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SID 5 Research Project Final Report

SID 5 (Rev. 3/06) Page 1 of 30

NoteIn line with the Freedom of Information Act 2000, Defra aims to place the results of its completed research projects in the public domain wherever possible. The SID 5 (Research Project Final Report) is designed to capture the information on the results and outputs of Defra-funded research in a format that is easily publishable through the Defra website. A SID 5 must be completed for all projects.

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Project identification

1. Defra Project code PS2611

2. Project title

Costs associated with changing pesticide practices

3. Contractororganisation(s)

ADAS UK Ltd

54. Total Defra project costs £ 18,834(agreed fixed price)

5. Project: start date................ 01 February 2006

end date................. 31 July 2006


6. It is Defra’s intention to publish this form. Please confirm your agreement to do so...................................................................................YES NO (a) When preparing SID 5s contractors should bear in mind that Defra intends that they be made public. They

should be written in a clear and concise manner and represent a full account of the research project which someone not closely associated with the project can follow.Defra recognises that in a small minority of cases there may be information, such as intellectual property or commercially confidential data, used in or generated by the research project, which should not be disclosed. In these cases, such information should be detailed in a separate annex (not to be published) so that the SID 5 can be placed in the public domain. Where it is impossible to complete the Final Report without including references to any sensitive or confidential data, the information should be included and section (b) completed. NB: only in exceptional circumstances will Defra expect contractors to give a "No" answer.In all cases, reasons for withholding information must be fully in line with exemptions under the Environmental Information Regulations or the Freedom of Information Act 2000.

(b) If you have answered NO, please explain why the Final report should not be released into public domain

Executive Summary7. The executive summary must not exceed 2 sides in total of A4 and should be understandable to the

intelligent non-scientist. It should cover the main objectives, methods and findings of the research, together with any other significant events and options for new work.

ObjectivesFollowing the publication of the Royal Commission on Environmental Pollution (RCEP) report on Crop Spraying and the Health of Residents and Bystanders, PSD identified several areas for action, and required a review of options and costs of topics associated with buffer zones, notification of pesticide applications, disclosure of information, and other legislative and certification changes. In this report, the national costs to farmers, government and private industry, associated with various options, have been considered along with the distribution of impacts within the farming industry.

Costs of OptionsThe options considered and the estimated costs are summarised in Table 1. All costs, other than the costs associated with monitoring and enforcement of a statutory Code of Practice, accrue to the industry.

Neighbour consultations for public registrationThe costs of the topics marked with an asterisk (Table 1) could be dependent upon public uptake/registration and the costs presented represent the highest costs. In practice it is likely that these costs could be reduced significantly depending on the level of public registration. The pesticide notification methods study (ADAS, 2005) suggested that, although over 75% of adjacent residents were interested in being notified of pesticide applications, only 8% took action to source the information themselves (via internet or telephone) and only 20% took action as a result of the leaflet notification. At low levels of public registration the costs associated with neighbour consultation may exceed the cost of the measure such as no spray buffer zones or notification.

Distribution of Notification CostsThe distribution of notification costs (neighbours and public rights of way) across the industry varies significantly, with those with the highest notification level bearing the greatest cost – this will include horticulture businesses where the number of spray passes is greatest and larger arable and horticulture farms. Examples of the range of notification costs are shown in table 3. The notification level is an indication of the likely number of notification given the type of cropping, location of land and the number of adjacent properties and the size of the farm.

Impact of measures at an individual farm levelThe additional annual costs of the measures for a medium sized combinable crop farm are £277 based on leafleting as the notification option and existing membership of NRoSO, which represents less than 1% of the profit. If other notification options were to be considered the annual cost could be up to £206 higher. The location of the farm and its proximity to housing will make a difference to the notification costs. The same farm in a more rural location would have additional costs of £100 per year, and in a more urban situation up to £2617.


The additional annual costs of a small top fruit farm are high. Despite being a small farm with low costs of notification, the additional costs of training and NRoSO membership result in the total costs to this business of £582 per annum, which represents over 11% of the profit. Buffer zones and notification costs (leafleting) of £134 represents 2.5% of the profit, assuming that there are no footpaths on such a small farm.

The total additional costs for a medium sized dairy farm are in the region of £509 per annum representing 1.58% of the profit. The notification and buffer zone costs are low at only £34 per annum or 0.1% of profit. The main costs occur due to the training and sprayer testing requirement.

Table 1 Summary of options and costsTopic Options Total cost

100% uptakeWhosecost?

Comments

Publicity £25,000 –£500,000

Govt

Neighbourconsultation

£4.2m Farmer Neighbour consultation could be used inorder to reduce the need for bufferzones and notification measures

Buffer zones* 5m no-spray bufferzone – with opt-in

£4.8m Farmer Neighbour consultation could reduce therequirement (Table 2)

No-spray buffer withset-aside

£0 – £4.8m Farmer Neighbour consultation could reduce therequirement (Table 2)

Notification* Telephone –SprayWatch

£17.0m Farmer Some costs could be passed to public

Internet –SprayDays

£2.9m Farmer 14% of holdings only to allow foraccessibility

Leaflets £16m Farmer Neighbour consultation could reduce therequirement (Table 2)

Local plans £9.9m Farmer Neighbour consultation could reduce therequirement (Table 2)

Public rights ofway

PROW notices £6.1m Farmer

RangeDisclosure Direct £0.25m Farmer £86,000 - £1.7m depending on numbers

requestedThird Party £0.5m Farmer/

Govt£150,000 - £3.4m depending onnumbers requested

Statutory Codeof Practice

Monitoring andenforcement

£3.3m Govt £1.6 - £16.4m depending on level ofmonitoring

Other potentialfarmer costs

£42m Farmer Some costs may be mitigated throughrequirements of other schemes

Removal ofgrandfatherights

£25m Farmer £0 - £39m

Topic Options Total cost100% uptake

Comments

Qualificationsor purchase

£0.75m Farmer Requirement for BASIS advice.Additional costs of removal ofgrandfather rights for Certificate ofCompetence

Continuedraining

NRoSO £8.7m Farmer/contractor

Retest £6.0m

Sprayeresting

£14.5m Farmer Annual cost for all sprayers


Table 2 Change in costs following neighbour consultations and levels of public registration% public registration

100% 75% 33% 8%Cost of neighbour consultation (NC) £4.2m

No spraybuffer zones

5m no-spray bufferzone with publicopt–in

£4.8m £3.6m £1.4 £0.4

5m no-spray bufferzone with set-aside

£0 –4.8m

£0 –3.6m

£0 –1.4m

£0 –0.4m

5m buffer zone withconsultation costs

£9.0m £7.8m £5.6m £4.6m

Notification Telephone –SprayWatch

£17m £12.8m £5.2m £1.3m

Including NC costs £21.2m £17.0m £9.4m £5.5mInternet –Spraydays

Self registration

Leafleting £16m £12.0m £5.2m £1.3mIncluding NC costs £20.2m £16.2m £9.4m £5.5mLocal plans £9.9m £7.4m £3.3m £0.8mIncluding NC costs £14.1m £11.6m £7.4m £5.0m

Table 3 Costs per holding for different notification requirementNotification method Notification Level

Low Medium High AverageNeighbour consultation £8 £38 £116 £22Telephone – SprayWatch £44 £162 £362 £109Internet – Spraydays - - - £107Leaflets £10 £159 £595 £84Public rights of way notices £18 £61 £78 £32

Project Report to Defra8. As a guide this report should be no longer than 20 sides of A4. This report is to provide Defra with

details of the outputs of the research project for internal purposes; to meet the terms of the contract; and to allow Defra to publish details of the outputs to meet Environmental Information Regulation or Freedom of Information obligations. This short report to Defra does not preclude contractors from also seeking to publish a full, formal scientific report/paper in an appropriate scientific or other journal/publication. Indeed, Defra actively encourages such publications as part of the contract terms. The report to Defra should include: the scientific objectives as set out in the contract; the extent to which the objectives set out in the contract have been met; details of methods used and the results obtained, including statistical analysis (if appropriate); a discussion of the results and their reliability; the main implications of the findings; possible future work; and any action resulting from the research (e.g. IP, Knowledge Transfer).


1.0 IntroductionFollowing the publication of the Royal Commission on Environmental Pollution (RCEP) report on Crop Spraying and the Health of Residents and Bystanders, Pesticide Safety Directorate (PSD) has identified several areas for action, and requires a review of options and costs. There are two main themes, firstly issues concerned with buffer zones, notification of adjacent residents and records disclosure, and secondly issues concerned with certification of spray operators and purchasers and the legal status of current measures.

ADAS UK Ltd has been asked to review the options within each topic and estimate the associated costs of any changes.

2.0 BackgroundIn July 2003 PSD carried out two public consultations seeking views on no-spray buffer zones and how residents could best be informed about pesticide use. Following the consultation, the Government asked the RCEP to examine the scientific evidence surrounding bystander exposure. This report was published in September 2005 and recommended changes to safeguard the health of those living near sprayed fields and to the regulation of pesticides. This included better enforcement of the rules governing the use of pesticides on farms and the introduction of additional measures over and above the current measures employed to give further protection to the public.

