs, PAHs, PBDEs, dioxins and furans) and their possible consequences for populations, especially sublethal effects and interactive effects;

. regulatory mechanisms and other mechanisms for reducing loading of nutrients in freshwater ecosystems;

. the scale of damage to rivers as a result of sheep dipping activities and the long-term effects of low level pollution by contaminants such as pesticides in aquatic ecosystems;

. long-term term trends in nutrient status of maritime habitats, relationships between nutrient concentrations or loadings and marine ecosystem responses, and targets for nutrient concentrations within such ecosystems;

. the suitability of EQSs for the protection of nature conservation features and the absence of standards for sediment contaminants to protect ecosystems in the UK;

. the scale of potential endocrine disruptor effects, the range of species at risk and the population consequences of current levels of exposure;

. the impact of chemicals used in fish farming on marine ecosystems, and possible long-term effects of antifoulants used in marine and coastal environments;

. the contribution made by indirect effects of pesticides to observed declines in farmland biodiversity relative to other factors linked with farming intensification;

. the possible significance for ecosystems of the use of antibiotics in agriculture;

. the widespread contamination of, and risks to, top predators from second generation rodenticides.

7.    The study should investigate possible approaches to assessing risks of interactive effects of chemicals, the capacity for regulatory processes to address this issue and the risks involved in not incorporating this within regulatory assessments.

8.    The study should cover the basis for assumptions on which metabolite hazards are assessed and the current capacity and requirement to understand the relative hazards of isomers and their metabolites.

9.    The study should consider the role, current scope and future requirements for chemical usage monitoring in assessing long-term risks of chemicals.

10.    The study should consider the degree to which current population dynamics theory is being or could be incorporated more fully into ecotoxicology and ecological risk assessment and the place of population modelling in predicting the long-term effects of chemicals.

11.    The use of safety factors and appropriateness of test organisms in extrapolating the results of risk assessments for long-term chemical effects between and within different taxonomic groups should be examined during the RCEP study.

12.    The study should examine the need for further research into the long-term indirect effects of chemicals in the environment and the need for such assessment during risk evaluations for chemicals.

13.    We identify a number of issues relating to the need for surveillance and monitoring of the long term risks of chemicals:

. the requirement for and current extent of chemical monitoring in wildlife, and in the environment more widely;

. coordination of different monitoring activities for long-term effects of chemicals in the environment;

. the development and implementation of better indicators of chemical effects in the environment, in particular through the development of better biomarkers;

. the role of intact ecosystems in providing a source of early warning about potential long-term risks from chemicals;

. the limitations of long-term monitoring as a tool to detect long-term change.

1. Introduction
English Nature is the statutory body that champions the conservation and enhancement of the wildlife and natural features of England. We do this by:

advising - Government, other agencies, local authorities, interest groups, business, communities, individuals
regulating - activities affecting the special nature conservation sites in England
enabling - helping others to manage land for nature conservation, through grants, projects and information
enthusing - advocating nature conservation for all and biodiversity as a key test of sustainable development.

- establish and manage National Nature Reserves - notify and safeguard Sites of Special Scientific Interest (SSSIs);
- advocate to government departments and others effective policies for nature conservation
- disseminate guidance and advice about nature conservation
- promote research relevant to nature conservation.

1.1    Given the broad scope of the investigation, there is a need to focus on those elements which are of most pressing concern, even if this means the coverage of the subject is patchy. This response from the conservation agencies therefore aims to indicate those issues relevant to the scope of the study which are of greatest concern to the conservation agencies, the areas of uncertainty associated with these and the relevant studies which the agencies are involved in. An important principle is that long-term effects of chemicals can arise from short-term exposures (and hence from short-persistence chemicals). Therefore our response is not concerned exclusively with persistent and bioaccumulative chemicals.