Prior to the publication of the RCEP report, PSD had commissioned ADAS UK Ltd to carry out a field evaluation of pesticide notification methods1, and a survey of farmers and neighbours attitudes. That study involved a series of consultations with residents living adjacent to sprayed land to seek their views, followed by a field trial of different methods of notification of pesticide application – telephone answer machine, internet notification, leafleting and public rights of way notices - during a period April to June 2005. Farmers and adjacent residents were interviewed following the field trial to gauge their views. The main conclusions were that the interest of the public was variable, with three quarters expressing an interest in notification, but only 8% taking action to gain the information. Leafleting was the most popular method amongst the adjacent residents as it required no action on their part. Farmers found all methods time consuming. As part of the RCEP report on bystander exposure a report on the costs of no-spray buffer zones on arable and horticultural land was commissioned from Agra CEAS 2. This concluded that the cost of a 5 m buffer zone would cost the industry £1.64 million, based on crop being produced but not sprayed. In practice this is unlikely to happen given the perceived problems of spread of weeds, pests and diseases into the crop. This attitude is reflected in the relatively poor uptake of the arable field margin option in Environmental Stewardship. Another study commissioned for the RCEP report, and carried out by the Centre for Ecology and Hydrology (CEH)3 in 2005, has given useful data on the length of arable and horticulture boundary with adjacent properties and an estimate of the number of adjacent properties. This information has been fundamental in assessing some of the costs in this report.

3.0 ObjectivesThe objective of this project is to provide information to PSD to assist in policy decisions. Within this objective, the project aims are to:1. Give an overview of current minimum standards for ensuring public safety during pesticide use, the further

requirements under crop assurance schemes and the Voluntary Initiative, and the additional measures required under the options identified.

2. Having identified and agreed the most practical options with PSD, analyse the costs for each option to give costs to the industry (drawing on information from the Pesticides Notification Methods Study), Government and private individuals. In addition farm costs will be examined to give an indication of the distribution of costs across the industry.

3. Analyse impacts on each sector and carry out a small business impacts test.

4.0 Approach and MethodologyThis study aimed to review costs associated with implementing the different options using information currently available, including information from the Pesticide Notification Methods Study (ADAS, 2005) and assumptions based on consultation with appropriate trade/industry bodies and our knowledge of the industry. Any area where more detailed information is required is highlighted.

1 ADAS UK Ltd (2005) Notification of neighbours of pesticide applications: a field evaluation of methods and survey of farmers and neighbours attitudes.2 Agra CEAS Consulting Ltd (2005) Potential economic and financial impact of buffer zones.3 Centre for Ecology and Hydrology (2005) National estimates of residential land adjacent to arable land using Countryside Survey sample data


5.0 Overview of Current Requirements and enforcement for Operator Training and Public Safety during Pesticide Applications

The new Code of Practice for using Plant Protection Products4, was published in January 2006, which is the key publication for farmers and growers who apply pesticides as it outlines the legal requirements in relation to pesticide applications. There are also crop quality assurance schemes and the Voluntary Initiative which have no legal status but may have a bearing on compliance and enforcement of the Pesticide Code.

6.0 Terminology and background data used in no-spray buffer zone and notification cost analyses

The data and assumptions used in the no-spray buffer zone and pesticide notification cost analyses are given below. Assumptions specific to other cost analyses are in the relevant sections.6.1 Type of Notification of Pesticide Application (NPA) There are two main alternative types of notification for residents of adjacent properties:

1. Property based direct notification where the individual adjacent properties are notified of pesticide applications. Methods of direct notification include leafleting or telephoning residents and put the onus on the farmer to supply the information individually to each resident who do not need to take any action themselves. There is usually direct contact with the individual residents and farmers must issue a notification for each adjacent property.2. Field based remote notification where the farmer makes a notification for a field and residents of any adjacent properties are either notified automatically or seek the information themselves. Methods include internet, automated telephone messaging or public notice board. There is no direct contact between the resident and the farmer and the farmer need only issue the information once per field rather than to each adjacent property.

Direct notification tends to be more popular with the adjacent residents and in the Pesticide Notification Methods Study, leafleting was the favoured method with the adjacent residents. Farmers on the other hand, preferred the remote notification methods which were seen as less time consuming, particularly when there is a high number of adjacent properties.In addition users of public rights of way will require notification through notices:Public rights of way (PROW) notices would be posted at visible points at the entrances to fields that are due to be sprayed, or have just been sprayed. Typically one field would have two notices if a path crosses or runs alongside the field.6.2 Number of holdingsData from Agriculture in the United Kingdom 2004 (AUK2004) gives the number of holdings in different size bands (measured in European Size Units (ESU), which use standard gross margin as a measure of size). The impact of pesticide application notifications will rest with the 190,000 holdings in the main farm categories (the 97,000 holdings classified as other, of which 70,000 are under 8 ESU/ha, are not included in calculations in this report, as they are unlikely to be productive agriculture units). Of these 190,000 holdings there are approximately 47,600 arable and horticulture holdings (26%), 118,000 mainly grassland holdings (56%), 10,000 mixed units (9%) and 8200 intensive livestock holdings (4%) (Table 1). These figures for holdings will slightly over estimate the number of businesses because it is not unusual for one business to operate on more than one holding, especially among larger businesses

Table 1 Number of holdings in UK by farm type <40 ESU 40-100 ESU >100 ESU TOTAL

Dairy 6,100 11,100 6,400 23,600

Cattle & Sheep LFA 44,800 5,700 800 51,300

Cattle & Sheep Lowland 40,800 1,800 400 43,000

Pigs and Poultry 6,300 900 1,000 8,200

Cereals 14,200 6,700 4,600 25,500

General Cropping 3,400 3,700 4,300 11,400

Mixed 8,500 3,000 2,200 13,700

Horticulture 8,700 1,300 700 10,700

Other 90,700 <100 <100 90,700

TOTAL 223,500 34,200 20,400 278,100

Estimated total applying pesticides 132,800 33,300 19,400 187,400

4 Defra (2006) Code of practice for using of plant protection products


% of total in each size band 71% 18% 11%

Source: AUK20046.3 Number of adjacent propertiesThe number of adjacent properties is important when using direct notification methods, and remote notification methods with automated delivery. Work carried out the Centre for Ecology and Hydrology (CEH)5 for the RCEP report, using Countryside Survey sample data estimated the total length of boundaries between residential land, and arable and horticultural land in Great Britain, at about 20,700 km. In the same analysis the number of properties bordering arable and horticultural land was estimated at 500,000, and the number of people resident in these properties between 1 and 1.5 million (Table 3). Table 2 Length of boundary, adjacent properties and residents adjacent to arable and horticulture land estimated from Countryside Survey sample data.

Region Length of boundary (km)

Number of properties adjacent to arable and horticulture land

Number of residents

England and Wales 18,540 450,000 1.1 millionScotland 2,130 50,000 0.1 millionGreat Britain 20,700 500,000 1-1.5 millionSource: Centre for Ecology and Hydrology (CEH)With 500,000 properties adjacent to arable and horticulture land and approximately 61,300 arable and horticulture holdings (AUK 2004), this gives an average number of properties per holding of 8, however this is likely to hide a wide range from 0 to potentially over 100 adjacent properties. There is no survey data on the number of properties adjacent to temporary grassland. However, given that arable and horticulture holdings make up around 27% of the agriculture land in the UK (Table 4), and that temporary grassland and fodder crops make up 9%, a pro rata distribution would result in a further 150,000 properties which are adjacent to farms with temporary grassland or fodder crops sprayed with pesticides. This gives an estimated total number of properties, adjacent to land that might be sprayed, of 650,000.6.4 Number of Fields with adjacent propertiesThe number of fields with adjacent properties is important when using remote methods of notification. There is no published information on the number of fields with adjacent properties. A range of between 1 and 20 per farm was used in the Pesticide Notification Methods Study to cover the range of rural and urban locations, and different sized farms. There are an estimated 1.4 million fields in the UK, based on 11.5 million ha of arable, horticulture and temporary grassland with an average field size of 8 ha. In the Pesticide Notification Methods Study the proportion of fields with adjoining properties per holding with adjacent property, ranged from 10% in rural areas to over 50% in the more built up areas. An estimated figure of 25% of fields with adjacent properties would result in 350,000 fields. For 190,000 holdings (AUK2004), this would give an estimated average figure of 1.8 fields with adjacent properties per holding. The range could be from 0 on small, rural units to over 50 in larger units in highly populated areas. This issue of field numbers would merit further study to validate these estimates. 6.5 Cropping and number of pesticide applicationsThe number of times a field is sprayed with pesticides is related to the type of crops grown. Data from the Pesticide Usage Survey (Table 4) gives an indication of the number of pesticide applications in each of the crop types. Arable crops were sprayed on average 5.3 times in a year. Orchard crops, hops and outdoor bulbs were sprayed over 13 times in a year. The higher intensity spraying was, however, on less than 0.5% of the cropped area of the UK. Grassland and fodder crops were sprayed on average 1.6 times per year, but this is likely to be predominantly on temporary grassland rather than on permanent grassland which is sprayed very infrequently and often only in patches to control thistles or nettles. Rough grazing is never sprayed. Only one third of farmland in the UK is regularly sprayed.Table 3 Pesticide Applications per CropCrop Group No. of sprays

applied per annum per field*

UK area of farmed land 2005 (‘000ha)***

% of farmed area 2005

Arable crops 5.3 4089 26Grassland and fodder crops

1.6 1400 9

Permanent Grass 0** 5710 36Rough Grazing 0** 4381 28Vegetable crops 5.9 120 0.76Orchard fruit 14.1 25 0.16Soft fruit 7.3 20 0.13Hops 14.3 1 0.01Outdoor bulbs 13.4 5 0.03*Source: Pesticide Usage Surveys 173, 181, 172, 195, 188, 187.

5 Centre for Ecology and Hydrology (2005) National Estimates of residential land adjacent to arable land using Countryside Survey sample data, www.rcep.org.uk/pesticides


**Assumption***Source: Defra statistics 20056.6 Distribution of ImpactsIn order to assess the distribution of impacts from notification measures, farms can be categorised into three levels of notification - low, medium and high (Table 5). Low notifications levels will tend to be found on grassland farms that have lower spray passes per year, small arable farms (as they will tend to have fewer neighbours or fields with adjacent properties), and farms in more rural settings with low density housing. Medium notification levels will be found on arable farms as they have more passes per crop, small horticulture units and in more densely populated areas. High notification levels will be found on large arable farms as they are more likely to have more fields with adjacent properties, horticulture units with high spray passes per crop and farms in urban/high density housing situations.Table 4 Notification classifications and number of notificationsNotification classification

Description

Low notifications Grassland farms, small arable farms, rural locationMedium notifications Arable farms, small horticulture units, village locationsHigh notifications Large arable farms, horticulture units, town or urban locations

Applying these categories to the number of holdings by farm types and sizes (Table 1) the number of holdings in each notification level can be estimated. Of the 190,000 holdings, 72% of holdings fall into the low notification level, or 136,000 holdings, with 21% or 41,000 holdings in the medium notification level and the remaining 7% or 13,200 holdings with high notification level (Table 6). This last category will bear the highest burden of any measures implemented.Table 5 Number of holdings in each notification level Notification level Categories of farm type (from Table 1) Number of

holdings% of total

Low All dairy, cattle and sheep, pigs and poultry and small mixed farms

136,000 72%

Medium Small horticulture farms, small and medium cereal and general cropping and medium mixed farms

41,000 21%

High Large cereal, general cropping, mixed farms, medium and large horticulture farms

13,000 7%

TOTAL 190,000Source: AUK 20046.7 Estimated number of notificationsUsing the information and estimates of farm holdings, adjacent properties, fields with adjacent properties and spray passes detailed above, an estimate of the number of annual direct or remote notifications can be calculated. Farmers in the UK would make in the region of 3.1 million direct notifications and 1.3 million remote notifications at 100% public registration. Sensitivity If the average number of adjacent properties was 1 million (rather than 650,000) the number of direct

notification will increase to almost 5 million with 5.3 properties per holding. If the average number of fields with adjacent properties was increased to 500,000, the number of remote

notifications would increase to almost 2 million.Based on information available the likely number of direct notifications will be 3.3 million (190,000 holdings with average of 3.5 adjacent properties per holding, or 650,000 adjacent properties, based on CEH figure for adjacent properties plus pro rata for temporary grassland), but could be as high as 5 million (190,000 farm holdings with average of 5.3 adjacent properties per holding, or 1 million adjacent properties). The number of remote notifications is likely to be around 1.3 million (190,000 holdings with 1.8 fields having adjacent properties per holding), but could be as high as 2 million (190,000 holdings with 2.8 fields having adjacent properties per holding).6.8 Annual Prior RegistrationNot all residents of adjacent properties will be interested in individual pesticide application notifications. In the Pesticide Notification Methods Study, three quarters expressed an interest in being notified following an introductory letter. However, where the internet or recorded telephone message methods were used, only 8% registered or telephoned for information. On this basis the number of notifications could be reduced quite dramatically (Table 7).Table 7 Estimated national notification numbers at different levels of prior registration

% prior registration100% 75% 33% 8%

No. direct notifications 3,100,000 2,325,000 1,100,000 264,000No. remote notifications 1,300,000 975,000 430,000 100,000


7.0 Options and Costs

7.1 Public and farmer awareness of notifications measuresWhichever options are chosen for field and footpath notifications it will be important to increase awareness and knowledge amongst residents, users of the countryside and farmers and spray operators. A regional and national media campaign (TV, radio and press) would cost in the region of £25,000 for an initial campaign and up to £500,000 for an ongoing multi-media campaign. In addition, information via a website and perhaps information packs for farmers could be considered. Duration of such awareness programmes affects the total cost.7.2 5 m no-spray buffer zones A 5 m no-spray buffer zone between pesticide applications and adjacent properties has been recommended by the RCEP report in which no pesticide applications would be allowed. In arable and horticulture enterprises it is most likely that the buffer zones would remain uncropped. There is a possibility that this could be entered into set-aside or as part of cross compliance requirements or other agri-environment scheme. In grassland, the crop would be present but would remain unsprayed. The uncropped no-spray buffer zone is likely to be perceived as more beneficial than a cropped area, in terms of clarity for the residents and for monitoring.Given the range of adjacent properties not all residents may require, or be interested in, no-spray buffer zones. For instance, if there is a high wall, fence or hedge bordering the property, or if the property is some distance from the boundary. Other residents may prefer to have the crop close to the border in order to prevent increased access to the rear of the property, or to stop ingress of undesirable weeds such as thistles or docks. In these situations the resident may wish to choose to opt-out of the requirement for farmer to have a no-spray buffer zone. However this is only likely to be of practical value where a few “commonly minded” residents of properties are involved and it could be difficult to provide for this flexibility within a statutory scheme. The obvious cost for farmers is in the loss of production from the land. The no-spray buffer zones will also incur costs through the time taken to measure and mark out the the zones, and in completing forms for the Single Payment Scheme. These costs could potentially be mitigated by using the uncropped area as set-aside or under Entry Level Scheme measures (currently 12,000 agreements covering 1,390,000 ha).

Cost analysis options: 5 m no-spray buffer zone next to adjacent properties Impact of SPS or agri-environment schemes on 5 m no-spray buffer zones Practicalities and financial impact of opt-in/opt-out option Practicalities and financial impact of larger buffer zone

5 m no-spray buffer zone next to adjacent properties on all farmed land All farmed land adjacent to properties will be required to have a 5 m buffer strip in which no pesticide applications will be allowed. This area will be uncropped in arable, fodder and horticulture crops, but can remain cropped but unsprayed in grassland fields. Costs will mainly accrue to the farmer with lost income from uncropped area and the time taken to mark out the areas. There may be some marginal benefits from improving field shapes and reducing field travelling and compaction. Production from the headland area is often less than the main part of the fields due to compaction, higher weed populations and less nutrients or moisture due to competition from hedges etc. The costs of lost production will relate to the marginal costs of production as the area taken out of production will rarely affect the fixed costs of the business. The gross margin of each farm type can, therefore, be taken as representing typical costs of lost production, adjusted to take into account the likely lower production from headlands. In this case the adjusted headland gross margin is assumed to be 70% of gross margin (Table 8). The impact from no-spray buffer zones will be minimal on livestock farms where grassland will be left unsprayed, but can still be fertilised and utilised by the livestock. There may be fodder crops grown adjacent to properties, in which case there would be losses from not growing the crop. Table 8 Farm type gross margins and number of holdings

Farm Type Standard classification

Gross margin (£/ha)*

Adjusted headland gross margin (£/ha)**

Number of holdings***

Approx arable area (ha)****

General Cropping 181 127 11,400 1.4 millionCereals 432 302 25,500 3.2 millionMixed 596 417 13,700 1.7 millionHorticulture 8885 6220 10,700 0.17 millionSource: *Defra Farm Business Survey 2003/2004 adjusted to remove AAPS income

**70% of gross margin***AUK 2004****Derived from crop areas and number of holdings

CEH estimated that the length of boundary between arable and horticulture enterprises and residential properties was 20,700 km. A 5 m buffer zone would result in 10,350 ha coming out of production. If this area was left uncropped the potential cost of lost production would be almost £4.8million (Table 9). Horticulture accounts for

SID 5 (Rev. 3/06) Page 10 of 30

40% of this potential loss, and equates to £177/holding compared to £26/holding for general cropping, £59/holding for cereals and £80/holding for mixed farms. Table 9 Potential cost of buffer strip in arable and horticulture

Crop Type Adjusted headland gross

margin

Length of boundary (out of 20,700km total)*

Area taken out of production at

5m

Potential cost to the industry

£/ha Km Ha £General cropping

127 4,500 2,250 £0.3 million

Cereals 302 10,100 5,050 £1.5 millionMixed 417 5,500 2,750 £1.1 millionHorticulture 6220 600 300 £1.9 millionTotal 20,700 10,350 £4.8 million*Pro rata based on % of areaThese figures do not, however, take into account the potential increased length of buffer strip if adjacent properties are intermittent along the boundary which could increase the lost production by as much as 50%.

Impact of SPS or agri-environment schemes on 5 m no-spray buffer zonesIf the no-spray buffer zones can be managed within, or integrated with, other schemes such as Cross Compliance, Entry Level Scheme or Set-aside, many of these costs could be reduced to zero. There are ways to operate within the current rules of these schemes, but a better option would be to have the requirement as a Statutory Management Requirement under Cross Compliance or if possible a requirement with allocation of points under the Entry Level Scheme. The current rules of the various schemes do not allow any one single scheme to be applicable in all situations but offer a variety of options to help mitigate the costs. Practicalities and financial impact of opt-in/opt-out optionNo-spray buffer zones adjacent to properties may give a perceived feeling of comfort to adjacent residents with respect to the issue of spray drift. It will not address the concerns of those residents who feel that a much larger buffer zone is necessary to protect human health. In some cases it may have an adverse effect on public confidence in that it could give the impression that there is a health risk associated with spraying right up to their boundary. The simplicity of all adjacent properties having a buffer strip means that the potential for dispute is reduced. However this lacks flexibility for those premises that are some distance from the field being sprayed or have high hedges/fences or other barriers between the crop and the property. Uncropped strips can also lead to increased access, for dog walking, playing, garden waste dumping etc. Increased accessibility may also increase the risk of burglary. There could be advantages in allowing residents to opt-in, to specifically request a 5 m no-spray buffer zone, or opt-out to elect not to have a 5 m no-spray buffer zone. This is likely to reduce the need for buffer zones and may be advantageous for farmers who do not have the option of set aside or other schemes, in particular growers of horticultural crops. The costs of registration will be an additional cost, but at a local level it could improve dialogue between farmers and residents.