1.2    The conservation agencies have concerns over long-term chemical effects due to the potential impacts on designated sites, arising from both point and diffuse sources of chemicals in all media. Some of these effects will be measurable in terms of effects on communities and populations, and hence on the nature conservation objectives for the sites. Such effects include eutrophication in freshwater and maritime sites, atmospheric deposition of nitrogen in sensitive habitats, effects of antifoulants in marine habitats. Other potential effects are appreciated more in terms of their potential risks - the effects being less easily measured - such as the impact of pesticide drift on adjacent sites, contamination of sites by persistent pollutants and critical load exceedence for acidity in various habitats. Here the concern is more to reduce risks than to eliminate impacts.

1.3    The conservation agencies also have concerns over the long-term effects of chemicals in the environment more widely and this has, for example, been identified as an issue under the Biodiversity Action Plans for a number of species. For example the consequences of both direct and indirect effects of pesticides on farmland biodiversity and contamination of marine mammals with persistent pollutants.

1.4    The study provides an important opportunity both to review the current risk assessment and risk management approaches to chemicals in the environment, and to examine potential new issues in the light of emerging initiatives and legislation. Thus the study should draw upon past experiences but also examine our capacity to predict new risk areas. An important function of the RCEP study should be to examine the context within which goals are set for environmental objectives and against which chemical assessments are made. Much of pollution control and prevention is based on short term targets and these change over time as, for example, new information on risk becomes available. Longer term, sustainable targets should become the overall objective, within which shorter term goals (such as environmental quality standards) can be set.

Recommendation: The study should examine the long-term policy framework within which goals for dealing with the long-term effects of chemicals are set.

1.5    Nature conservation drivers
Important new drivers in considering the risks and management of long-term effects of chemicals in the environment and for nature conservation derive from European and wider international initiatives. In particular, the Biodiversity Action Plans for species and habitats provide important targets against which objectives for environmental contamination by chemicals may now be set. For example, a recent consultation by the Advisory Committee on Releases to the Environment (ACRE) subgroup on wider biodiversity issues (DETR 2000) has proposed the use of such targets in the assessment process for the wider effects of GMO releases. Another major driver derives from the Habitats Regulations (Conservation of Natural Habitats & Regulations, 1994) which implement measures under the EU Habitats and Birds Directives. An important feature of this legislation is the incorporation of the precautionary principle through the requirement to demonstrate "no adverse effect" on the integrity of sites (Natura 2000 sites) designated under those Directives (see Section 3.3 below). This requirement extends to the effects on such sites of potentially polluting activities regulated under a range of existing UK legislation.

Recommendation: The RCEP study should investigate the role of important new drivers, in particular BAP targets and Habitats Regulations, in setting a framework within which long-term risks of chemicals to nature conservation are assessed.

1.6    Scope of the study
Although any long-term effect of chemicals in the environment may be included in the study, it appears from the consultation document that the RCEP investigation has a particular focus on those chemicals whose manufacture and use is regulated to some degree (for example frequent references to the Government's chemicals strategy and to chemical assessments and control processes). However, some of the most significant current long-term effects are due to point and especially diffuse sources of non-synthetic chemicals, especially nutrients via aquatic and atmospheric routes. We have taken a very broad view of the RCEP study in preparing this set of recommendations of issues for investigation, and we recommend that the RCEP maintains this broad scope for the study.

Recommendation: The study should be broad enough to encompass non-synthetic chemicals which are having serious long-term effects on the environment, including nutrients.

2.    Overview of existing knowledge and research needs: Environmental effects and chemicals of most concern to the conservation agencies:
Categories of chemical pollution which we particularly wish to bring to the attention of the RCEP because of their long-term or potentially long-term effects are:

2.1    Atmospheric pollution:
There is likely still to be significant eutrophication and acidification critical load exceedence of SSSIs, under current and future emission reduction scenarios. This has implications for the sustainability of a range of sensitive habitats. Ozone concentrations still exceed critical levels for vegetation and pose an important long-term risk which is poorly understood at the ecosystem level. Areas of particular uncertainty here are the relationship between critical load or level exceedence and the consequential long-term effects on particular habitats and species. In particular there is a need for improvements in our ability to quantify the role of atmospheric sources of nitrogen in semi-natural habitats, and for a better understanding of the interactions between effects of acidification, eutrophication (and in turn of ozone levels) in ecosystems. Regulatory regimes for diffuse atmospheric pollution sources are inadequate.