Local registration would require all farmers with fields that will be sprayed adjacent to properties, to contact the residents and ask whether they would like to be notified or have a buffer strip adjacent to their property. This could also apply to pesticide application notification measures.

The main costs involved will be the time taken by the farmers to contact adjacent property holders. This could take the form of a leaflet dropped through the doors of adjacent properties, local meetings, or simply a telephone call where neighbours are already known. This would be done once per year.

The time taken for this will vary considerably for each farmer depending on the number and location of the different properties. If all adjacent residents are initially contacted by leaflet, the annual costs to farmers for consulting with 650,000 adjacent property holders is in the region of £4.2million (Table 10). Some of this consultation will already be taking place on an informal basis so the main additional cost will be the formalisation and the record keeping. It will be important to carry out annual neighbour consultation to accommodate any changes in ownership or views.

Table 10 Annual running costs for local farm notification plansAction Unit Cost National Annual

Cost

Production and delivery of 650,000 leaflets

£2.20 £1,430,000

Management of register 1.0 hour per year per farm @£15/hr £2,850,000Total £4,200,000

SID 5 (Rev. 3/06) Page 11 of 30

Cost per holding £22

There will be unequal distribution of consultation costs, with larger farms, or those in more densely populated areas having higher costs (Table 11).

Table 11 Distribution of consultation costs% properties Consultation cost Cost per holding

Low 27 £1,100,000 £8Medium 37 £1,500,000 £38High 36 £1,500,000 £116TOTAL 100% of 650,000 £4,200,000 £22

Farmers could of course choose not to consult with the neighbours and simply install a no-spray buffer zone or carry out notification without any of these costs. This is most likely to be the case for areas with high adjacent populations. The cost of consultation is almost as high as the cost of installing a buffer strip and even at the lowest level of uptake, the costs of consultation are still in excess of the no-spray buffer zone costs (Table 12). This situation would change, however, if the consultation costs were being incurred for notification purposes in addition to the no-spray buffer zones, when there may be a case for a neighbour opt-in for no-spray buffer zones.

Table 12 Costs of no-spray buffer zone with resident opt-in% resident opt-in

100% 75% 33% 8%Potential cost £4.8 million £3.1 million £1.4 million £0.4 million

Neighbour consultation

£4.2 million £4.2 million £4.2 million £4.2 million

Total £9.0 million £7.3 million £5.6 million £4.6 million

7.3 Notification of Pesticide Applications – (a) Adjacent PropertiesThree main methods of notification were evaluated in the Pesticide Notification Methods Study – telephone answer machine, internet and leafleting. The internet and leaflet notification methods had the advantage of being consistent with the presentation of the information whilst the telephone and leaflet notification had the advantage of being easily accessible by all farmers and public. The internet method could be made more accessible through operation of a bureau service, and other methods such as a simple telephone call to a neighbour, may be appropriate in some circumstances. The practical advantages and disadvantages of each method, and the costs to farmers have been covered in the Pesticide Notification Methods Study, but the costs have been updated in this report.

Options for adjacent resident notification: National automatic telephone notification system with and without prior registration, based on the New

Zealand SprayWatch system. National internet/bureau notification system with and without prior notification, based on Spraydays system

used in the Pesticide Notification Methods Study. Local notification system (individual farm based) with and without prior registration. Leafleting with and without prior registration.

National automated telephone notification system - SprayWatchA system called SprayWatch is operational in New Zealand. This is an automated telephone based service paid for by the farmers. Farmers register their farm and their neighbours who wish to be notified (application form in Appendix 5). The farmer is issued with a PIN number. Farmers telephone the SprayWatch number and record a spray notification message prior to the pesticide applications. SprayWatch calls the identified neighbours and plays them the recorded message with a requirement to press a key on the telephone pad to acknowledge receipt. Messages are sent between 7am and 9pm. Charges are a service fee of £7 per adjacent property, a base fee of £23 per farm per annum, and call charges of 49p for each recorded message and 31p for each delivered message. Potential disadvantages are the inconsistent format of the telephone message, which was a problem in the Pesticide Notification Methods Study, however this could be overcome by the use of a proforma. Farmers in the Pesticide Notification Methods Study also found that leaving a message was time consuming, particularly gathering the information for the message. Not all farmers felt comfortable with leaving the messages and they were frustrated when they made errors and had to start again. Farmers with several fields with adjacent properties need to leave a message for each field.

The capital cost of setting up the NZ SprayWatch service is not available at the time of writing.

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A similar system in the UK would cost the 190,000 farmers approximately £17 million, of which £10.5 million is service charges, but there is the possibility that the recipients of the telephone calls could pay a proportion of this cost. If the profits made on the SprayWatch system are not large then the fees will largely reflect the cost of operation. Costs may be reduced as not all residents will require notification, and therefore not all farmers would need to register with the service. A local prior registration consultation with neighbours as in section 7.1 would cost around £4.2 million but could reduce the costs significantly (Table 13).Table 13 Effect of neighbour consultation on SprayWatch costs

% prior registration100% 75% 33% 8%

Potential cost £17 million £12.7 million £5.2 million £1.3 millionNeighbour consultation


Total £21.2 million £16.9 million £9.4 million £5.5 millionCost per notification

£16

Cost per farm £109

The costs will not be borne equally by the industry. Large farms, with intensively sprayed crops or in highly populated areas will have higher costs than smaller, more remote farms (Table 14). The average cost for low notification farms is £44/year, compared to £362/year for high notification farms. The average over all farms is £109/year. These costs are the full costs of all farms registering and all adjacent properties being notified and could be reduced by prior registration of adjacent residents. By passing the cost of registration of properties and phone calls to these residents, costs to farmers could be reduced by about one third.Table 64 Distribution of SprayWatch service costsNotification Level

Number of

holdings

Holding Base fee

(£23 each)

Cost of leaving

messages

Neighbour fee (£7

each)

Cost of deliverin

g messag

e

Total Service

Cost

Cost of farmers time

Total Cost per

holding

Low 136,000 £3.1m £0.13m £1.23m £0.09m £4.5 m £1.4m £6.0m £44Medium 41,000 £0.9m £0.32m £1.72m £0.41m £3.4 m £3.3m £6.6m £162High 13,000 £0.3m £0.2m £1.64m £0.47m £2.6 m £2.1m £4.7m £362Total 190,000 £4.3m £0.65m £4.5m £0.97m £10.5m £6.8m £109

National Internet/Bureau notification system – Spraydays (ADAS trial)An internet notification method was evaluated in the Pesticide Notification Methods Study where farmers registered fields with adjacent properties and interested residents could then register for notification of pesticide applications to that field. The farmer entered details of planned pesticide applications into the website and these were sent by SMS text or email to the registered residents. The system was popular with farmers, although it was time consuming and they would have liked automatic transfer of spray recommendations from other systems to avoid duplicate entries. The main advantage was the single entry per field for each spray application, with no further action required. The information was also presented consistently. The residents who used this method were happy with it, the main advantage being immediacy of notifications where ever residents were. The system could now be extended to send SMS text messages to fixed line telephones, so could be available to more than just mobile phone owners. The main drawback of the system was that it was internet based and therefore excluded farmers and residents who did not have internet access. However, this could be overcome by running a telephone bureau service. The costs and practicalities of setting up and running a bureau service are high, with a potential bureau staffing level of between 20 and 250 depending on the level of public registration, with more staff required at peak spray times.

There is, however, potential for the Spraydays software to be used locally by farmers with internet access, if they do a local neighbour consultation and enter details of those requiring notification. The farmers would then enter their field pesticide applications onto the system and the notifications would be sent by SMS text to mobiles, or converted to voice messages for fixed lines. This could be linked to farm records software to avoid double entry.

The main costs are the farmers’ time to carry out the neighbour consultations along with the time to register the farm, fields and adjacent residents, and subsequently enter the notification information. There is also the cost of sending the SMS text messages. The advantages are the ability to control the content of the information entered and sent, to get consistency and accuracy. There is also the possibility of linking with current farm records programmes to save double entry of information. Farmers often now receive pesticide recommendations on software programmes that could be linked and transferred without any keying in time. An advantage for the authorities would be access to notification statistics.

SID 5 (Rev. 3/06) Page 13 of 30

The drawback of this system is that it is not available to all farmers, however it may be an option to consider in the development of local farm notification plans which allow a flexible approach to notification methods (see later section).

The potential set up costs are relatively small compared to the cost of farmers’ time input. The programme development cost could be in the region of £25,000 with ongoing annual maintenance costs of £7,000-10,000 including hosting of the site and statistics. It is possible that some of the companies who make agricultural records software would be interested in developing a system that links to their products and make the appropriate charges to the farmer.

The operational costs are primarily the farmers’ time and the cost of text messages and amount to just under £3 million for the 27,000 farmers who are most likely to use this type of service i.e. larger arable and horticulture businesses. The local neighbour consultation is an integral part of this process and would cost another £1.5 million giving a total of £4.5 million.

LeafletingLeafleting was the most popular method of notification with adjacent residents in the Pesticide Notification Methods Study. It was easily available to all farmers, but had the disadvantage of a high workload and cost, particularly in high notification situations.

The main costs are the farmers’ time to produce and deliver leaflets, while the public costs will be for monitoring and enforcement. There are no set-up costs for leaflets.

The annual running costs for leaflet notification depend on not just the number of direct spray notifications, but also the number of neighbours who wish to be notified. The location of neighbouring properties and the structure of the farm will have a large bearing on the cost of delivering the leaflets. The total cost of leafleting all adjacent properties is estimated at £16 million and the estimated cost per holding is around £84.

Prior registration can reduce the cost of leafleting substantially with cost reduced to £5.5 million if only 8% require notification. However, if 75% of residents require notification by leaflets, the costs would remain the same at around £16 million (Table 15).

Table 15 Effect of prior registration% prior registration100% 75% 33% 8%

Leaflet notification £16 million £12 million £5.2 million £1.3 millionNeighbour consultation


Total £20 million £16.2 million £9.4 million £5.5 million

The distribution across the industry is not even, with those with high level notifications paying up to £600 per holding for leaflets compared to only £10/holding for low level notification holdings (Table 16).

Table16 Distribution of leafleting costsNotification level Number of

holdingsNumber of

notificationsCost of leafleting Cost per holding

Low 136,000 280,000 £1.4 million £10Medium 41,000 1,300,000 £6.5 million £159High 13,000 1,550,000 £7.7 million £595TOTAL 190,000 3,130,000 £16.0 million £84

Local farm pesticide notification plansLocal farm pesticide notification plans (PNPs) allow farmers and residents to develop an appropriate solution for their circumstances. Farmers would consult with each of their adjacent residents as to their wish to be notified (registration) and how they would like to be notified. This could be by telephone calls, leaflets, knock on the door, internet/SMS text messages, a flag, local noticeboard, etc., and would be implemented during the year. Where agreements cannot be made, an arbitration service would need to be employed

The majority of farmers will not be regular users of notification because of size, farm type and adjacent property variation and this keeps the notification simple and easy to administer encouraging good relations with neighbours. Novel approaches in communities may develop, such as a pyramid system, where the farmer notifies one resident who then informs the other encouraging social interaction. Increased communication between

SID 5 (Rev. 3/06) Page 14 of 30

farmers and neighbours may help allay concerns about pesticide use and could lead to a reduction in the call for notification.

A disadvantage of this type of flexible system is that it would be more difficult to enforce if it broke down. To be effective any system may have to be backed up with statutory provisions so that farmers could be prosecuted should they fail to comply with these obligations to notify. To allow the statutory provisions to be enforced, offences would have to be clearly documented – this would be difficult with a system designed to allow maximum local flexibility. The costs of notification will be dependent on the number of residents who register for notification and the way in which they would like to be notified. Where numbers of public registered are low for each farm, a telephone call may be sufficient. However, there may be instances where an internet system is preferable, in which case there would be a cost of setting this up, probably for fewer users than for a compulsory system. The SprayWatch service could be available for those preferring to use the telephone, or Spraydays for those who prefer the internet and SMS texting. This is likely to be attractive to businesses with a lot of fields with adjacent properties and a high level of public registration.

The costs of local pesticide notification plans will vary depending on the type of notification put in place. If it is assumed that half of the medium and high level notification holdings take up the automated telephone service, and half the internet, and the remaining low level notification holdings use a low tech option such as leaflets, the cost would be around £9.9 million, which could be reduced to £5.0 million by prior registration. (Tables 17 and 18).Table 17 Cost of local pesticide notification plansDescription No. holdings CostsMed/high level notification telephone (Table 19) 27,000 £5.6 millionMed/high level notification on internet (Table 20) 27,000 £2.9 millionLow level notification on low tech leaflet option (Table 23) 136,000 £1.4 million

Total 190,000 £9.9 millionCost per holding £52

Table 18 Effect of prior registrationNotification % public registration

100% 75% 33% 8%Cost of local plans £9.9 million £7.4 million £3.2 million £0.8 millionNeighbour consultation


Total £14.1 million £11.6 million £7.4 million £5.0 millionCost per holding £74

The theoretical advantage of a local scheme would be that the provision of information would match local need. In areas of high concern there would be high levels of notification and vice versa. Also the form of notification could be tailored to meet demand. However, there are likely to be significant practical difficulties in fitting this flexibility with a statutory scheme as recommended by the RCEP. It would require a much higher level of co-operation between farmers and adjacent residents. 7.4 Notification of Pesticide Applications – (b)Public Rights of WayPublic rights of way (PROW) include footpaths, bridleways, byways open to all traffic and roads used as public paths (which will shortly be designated restricted byways). There are 188,700 km of PROWs in England. PROWs are managed and maintained by the highways authority and recorded by the surveying authority, in both cases usually the county council or unitary authority. Work by Centre for Ecology and Hydrology6 for the RCEP report on Bystander Exposure estimated the total length of paths/tracks/roads crossing or within 6 m of arable or horticulture land to be 253,000 km in GB with 225,000 km in England and Wales. This figure is higher than the 209,000 km of PROW across all farm types in England and Wales (Defra 2005) and indicates that there are many more potential access points than just PROWs.There is no published information on: Length of footpath adjacent to temporary grassland fields. Number of fields with footpath crossing or adjacent, nationally or per farm. Distribution of footpaths across the countryside.It is likely, given the historical development of rights of way,

that they will be more concentrated around hamlets, villages and towns. Information from the farmers who participated in the Pesticide Notification Methods Study, and from some non-statistical map reviews, suggest that between 10% and 35% of arable and temporary grass fields have public

6 Centre for Ecology and Hydrology (2005) National estimates of residential land adjacent to arable land using Countryside Survey sample data, www.rcep.org.uk/pesticides

SID 5 (Rev. 3/06) Page 15 of 30

rights of way running across or adjacent to the field. The nature of public rights of way mean that their distribution is linked to historical settlement patterns, which vary across the country as well as the type of cropping. Taking the number of fields in arable, horticulture and temporary grass as 1.4 million, it is estimated that 1 in 7 fields have a PROW adjacent to, or across the field, resulting in an estimated 200,000 fields affected.

Cost analysis options for public rights of way field noticesFarmers would be required to print and display notices at the entry points to fields that will be sprayed with a pesticide. The information on the notices can be specified to cover, for example, planned date of application, chemicals used and contact point and recommended action. These would be placed where PROWs enter a field that is shortly to be sprayed with pesticides, and removed within a suitable period after spraying.

Users of footpaths in the countryside need a warning of potential pesticide applications. The Pesticide Code recommends that footpaths are not sprayed, and that spray operators stop if they see a member of the public on the footpath. Notices may be useful in order to ensure PROW users stay on the footpath and avoid contact with the newly sprayed crop. The notices would not be intended to stop the PROW being used, but would give enough details to allow the user to make an informed decision about the use of the path.

There are no set-up costs for farmers placing notices on field access points. Standard format notices can be printed from the internet or purchased through normal farm suppliers. The main cost is the time taken to complete and place the notices. The costs per farmer were reviewed in the Pesticide Notification Methods Study and have been updated in this report. The total cost based on the assumption that there are 200,000 sprayed fields with public rights of way is £6.0 million or £32 per farm. The costs change pro rata if the number of affected fields changes.

There would be differences between notification groups, with those in the high notification group likely to have more PROWs due to their size and/or proximity to dense populations (Table 19). The costs on these farms could be around £78 per holding, compared to £18 per holding on farms in the low notification category. Outside of this range, there could be an occasional extreme case, such as a fruit farm with up to 14 spray passes per annum, where the cost of footpath notices could reach £420 per footpath. With 8 footpaths, costs could reach £3360 per year.Table 19 Potential differences in PROW notification costs between notification groups

Number of spray

passes

Number of holdings

Estimated no. fields with footpaths*

Approx. No. Notices

Cost Cost per holding

Low 1.6 136,000 143,000 500,000 £2.5 million 18Medium 5.3 41,000 43,000 500,000 £2.5 million 61High 6.6 13,000 14,000 200,000 £1.0 million 78TOTAL 3 190,000 200,000 1,200,000 £6.0 million 32*Pro rata by number of holdings (the number of holdings in each category is a mix of farm sizes, spray intensities and housing density so it is difficult to be more accurate).Use of public rights of way notices is not without problems. In the pilot study farmers were generally reluctant to implement this form of notification, and those that did found it time consuming and often irrelevant on fields where the footpaths were seldom used, such as on paths well away from properties. Where paths were used the notices were occasionally removed by footpath users, perhaps so they could do further research, leaving the footpath with no warnings for other users. The time between spraying and removal of the notices by the farmer was variable, and this could lead to notices being left too long and causing undue concern to the footpath users.7.5 Disclosure of informationThe right of the public, not just adjacent residents, to request information on pesticide applications was debated in the consultation in 2004. In general the public would prefer direct access to the farmer, but the farmer would prefer third part access if any. A minimum level of information would be the date, location, and pesticides used.

An incidence of potential contamination might need an immediate disclosure, or short-term disclosure. For instance a child could run into a recently sprayed field and a parent may wish to consult a doctor. In this situation a member of the public may want to know what had been sprayed on a particular field on a certain day. Disclosure of historical records, or long-term disclosure, may be requested after the diagnosis of a chronic illness such as asthma and the individual may wish to review details of potential pesticide exposure over a number of years.