Persistent organic pollutants and some metals are of concern because of their capacity to persist and bioaccumulate, and because of their widespread occurrence as evidenced from monitoring programmes for contaminants in wildlife. Although controls over industrial emissions of metals have increased, there is a need for further work on the interactions between other polluting effects (such as acidification) and climate change on mobilising pollutants and increasing their availability within ecosystems. There are particular concerns arising from the lack of knowledge of effects in organisms of persistent organic pollutants, especially sublethal effects and their possible consequences for populations. The conservation agencies can supply information on some of these contaminants in birds of prey collected under the Wildlife and Pollution monitoring scheme, part funded by JNCC (Newton et al 2000, 1999, 1997). This work indicates continuing relatively high levels of PCBs and mercury in some species, with evidence for "hot spots" for contamination in some locations. The significance of this is not well understood.

2.2    Freshwater pollution:
Diffuse nutrient sources are a principal concern here. Some 40-60% of the annual phosphorus budget to UK surface waters is estimated to come from diffuse sources, mainly from agriculture. The regulatory control over the sources of this environmental loading is very limited, whilst other mechanisms for reducing loads (such as grant aid and advice to farmers) are not being applied in an effective way. This is one of the gravest threats to the integrity of aquatic ecosystems and the situation is likely to worsen as livestock farming increasingly gives way to arable in areas at risk from nutrient enrichment via sediment runoff. Further information can be provided and a position statement on this issue is attached.

Although the effects of diffuse or point source pollution by chemicals such as sheep dip may have a primarily short term acute effect, with recovery in the scale of months rather than years, this need not necessarily be the case if extensive areas or critical life stages have been affected. There are particular concerns over the scale of damage to rivers as a result of sheep dipping activities and especially following the widespread switch from OP to SP dips (House of Commons Agriculture Committee, 2000). The long-term effects of low level pollution by contaminants such as pesticides in aquatic ecosystems are poorly known.

2.3    Marine/coastal pollution
Diffuse nutrient pollution is again a key issue and long-term changes in some ecosystems have been observed as a result of long-term exposure especially to diffuse sources. Areas of particular uncertainty include the shortage of information on long-term trends in nutrient status at many locations, and the lack of knowledge of the relationships between nutrient concentrations or loadings and marine ecosystem responses (Scott et al 1999). This creates difficulties in setting targets for nutrient concentrations within areas having differing environmental quality objectives. Although the primary nature conservation concern is long-term changes in ecosystem structure due to shifts in nutrient balance, other concerns which require further investigation relate to the possible role of anthropogenic inputs on toxic algal blooms and the significance of these for wildlife such as seabirds.

Persistent pollutants give rise to similar concerns over sublethal effects and significance of contaminant levels found in marine wildlife as for atmospheric routes, above. In many instances EQSs have been set for such pollutants, but for many pollutants water column EQSs do not exist and their suitability in all cases for the protection of nature conservation features has been questioned (Grimwood et al 1997). Of particular concern is the absence of standards for sediment contaminants to protect ecosystems in the UK although this is starting to be addressed. This is of particular concern in the assessment and regulation of potentially damaging effects to Natura 2000 sites (see 1.5 above). The requirement to demonstrate "no adverse effect" of operations has become a particularly difficult area in the absence of accepted standards for sediment contamination, which has become a key area requiring further work.

There are particular uncertainties over the scale of potential endocrine disruptor effects, the range of species at risk and the population consequences of current levels of exposure to this group of pollutants (Allen et al 2001). There are particular concerns over potential effects of persistent and bioaccumulative pollutants on long-lived marine vertebrates of conservation concern such as cetaceans and basking sharks. A better understanding is needed of the effects of PCBs, PAHs, PBDEs and dioxins and furans in marine ecosystems. Monitoring of effects following oil spills such as the Sea Empress provides an indication of possible longer term effects of such one-off pollution events. The long-term surveillance of organochlorines (including PCBs) and mercury in gannet eggs carried out under the JNCC "Wildlife and Pollution" contract provides a record of these contaminants in the marine environment over 27 years and as such is of international significance (Newton et al 1997, 1999, 2000).

A specific area of concern is the impact of fish farming on marine ecosystems, and a study into the long-term effects of biocides in fish farming is referred to in the response to the RCEP consultation from Scottish Natural Heritage. The shortage of information on possible long-term effects of antifoulants used in marine and coastal environments is of concern, the need for an international regulatory approach is particularly important here.

2.4    Terrestrial pollution
The principle issues we would like to draw to the attention of the RCEP are:
The direct and indirect effects of pesticides on farmland biodiversity. Inadequacies of the present regulatory process are discussed below. A particular difficulty is in understanding the contribution made by pesticides to observed declines in farmland biodiversity relative to other factors linked with farming intensification. This is not just of theoretical interest but also affects the relevance of particular regulatory regimes or other measures to address this issue, and the extent to which a "polluter pays" approach should be adopted.

Particular uncertainties exist over the effects of certain veterinary medicines at the ecosystem level. Aspects relating to anthelmintics and their impact on dung fauna and possibly on dependent trophic levels are discussed below, but the possible significance for ecosystems of the use of antibiotics in agriculture is an additional area of uncertainty.

The conservation agencies have major concerns over the risks to top predators from exposure to second generation rodenticides. Evidence can be provided from JNCC and EN monitoring data of increases in contamination of barn owls by this class of chemical, and of high levels of residues in red kites. Significant uncertainties exist over the biological significance of residue levels in these species and other predators, and over the changing risk scenarios due to resistance development to second generation rodenticides. Changes in the patterns of use of these products are likely to increase their long-term risks to wildlife populations.

2.5    Climate change
Whilst we do not expect the RCEP study to extend to such indirect effects of chemicals as the impacts of greenhouse gases on the environment, the increased levels of the principal greenhouse gas carbon dioxide may also have a direct effect on biodiversity and so should be considered in the study. English Nature currently leads a consortium of 11 funding partners who have commissioned a major study into the impacts of climate change on wildlife and natural processes in the British Isles. The study, named MONARCH (Modelling Natural Resource Responses to Climate Change) is being carried out by a research team led by the Environmental Change Institute, University of Oxford. It will conclude in February 2001 and a report of its findings will be available shortly thereafter.

3.    Chemical assessment and hazard and risk identification
In addressing these two broad topics raised in the consultation, we will consider current knowledge and research needs under the headings of hazard and exposure identification, risk assessment and monitoring requirements and finally some principles involved in risk management of chemicals.

3.1    Hazard identification
Significant areas of uncertainty remain in determining hazards for chemicals. These deficiencies are generally well-recognised, and the reasons for not addressing them may be in part due to the complexity of the hazard and risk assessment that would be generated. Where such potential areas of hazard are not addressed there is a need to consider the extent to which a precautionary approach is needed and emphasis must be placed on critical monitoring/surveillance, preferably of the most sensitive indicators or ecosystems.

Areas of particular concern for nature conservation are:

. Sublethal effects. A range of end points may be used in hazard testing. The extent to which they represent the broad range of potential sublethal effects varies according to test procedures. For example there are often limited avian reproductive tests and there is variable use made of mammalian chronic endpoints in human vs other mammalian risk assessments. In aquatic risk assessments, tests of the order of months rather than days may more appropriate for some products, particularly if very bioaccumulative or accumulative in sediments. A critical area of uncertainty at present is endocrine disruptor effects. The present range of chronic and subacute tests used in pesticide registration, for example, is unlikely to have detected the imposex effect of TBT which has had such a devastating effect on certain marine mollusc populations and hence on marine ecosystems.