Potential number of disclosure requestsThe number of complaints to HSE about pesticide use runs only at about 200 complaints per year (2002/3, 215; 2003/4, 204 and 2004/5, 150). This may give some indication of the number of requests for disclosure of information. However one would expect the number of requests for disclosure of information to be higher than the number of complaints since this is a step many individuals are likely to make before lodging a complaint. Availability of information from disclosure could increase or decrease the number of complaints.

SID 5 (Rev. 3/06) Page 16 of 30

The number of residential properties next to arable land is about 500,000, in which there live about 1.0 – 1.5 million people, with an estimated further 150,000 properties adjacent to temporary grassland. If one assumes that requests for disclosure will come from one person per household, for example one adult enquiring on behalf of a member of the household, then 650,000 is the population of those likely to request disclosure plus some PROW user requests. An estimate of the total population that could make disclosure requests, including PROW users, is 715,000.

An estimate of the minimum number of people per year requesting disclosure would be a few multiples of the number of people making pesticide complaints to HSE. In 2002/3 there were 215 complaints, in 2003/4, 204 and in 2004/5 150 We estimate that the lowest number of people making requests for disclosure would be around 1,000. The number of people requesting disclosure is likely to be higher initially when this is a new right with surrounding publicity, but will decline as some of those requesting information find they learn little of real value to them from the activity. This results in an estimate of the most likely number of people requesting disclosure of 6,000 (or 1% of the number of households adjoining sprayed land).

Given that most residents will be living adjacent to the common cereal crops and if they request disclosure, are unlikely to do so for every spray event, ADAS suggests a most likely number of requests, per person requesting information, of 3 per year. Our upper estimate, to accommodate frequently sprayed crops and requests relating to other fields (for example due to footpaths), is 25 requests per year.The likely range of numbers of requests for disclosure is 5,000 to 50,000 with the most likely estimate 15,000. Adverse publicity of spray issues in the local or national media could produce short-term peaks of demand.

Options for disclosure of information Direct public access to the farmer with assessment of short and long term disclosure requests Public access to the farmer through a third party, with assessment of short and long term disclosure requests

Requirements for disclosure would be likely to cover the form of requests, the information that must be disclosed and a time limit for supply of the requested information. There would need to be provisions to prevent excessive numbers of requests as a form of harassment, perhaps linked to an arbitration or adjudication procedure.

Direct DisclosureMembers of the public would contact the farmers directly, by post, hand delivery or email, with an application for disclosure for information. This would be a standard form including certain key items of information such as date, name, address, contact details, and request for pesticide application information (field, date, time and reason(s) for the request). Farmers would be obliged to respond to the request in writing on a standard form immediately or within a certain time limit.

The main cost to the public would be the time to organise the request, with the cost of materials and postage being minimal. Increasingly, requests and disclosures will be likely to be by e-mail for fast and inexpensive delivery. Postal delivery of hard copies or hand delivery are also likely methods where the main cost is time to formulate the request and provide the answer. The cost to the farmer is likely to be greater than the cost to the public because of the time required to look up relevant information for disclosure.

Assuming that 10% of the disclosure requests are for full histories (long-term disclosures), the costs to public and farmers are estimated at around £250,000 per year for 18,000 requests for disclosure, but costs could be as high as £1.7 million if disclosure requests reach high levels. If the balance of short:long-term disclosure was 50% of each, the total cost of 15,000 disclosures would increase to £400,000.

In terms of costs and benefits, those requesting disclosure (and willing to pay the costs) must perceive an overall welfare benefit, or they would chose not to exercise this right. In many cases the ‘welfare’ will be quantified though peace of mind. For the farmers this cost would be a loss of welfare as they must give up time to answer the requests, or forego profit by paying someone to supply the information (for example their staff).

Cost of Disclosure Through a Third PartyThe cost of a third party depends on their mode of operation. Options include a bureau service or web based service. Other considerations include whether the system would be run nationally or regionally which has big impacts on the costs. The simplest way to estimate the costs for a disclosure system that uses a third party as an intermediary, is to double the costs of direct disclosure, as the number of communications would be doubled compared with direct disclosure. This gives estimated costs of around £1.2 million at the medium level of disclosures (13,500 per year). In practice, the time required by the third party to pass on requests and information might be lower than the time taken by requesters and disclosers. It may also increase the total time taken for a disclosure, but this may be mitigated by farmers treating a request from an ‘authoritative body’ more seriously. It would also ensure a consistent approach and allow monitoring of activity. Actual costs would depend on whether the intermediary was a single national provider, or a number of distributed providers such as local authorities. The latter would have inherent inefficiencies for functions such as collecting statistics. The task itself

SID 5 (Rev. 3/06) Page 17 of 30

could be performed by relatively low paid staff but there would be the usual overhead costs of staff such as communications, accommodation and pensions.

Third party disclosure provides a barrier between the farmer and enquirers, restricting opportunity for confrontational behaviour. This barrier may be seen as providing some welfare to the disclosing farmers.

It should be noted that the financial estimates associated with disclosure depend critically on the level of demand and this is impossible to gauge with any level of confidence since there are no parallels or precedents with which to compare. 7.6 Statutory Pesticide CodeThe Green Code (Code of Practice for the Safe Use of Pesticides on Farms and Holdings) has now been revised, amalgamated with related pesticides codes, and republished as the Code of Practice for using Plant Protection Products. The Code provides practical guidance to farmers and growers engaged in commercial crop production, and to amenity users, in order that they can comply with the legislation under the Food and Environment Protection Act 1985 (FEPA) and Health and Safety at Work etc. Act 1974. The Code farmers and growers need to follow the Statutory Code in order to demonstrate that they have complied with the legislation. If they do not follow the code they need to be able to demonstrate how they have complied with the legislation in other ways. If the Code was to become “fully” statutory there would be costs to the industry in terms of monitoring and enforcement. Policing 100% compliance with PPP Code requirements is certain to be very costly and potentially disproportionate. To decide the level of compliance at which enforcement would be worthwhile, it would be necessary to know the nature and frequency of non-compliance, the costs of inspection, the marginal impact of inspection on compliance and the marginal benefits of increases in compliance. Of these five factors, only the cost of different levels of inspection are easily estimated.

Options New regulatory regime through Government Agency Statutory management requirements Crop assurance schemes

New regulatory regimeDesigning new regulatory regimes is a complicated issue and all aspects of the regulatory mix need to be considered including the probability of non-compliance being detected and the size of the penalty where this is the case. Effective enforcement of provisions of the code would require audits of written records and spot checks on field spraying operations. There are some aspects of the code that would be difficult to enforce unless the inspector was actually on site, such as wind speed and boom height.

There are about 63,100 holdings in UK which are full time cereal, general cropping, mixed or horticultural businesses (more than 8 European Size Units). Compliance could be least in very small businesses but most holdings registered with Defra as being under 8 ESU probably do not operate as separate businesses (with the possible exception of some horticulture businesses). At a 5% inspection level this would cost the industry around £1.6 million (Table 20).

Table 20 Estimated cost of inspections for Pesticide Code complianceInspection frequency - % of full time holdings per year inspected

5 10 20 50Man years – assuming 180 inspection per man year

18.1 36.2 72.4 181.1

Cost – assuming total cost of inspectors including support and management of £45,000 per year - £k

905,000 1,811,000 3,622,000 9,055,000

Hours of farmer/farm staff time at 0.5 day for inspection time

49,000 98,000 195,000 489,000

Cost at £15 per hour £733,000 £1,467,000 £2,934,000 £7,335,000Total cost of monitoring and inspections

£1,600,000 £3,300,000 £6,500,000 £16,400,000

This costing assumes that there is no additional cost to the industry such as increased time for record keeping, training, or testing equipment, in order to satisfactorily meet the requirements of the PPP Code and pass inspections as a result of making the Code statutorily enforced. If this was the case industry costs could quickly escalate to over £40 million for any level of inspection (Table 21).

Table 21 Potential additional costs of inspection

SID 5 (Rev. 3/06) Page 18 of 30

Extra on farm costs:Extra time on all holdings to demonstrate compliance (1 day @ £15/hr)

£22 million

Extra training (NRoSO CPD) £5 millionTesting of equipment £15 millionTotal extra on farm costs £42 million

In addition to the £42 million extra farm cost there could be extra engineering controls e.g. new products which may be effectively compulsory to purchase in order to comply with safety requirements. 7.7 Grandfather rightsAll pesticide users must be adequately trained, no matter what their age and qualifications. A trained operator is someone who does not have a certificate of competence but have attended some training courses and have grandfather rights. Contractors who apply agricultural pesticides commercially, and all operators born after 31 December 1964 are required to have a certificate of competence. The right to apply pesticides without an operator’s certificate of competence, because the operator was born before 31 December 1964, is known as grandfather rights.

In the Sprayer Practice Survey 2004 carried out by CSL for the Voluntary Initiative, it was estimated that 9% of the arable and horticulture area was sprayed under grandfather rights. Grandfather rights are most commonly exercised on small farms and farms in the less arable area such as Northern Ireland, Wales and the North West. Approximately 24% of total arable holdings had someone with grandfather rights while 7% of arable holdings had a sole operator working under grandfather rights.

The proportion of operators with grandfather rights will naturally decline, however there is still a significant proportion of arable and horticulture farms relying on sole operators with grandfather rights. Changes to the requirements will have an impact on those businesses, as will the length of any phasing-in periods if considered necessary. There is also a wider issue of operators who are trained but do not have the formal certificate of competence, estimated at 17% of spray operators in the Sprayer Practice Survey 2004.

There are approximately 50,150 spray operators in the UK on farms with arable crops (Sprayer Practices Survey 2004). If 7% of arable and horticulture holdings are under the sole control of an operator with grandfather rights, then there are approximately 3000 sole operators on farms with arable crops who are working under grandfather rights and would need to take action if grandfather rights were withdrawn. A further 17% (8000 operators) are not sole operators so perhaps may not need to retrain. There are no definitive figures for grassland, but if a similar proportion of non-LFA grassland holdings (67,000 holdings) is taken then there could be as many as 16,000 operators under grandfather rights. This figure is reasonable given that many grassland farmers will already use contractors and the ageing nature of industry personnel. If all livestock farms are included (126,000 holdings) the grassland figure could be as high as 30,000 operators under grandfather rights on grassland farms. This gives a total estimate of between 27,000 and 41,000 operators working under grandfather rights.

Options for grandfather rights cost analysis: Zero action – the numbers will naturally decline over the next 15 years. Costs of training those with grandfather rights Costs of using a contractor or training an employee

Zero ActionThe number of spray operators working under grandfather rights will gradually decline over time. Between the similar survey of operators practices in 2001 and 2004 the proportion of the UK arable crops sprayed under grandfather rights declined from 22% to 9% and this trend is likely to continue. The rate of decline will be slowest in the infrequent user group such as the livestock farmers which is the biggest group but carries out little spraying.

This is a no cost option and is likely to achieve the objective within 20 years. Operators who were born in 1964 or before will be at least 41 years old now and so will all be approaching retirement age in the next twenty years.

Cost of trainingThe cost of training and NPTC testing is about £255 for each of PA1 and PA2 certificates of competence and in total takes around 3 days training plus 1 day assessment. For 27,000 spray operators to train to full PA2 standard the cost would be £25.6 million including fees and training time. If the number of operators that need to retrain is the upper estimate of 41,000 operators, the cost would be £39 million. These are the costs if grandfather rights were abolished at once. If the changes were phased in over a number of years, costs could be significantly reduced.

If there is a 9 year adjustment period up to 2015 when spray operators working under grandfather rights can retrain, around 40% of operators would naturally reach retirement age (65) before that date, assuming an even age distribution of those working under grandfather rights. Taking this number out of the calculations for the costs

SID 5 (Rev. 3/06) Page 19 of 30

of removing grandfather rights, the cost over a 9 year period up to 2015 is between £15.75 million and £23.4 million, with annual costs of between £1.75 million and £2.6 million.

It is likely, however, that many operators who have alternatives to their own time input would choose not to train and to allow other trained operators on the farm to carry out the work. Similarly, where the sole spray operator is working under grandfather rights, they may choose to employ contractors rather than have the expense and time of passing a course. If this was the case then there would be an impact on individual farms but there would be no loss to the industry, particularly as many farmers are also contractors.

If grandfather rights were abolished, the cost would fall mainly on small farms, elderly farmers and areas of the country that have little arable farming.7.8 Restriction on purchase of chemicals to those with qualifications: The RCEP recommend the restriction of the purchase of pesticides to those who are permitted to use them, i.e. those holding Certificates of Competence in the form of PA1 and PA2 training certificates, in order to help prevent spraying by unqualified persons. This would ensure that all pesticide purchases are made by a person who knows how to use the products. The cost of implementing this would be the cost of ensuring that all spray operators have the necessary qualification.

There are practical difficulties as the spray operators who hold the certificates are often not the people who purchase the chemicals, and may not have the necessary authority to do so. In arable situations the farm manager, owner, or the BASIS qualified agronomist usually places the orders and it would be inappropriate for the contractor or spray operator to make the purchases. The group most likely to be affected by a requirement to have certification of some kind, would be those farmers who are infrequent purchasers/users of agrochemicals. Examples of infrequent purchasers would be livestock farmers who occasionally need to have grass sprayed.

The simplest method of ensuring that pesticides are purchased for the correct situation and used by a qualified spray operator, would be to have requirements for those ordering chemicals to have taken advice from a BASIS qualified adviser, and to use a qualified spray operator. This could be through a written recommendation from a BASIS adviser and production of Certificates of Competence or NRoSO registration for the intended spray operator. The pesticide seller would need to demonstrate that all sales complied with these requirements, providing a verifiable record. In this situation the costs incurred will be from consulting a BASIS qualified agronomist if not previously done, and from using a qualified contractor or training for the certificate of competence if currently unqualified (e.g.grandfather rights).

The costs of using a qualified spray operator will be the same as those for the removal of grandfather rights, or £1.75 million per year until 2015. However there are other options such as using a contractor.

Ninety nine percent of the UK arable area was sprayed following recommendations by a BASIS qualified person (Sprayer Usage Survey 2004). The 1% who did not take up BASIS registered advice accounted for over 3000 arable farms. However, qualifying farmers are a rapidly increasing sector of the BASIS register. Most arable and horticultural units will have an adviser who is BASIS qualified. There are approximately 750 trade agronomists in the UK who cover approximately 75% of arable farms and ordering pesticides on behalf of the farmer. In this situation no need to change to pesticide purchasing is envisaged. Also, there are about 350 independent agronomists covering 25% of arable farms including some farmers that are BASIS trained. Some of these will order pesticides for the farmer but many will not. This situation should require little change in procedure since these farmers are receiving advice from BASIS qualified advisers and should be able to give the BASIS number of their agronomist.

If use of a BASIS qualified advisor and a certificated spray operator are required, it is the farms that infrequently purchase sprays, typically for use on grassland (that is, not arable or horticultural units), that will have a problem. In many cases they will use a contractor to apply sprays and they may be remote from agronomists who tend to be based in areas with a high proportion of arable farms. Where a farmer has no relationship with a qualified agronomist they could seek advice from their supplier. Dairy farms will typically use more sprays than beef and sheep farms, and many dairy farms, that grow maize and other fodder crops, use an agronomist. ADAS has assumed that 50% of dairy forage crop growers will have a relationship with a BASIS qualified agronomist and hence would have no additional cost, but the remaining dairy farms and all beef and sheep farms do not. In addition it has been assumed that these farms purchase pesticides on average once per year. This would give rise to about 109,000 orders for pesticides from infrequent users.

Infrequent users are likely to be dealing with a supplier where a Nominated Store Keeper (NSK) handles the transaction rather than a BASIS qualified agronomist who can give advice. To obtain advice it would be necessary for the NSK to put the purchaser in contact with a BASIS qualified agronomist by telephone (all suppliers are likely to have agronomists in their organisation but not always on the premises). The advice is likely to cover the crop, soil type, proximity to water courses (in relation to LERAPS), type of agronomic problem

SID 5 (Rev. 3/06) Page 20 of 30

(frequent weeds, type of pest etc.). Following this the agronomist would need to post a copy of the advice which the purchaser could retain.

Accounting for the farmers’ time at £15 per hour and the agronomist at £20 per hour plus £1 for post and telephone, the cost of requiring BASIS advice would be £6.80 per order and £740,000 annually for the industry.

The costs to the agrochemical distributor companies for collecting the information, would be passed to the farmers in terms of higher pesticide prices or charges (expressed as the hourly rate above).

In addition there would be the cost of enforcement. Enforcement would be by checking a sample of purchase transactions for a BASIS number and asking the purchaser for records of the advice issued. 7.9 Continued trainingSpray operators can demonstrate that they are maintaining their knowledge of spraying as a means to keep their certification. This could be achieved through refresher/update certification courses or through the NRoSO membership and gaining CPD points, or possibly a mix of these two options. There are currently 20,000 spray operators registered with NRoSO (out of an estimated 50,000 arable operators) covering 75% of the arable area. NRoSO operators spray most of the arable area because this is a requirement of the Assured Combinable Crops and Assured Produce Schemes.

Options for continued training cost analysis: NRoSO membership and CPD points Retest/refresher/update training every 5 years

NRoSO membership and CPDThe Pesticide Code recommends that spray operators maintain an adequate training record. One way of achieving this is to become a member of NRoSO. NRoSO membership requires the collection of at least 30 CPD points over a period of 3 years. The points have to relate to three subjects - application practice, crop protection or the environment. The points collected for each subject have maximum and minimum requirements. Typically a spray operators can collect a considerable proportion of their CPD points by recording activities that they would undertake regardless of the CPD points requirement. Examples of this are reading technical notes/trade journals, attendance at specialist shows (such as the annual Cereals event) and meeting with their agronomists. It seems reasonable to assume that spray operators will typically be able to record 20 points in a three year period in this manner, with the only cost being that of keeping personal records. That would leave about 10 points per three year period for which the operator might have to attend specialist courses. The nature of the courses varies (for example spray awareness, protecting water, Entry Level Stewardship or Higher Level Stewardship, but the cost is typically £20 - £30 for a half day training event. A typical number of points per event is 6. The larger cost for participants is the cost of their own time and the cost of travel. Half-day training events are likely to require 5 hours away from the farm, with a typical distance to travel of 20 miles each way. Charging the operators’ time at £15 per hour and travel at 25p per mile gives a total cost of £110 per half-day training event.

A reasonable assumption is that activities they would in any case undertake plus two half day training events would allow operators to reach their requirement for 30 points in three years. Some allowance must be made for planning activities, managing personal records and acquiring the proof required to collect CPD points. One hour per year has been costed for this purpose.

These assumptions give a total cost per three-year period of £265, or £88 per year per operator. The cost of registration with NRoSO is £17 per year if paying by direct debit (if paying by cheque it costs £20 per year).