. Interactions between pollutants. At present the environmental effects of most chemicals are assessed in isolation even at the highest tier tests and despite widespread multiple exposure, and even in cases (eg OP insecticides) where similar modes of action suggest that an additive effect is likely, at least for some end points, if there is simultaneous exposure to more than one product. Synergy between chemical pollutants is well known (eg EBI fungicides and OP insecticides, and between different heavy metals) and between pollutants and other environmental factors (eg PAHs and UV light). The ecological significance of such interactions is poorly understood, and an understanding of such interactions may be crucial in understanding relative risks in particular environmental compartments. More emphasis needs to be placed on estimating total toxic burden in the environment, considering the effects of toxins in combination through an understanding of toxicity mechanisms.

. Metabolites: hazards arising from chemical metabolites receive variable consideration during regulatory processes. Assumptions may be made about metabolite hazard on the basis of the percentage of the parent compound and its relative persistence.

. A particular area of concern is the different metabolic pathways that may be followed by different stereoisomers. As a result, isomeric ratios in the parent may affect the concentrations of metabolites produced and this may have significant implications for the risk assessment.

3.2    Determining exposure:
The range of exposure pathways of concern for nature conservation is usually very much greater than for human health risk assessment. Often, however, there is insufficient knowledge at the initial stage of chemical registration to adequately predict all pathways of exposure (see for example evidence for exchange between marine and terrestrial systems and the widespread global transport of POPs). More data are needed on environmental loadings and distributions to improve our capacity to predict risks. Such monitoring data includes information on usage patterns or environmental loadings, as well as concentrations in the abiotic environment and in biota. The latter are considered under 3.4 below, however usage data - both predicted and measured - has an important place in helping to understand the scale and hence potential significance of long-term effects. Sources and loadings may change as a result of indirect, as well as direct, anthropogenic effects. For example effects of climate change on release of bound contaminants.

The provision of chemical usage data is very variable and the requirement for gathering such data varies among different chemical authorisation regimes. The range of pesticide (in the broadest sense) usage data collected was analysed in the recent report from the Pesticides in the Environment Working Group (PEWG) (Environment Agency, 2000). The MAFF/SERAD Pesticides Usage Surveys provide a good model of data collection in support of the pesticides registration process. By contrast, there are no regularly published or systematically collected usage statistics for veterinary medicines or for a wide range of other chemicals with a possible long-term environmental risk.

Recommendation: The RCEP study should consider the role, current scope and future requirements for chemical usage monitoring in assessing long-term risks of chemicals. The RCEP should also consider the extent to which all environmental pathways are fully covered in current risk assessments.

3.3    Risk assessment

. Population dynamics
In determining the acceptability of a particular risk for nature conservation it is usually necessary to consider effects at the population and often at the community level. The way in which risk assessments consider this varies. For example it may be adequate to consider critical load exceedence for some atmospheric pollutants without needing to predict consequent community effects on the ecosystem. In the case of many xenobiotics released to the environment comparisons are often made with an environmental standard or a toxicity: exposure ratio, both of which are single values. Other approaches may involve an assessment of percentile risk of exceedence or involve probabilistic approaches to exposure estimates.

Virtually no approach, however, takes full account of the dynamics of the populations in question. The roles of density dependence and of other key factors at sensitive stages of the life cycle are seldom incorporated into predictions based on chemical risk assessments, and our ability to predict effects at the population level from current toxicological studies is usually a significant limiting factor in the broader understanding of long-term ecological risk. Future attempts at linking effects on the individual to effects on the population have to adopt approaches that accommodate this problem. Long-term effects arising from short-term exposure are an important issue. Recovery rates of aquatic populations following acute pollution incidents can be considerable (although many species recover quickly as long as the chemical stressor does not persist), depending upon the mobility of the species, the location of the incident relative to recolonising populations, and obstacles to movement between the impacted area and recolonising populations. Ecological assessments of recovery rates could ultimately be built into risk assessment procedures, depending on the nature and location of use of a product.

. Safety factors: Safety (uncertainty) or assessment factors are widely used in risk assessment protocols for chemicals and in setting environmental standards to prevent long and short term risks to populations. The basis for the safety factors used is not always clear and different approaches may be adopted in different regulatory regimes (see for example RCEP study 1998). Selection of appropriate test organisms is also open to wider debate.

. Indirect effects: The indirect effects of pesticides on farmland biodiversity are considered to be one of the key concerns relating to the agricultural use of pesticides in the UK at the present time. Good experimental evidence exists for such effects on grey partridge populations and evidence is emerging from a number of studies including autecological studies commissioned by English Nature for similar mechanisms operating in a number of other farmland bird species (material can be provided). In this case the long term effects of chemicals are not due to the persistence of the chemicals in the environment or their bioaccumulation up food chains, but to the widespread, repeated use especially of broad spectrum products. Indirect effects are a potential consideration in other areas of nature conservation concern, including other xenobiotics (eg veterinary medicines such as anthelmintics which may have indirect effects on birds and mammals dependent on dung fauna). Indirect effects are not however considered during regulatory assessment processes. Such effects are among key concerns over the wider impacts of the commercial release of herbicide tolerant crops on farmland biodiversity and an ACRE subgroup has recently consulted on mechanisms for considering indirect effects during the process of authorisation of GM crops (DETR 2000).

. Precautionary approach: The requirement under the Habitats Regulations (Section 1.5 above) to demonstrate "no adverse effect" places a precautionary approach at the heart of decision making in the protection of Natura 2000 sites, with implications for long-term effects of chemicals as well as other activities at such sites. This provides an important and novel context for assessing the impacts of chemicals on the environment and is likely to have significant implications for dealing with existing areas of uncertainty.

3.4    Surveillance and monitoring:
Monitoring plays a key part in our understanding of the long-term effects of chemicals. It is an important part of confirming, at the large scale (ie commercial use), the outcome of risk evaluations undertaken during product registration or process authorisation. It is also an important means of detecting unforeseen changes in the environment as a result of exposure to chemicals. In the past we have been alerted to environmental problems as a result of monitoring contaminants in wildlife or their effects (eg OC residue problems and birds of prey) or changes in exposed populations (eg current declines in farmland birds). The main issues which we consider the RCEP study should address under this heading are:

. Inconsistency and inadequacy in the extent of monitoring for different chemicals. The monitoring of pesticide incidents and wildlife under the Wildlife Incidents Investigation Scheme (WIIS) is a useful model although the scheme is probably not sufficient to give adequate reassurance about acute lethal effects across all wildlife groups, and not able to detect sublethal or other chronic effects. Incidents relating to other types of chemical exposure (eg sheep dip) may be monitored by environment agencies. However surveillance monitoring for chemicals in the environment or contamination of wildlife generally is very patchy and very little monitoring is undertaken for the majority of chemicals in the environment. The JNCC supports a monitoring scheme for various persistent chemicals in certain top predators and rodenticides in red kites and barn owls (Newton et al 1997, 1999, 2000, Shore et al 2000). The requirement for and current extent of chemical monitoring in wildlife, and in the environment more widely, should be a priority for the RCEP study. This should include both surveillance for routine exposure as well as the capacity to investigate and detect novel environmental impacts, eg via investigations of major mortality incidents.

. Need for coordination of different monitoring activities for long-term effects of chemicals in the environment. Such a coordination effort has been initiated for pesticides by PEWG (Environment Agency 2000). There is a need for similar coordination of other chemical monitoring activities to ensure that monitoring undertaken by the various environmental agencies, conservation agencies, research institutes etc addresses areas of known or expected long-term risk and provides a means of alerting to the development of new risks in the future.

. There is a need for the development and implementation of better indicators of chemical effects in the environment, in particular through the development of better biomarkers or other toxicity responses as indicators of exposure to a range of environmental stresses. Such approaches are being developed for monitoring in the aquatic environment and for enforcement monitoring as toxicity based consenting methods. This is likely to a require a refocussing of current chemical monitoring.

. Examine the role of intact ecosystems in providing a source of early warning about potential long-term risks from chemicals. Modern intensive agriculture has simplified ecosystems to the extent that they may no longer function as indicators of adverse change, due to the increasing disassociation between biodiversity and crop systems. The importance of this and the degree to which such changes have affected other potential indicators of long-term change in the environment in other habitats should be considered.

. Examine the limitations of long-term monitoring as a tool to detect long-term change. Long-term monitoring may be a poor indicator in cases when short term exposure leads to a long-term effect, and especially when the vulnerable stage in a life cycle is very short. For example resource bottlenecks may mean that sampling taken after a critical resource period misses a short term impact.

Recommendation: The scope and practicality of offering mitigation measures to compensate for biodiversity impacts of chemicals such as pesticides used in agriculture should be investigated in the RCEP study.

4.    References:
Allen Y, Hurrell V, Jones C, Reed J and Matthiessen P (2001 - in draft) Endocrine Disruptors and European Marine Sites in England. Draft report to English Nature by CEFAS.

DETR (2000) Consultation document from the Advisory Committee on Releases to the Environment sub-group on wider biodiversity issues: Guidance on the Assessment of Risk to Wider Biodiversity from Proposed Cultivation of GM Crops (September 2000).

Environment Agency (2000) Monitoring of Pesticides in the Environment. Report of the Pesticides in the Environment Working Group.

Grimwood MJ and Dixon E (1997) Assessment of Risks Posed by List II Metals to Sensitive Marine Areas (SMAs) and Adequacy of Existing Environmental Quality Standards for SMA Protection. Report by Wrc to English Nature, March 1997.

House of Commons Agriculture Committee (2000) The Government's Proposals for Organophosphate Sheep Dips. Fifth report, May 2000.

Newton I, Dale L, Finnie JK, Freestone P, Malcolm H, Osborn D, Wright J, Wyatt C and Wyllie I (1997) Wildlife and Pollution: 1996/7 Annual Report. JNCC Report No 271.

Newton I, Dale L, Finnie JK, Freestone P, Wright J, Wyatt C and Wyllie I (1999) Wildlife and Pollution: 1997/8 Annual Report. JNCC Report No 285.

Newton I, Asfar A, Dale L, Finnie JK, Shore RF, Wright J, Wyatt C and Wyllie I (2000) Wildlife and Pollution: 1998/9 Annual Report. JNCC Report No 305.

Royal Commission on Environmental Pollution (1998) Twenty First Report: Setting Environmental Standards.

Scott CR, Hemingway KL, Elliot M, de Jonge VN, Pethwick JS, Malcolm S and Wilkinson M (1999) Impact of Nutrients in Estuaries. Report to Environment Agency and English Nature . EA R&D Project, i639.

Shore RF, Afsar A, Horne JA and Wright J (2000) Rodenticides and lead concentrations in red kites Milvus milvus. CEH Report to English Nature, June 2000.

Background
English Nature has identified pollution from diffuse agricultural sources as one of the major adverse impacts on aquatic wildlife in England. It also has serious public health and economic consequences, in terms of microbial and toxic risks to drinking and bathing waters and the siltation of reservoirs and surface drainage networks. A range of polluting substances are of concern, including nutrients, sediment, pesticides, heavy metals and degradeable organic material (the latter from livestock excreta).

In freshwaters, the most widespread and serious threats to wildlife from agricultural land are posed by excessive amounts of nutrients and sediment, entering rivers, streams, lakes and other waterbodies and producing insidious effects on resident plants and animals. Contamination of fresh waters by pesticides - from overspray, spray-drift and run-off - is also a major ecological threat and is addressed in a separate English Nature Position Statement.

Phosphorus is the nutrient of most concern in freshwater - elevated loads from agriculture and other sources lead to excessive growth of algae and a decline in aquatic flowering plants, together with the animal species dependent upon them for food, shelter and reproduction. Deoxygenation of the water and sediment also occurs, leading to suffocation of sensitive animals. Heavy sediment loads from agricultural land lead to accumulation of silt in river and lake sediments - this affects fish species such as the Atlantic Salmon (which needs clean gravels to spawn), and a range of aquatic invertebrates and rooted plants.

Causes of pollution
Elevated loads of phosphorus and silt from agricultural land are generated by the high net import of phosphorus onto intensively managed farms and increased soil erosion from a range of intensive farming practices, particularly the ploughing up of erosion-sensitive soils. The current crisis in the livestock farming industry is greatly exacerbating the problem by encouraging the ploughing up of permanent pasture for arable cultivation, particularly in the west of England on soils of high erosion risk. The outlook for livestock farming is poor, suggesting further deterioration of freshwater habitats. Efficient nutrient management and effective soil erosion control (including pasture retention and reversion where necessary), targeted at critical areas, are desperately needed to bring the situation under control.

Obstacles to resolving the problem
Current efforts to address the problem are largely of an advisory nature. The lack of progress in the following areas means that the problems continue to grow.

· Codes of good agricultural practice have been issued by MAFF, but research shows that they are not generally applied by farmers. Advice needs to be more proactive and farm-specific if it is to deliver tangible environmental benefits - it will never be sufficient in its own to resolve the issue.

· There are no obligatory mechanisms for ensuring that farmers act to control phosphorus and sediment losses from their land. It is vital that farming activity in high risk areas matches the environmental capability of the land to support agriculture without releasing excessive phosphorus and silt to receiving waters.

· There is no financial support available for preventing excessive phosphorus and soil loss to aquatic habitats through the adoption of appropriate land use and land management practices.

· Farm quality assurance schemes do not address diffuse pollution in a verifiable way, so consumers have no opportunity to favour low-pollution farming enterprises.

Such an approach will need to be adopted in order to fulfil the requirements of the European Water Framework Directive over the next decade. In the short-term, there is a need for urgent action within the catchments of sensitive rivers and lakes designated for their freshwater wildlife interest. In an international context, action on diffuse agricultural pollution is needed now to bring many freshwater Special Areas of Conservation (SACs, designated under the European Habitats Directive) into favourable condition within the required timescales. Nationally, achieving favourable condition within the freshwater SSSI network will also be dependent on a speedy resolution to this problem.

English Nature's position
Our priority is to bring freshwater SACs and SSSIs affected by diffuse agricultural pollution into favourable condition through efficient nutrient management and best practices for soil erosion control, implemented through coherent farm plans. We shall:

· work with others to raise awareness of the impacts of diffuse pollution on biodiversity and the need for sustainable management of the land;

· work to identify the statutory sites most affected by diffuse pollution and help to devise land management strategies to tackle the causes;

· continue to work with the Environment Agency, FRCA, FWAG and the farming community to encourage best practice in land management;

· collaborate with MAFF and others on research into techniques for assessing and controlling diffuse pollution by nutrients and siltation;

· work with key partners to remove constraints on bringing about desired changes in farming practice, including:

o proposals on the innovative use of agri-environment funds and other sources of grant aid, targeted at land of highest pollution risk and aimed at maintaining the viability of farms that are managed in an environmentally sympathetic way;
o the introduction of robust and enforceable criteria on diffuse pollution control into farm quality assurance schemes;
o an examination of the suitability of existing regulatory controls, such as Water Protection Zones, and the development of new measures that could be brought in under the Water Framework Directive; o an investigation into the feasibility of applying economic instruments to particular aspects of the problem.

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