There are estimated to be 50,150 spray operators on arable holdings. There is no information on numbers of spray operators on livestock/grassland holdings. There are 67,000 non-LFA livestock holdings of which an estimated 50% will already be using contractors leaving an estimated 33,000 spray operators on livestock holdings. Further investigation would be required to confirm this.

The total annual cost of NRoSO membership and collection of CPD points is estimated to be £8.7 million (Table 22).

Table22 Annual Cost of Compulsory NRoSo membershipItem CostNumber of arable spray operators 50,150Estimated non-arable spray operators 33,000NroSO membership costs @ £17/year £1.4 millionCPD training @ £88/year £7.3 millionTotal £8.7 million

SID 5 (Rev. 3/06) Page 21 of 30

Retest every 5 yearsThe cost of retesting all sprayer operators will be similar to the cost of a PA1 or PA2 course. Taking the cost to the operator of the refresher course and test as £250 and the time as 1 day, the total cost to the industry would be around £30 million, or £6 million per year over 5 years.7.10 Sprayer testing In the Sprayer Practices Survey 2004, 43% of sprayers had been tested by an NSTS approved tester. Sprayer testing is becoming compulsory under some crop assurance schemes and encouraged under the Voluntary Initiative. Assured Combinable Crops Scheme, which covers over 90% of arable farms, has made NSTS tests compulsory by harvest 2006 and must be carried out annually for larger farms and every two years for smaller farms. At March 2005, 50% of the sprayed arable area was covered by tested machines. The March 2006 target of 80% of sprayed area will be encouraged by the requirement for testing under the assurance schemes. National Sprayer Testing Scheme (NSTS) was set up by VI to provide an independently validated, low cost annual testing scheme. Registration costs £18 plus the cost of the test, which is approximately £10-20/m of boom, plus any repairs. If there are 44,000 sprayers in the UK with an average boom width of 18 m at a cost of £15 per metre, the cost of annual testing will be almost £13 million with an additional time commitment costing £1.5 million per year. 7.11 Suspension of certificationA possible sanction against non-compliance is the suspension of a spray operator’s certification. There are questions over what level of non-compliance would justify this action and, if taken, what would be the cost and consequence for the individual. The effect on individual operators is likely to be high. If a farmer is unable to spray there will be additional costs for employing a contractor and possibly loss of timeliness in pesticide applications. The impacts on a farmer/contractor will be the loss of income from any contracting work, and the extra costs of employing a contractor for their own spraying. Given that most farmer/contractors take on the work in order to maintain their income level this could have a serious impact on the farm profitability and survival. For those employed in, or running, a contracting business, the loss of a certificate of competence would be very serious. It would effectively take away their livelihood for the period of time and possibly longer, as other contractors would take on the existing workload. With this in mind, suspension of certification is likely to be an effective tool in ensuring compliance, particularly for those operating in the contractor marketplace.

8.0 Sector Analysis Summary8.1 Value of Sectors in Agriculture and HorticultureThe value of the Agriculture Industry in the UK in 2005 has been apportioned to four main sectors – three of which apply pesticides to land (Table 23).

Table 23 Value of sectorsSector

Arable Horticulture Grazed livestock(dairy, beef &

sheep)

Other (e.g. pigs and

poultry)Gross Value Added at Basic Prices (£ billion)

£2.8 £2.2 £5.3 £4.0

Source: AUK 2005. These figures exclude the Single Payment which is not related to production.

8.2 Cost of Measures in each Sector The tables below give the total cost of the measure and an estimated sector breakdown. The distribution row shows which sectors are most affected and details on how the costs have been

attributed. The % of sector value (Gross Value Added) indicates impact in the relevant sector.

ConsultationThe arable sector accounts for 66% of consultation costs (Table 24).Table 24 Consultation

Value of SectorsArable Horticulture Grazed Livestock

£ billion £2.8 £2.2 £5.3Consultation

Total Arable Horticulture Grazed LivestockCosts £4.2 £2.9 £0.3 £1.0Distribution – holdings and adjacent properties

66% 8% 26%

% of sector value 0.06% 0.01% 0.01% The cost of the buffer zones and notification could be reduced by carrying out a neighbour consultation to

establish notification requirements. The methods trial suggested that costs could be reduced to around 8%.

SID 5 (Rev. 3/06) Page 22 of 30

No-spray buffer zonesThe costs of no-spray buffer zones fall almost entirely on arable and horticulture businesses (Table 25).Table25 No-spray buffer zones


£ billion £2.8 £2.2 £5.3Buffer Zones (annual costs)

Total Arable Horticulture Grazed LivestockCosts £4.8 £2.9 £1.9 £0Distribution – area and gross margins

60% 40% 0

% of sector value 0.01% 0.09% 0.00% The buffer zone costs can be reduced significantly by the use of set-aside and other environmental options

and/or neighbour consultation

NotificationDifferent methods of notification have different impacts on each sector, however the arable sector bears the majority of the costs (Table 26). Table 27 Notification


£ billion £2.8 £2.2 £5.3Notification Options (annual costs):Telephone – SprayWatch

Total Arable Horticulture Grazed LivestockCosts £17.7 £13.3 £0.9 £3.5Distribution – holdings, fields and adjacent properties

75% 5% 20%

% of sector value 0.46% 0.04% 0.07%

Internet (15% of holdings only) (annual costs)Total Arable Horticulture Grazed Livestock

Costs £3.2 £2.2 £0.6 £0.4Distribution – holdings, fields and adjacent properties

71% 18% 11%

% of sector value 0.08% 0.03% 0.01%

Leaflets (annual cost)Total Arable Horticulture Grazed Livestock

Costs £15.1 £13.0 £0.9 £1.2Distribution – holdings and adjacent properties

86% 6% 8%

% of sector value 0.45% 0.04% 0.02% These figures are based on information from CEH study on properties adjacent to arable and horticulture and

estimates for properties adjacent to grassland, average spray passes for different crops from Pesticide Usage Survey and estimates of the number of fields with adjacent properties.

Costs can be reduced by using neighbour consultations

SID 5 (Rev. 3/06) Page 23 of 30

Public Rights of WayThe arable sector accounts for 88% of the PROW costs (Table 28).Table 78 Public rights of way


£ billion £2.8 £2.2 £5.3Public Rights of Way (annual cost)

Total Arable Horticulture Grazed LivestockCosts £9.4 £8.3 £0.5 £0.6Distribution – sprayed area 88% 5% 7%% of sector value 0.29% 0.02% 0.01% These figures are based on estimates of fields with footpaths. No survey information is available to check

these estimates.

Statutory CodeThe arable sector accounts for 89% of statutory code costs (Table 29).Table29 Statutory Code


£ billion £2.8 £2.2 £5.3Statutory Code (annual cost)

Total Arable Horticulture Grazed LivestockCosts £42 £37.3 £2.0 £2.7Distribution – sprayed area 89% 5% 6%% of sector value 1.3% 0.09% 0.05% These figures are the total costs of enforcing the requirements of the Code, and inspecting costs as well as

costs to the farmer.

Removal of grandfather rights over 9 yearsThe grazed livestock accounts for 37% of the costs of removal of grandfather rights Table30 Removal of grandfather rights


£ billion £2.8 £2.2 £5.3Removal of Grandfather Rights over 9 years (total cost for 9 year)

Total Arable Horticulture Grazed LivestockCosts £16 £8.2 £1.8 £5.8Distribution – number spray operators

52% 11% 37%

% of sector value 0.28% 0.08% 0.11% Spray operator numbers in each sector have been estimated from information from CSL Pesticide Practices

Survey and additional estimates for grassland.

Qualification for purchaseThe costs of requiring to have a qualification to purchase fall entirely within the grazed livestock sector (Table 31).Table 31 Qualification for purchase


£ billion £2.8 £2.2 £5.3Qualifications for purchase (annual cost)

Total Arable Horticulture Grazed LivestockCosts £0.75 £0 £0 £0.75Distribution – BASIS advice 0% 0% 100%% of sector value 0.00% 0.00% 0.01% CSL Pesticide Practices Survey indicated that most arable and horticulture farms took advice from a BASIS

qualified agronomist. Additional costs for removal of grandfather rights also apply

SID 5 (Rev. 3/06) Page 24 of 30

Spray Operator Training57% of the costs of spray operator training occur in the arable sector, 13% in horticulture and 30% in grazed livestock (Table 32).Table 32 Spray operator training


£ billion £2.8 £2.2 £5.3Continued training NroSO membership (annual cost)

Total Arable Horticulture Grazed LivestockCosts £8.7 £5.0 £1.2 £2.6Distribution – number of holdings 57% 13% 30%% of sector value 0.17% 0.05% 0.05%

Spray Operator re-testing (annual cost)Total Arable Horticulture Grazed Livestock

Costs £6.0 £3.4 £0.8 £1.8Distribution – number of holdings 57% 13% 30%% of sector value 0.12% 0.04% 0.05%

Sprayer TestingThere is a similar 57% : 13% : 30% split for the costs of sprayer testing (Table 33).Table 33 Sprayer testing


£ billion £2.8 £2.2 £5.3 Sprayer testing (annual cost)

Total Arable Horticulture Grazed LivestockCosts £14.5 £8.3 £2.0 £4.3Distribution – number of holdings 57% 13% 30%% of sector value 0.29% 0.09% 0.08% Sprayer testing is becoming compulsory in England and Wales through the Assured Combinable Crops

Assurance Scheme and is encouraged by the Voluntary Initiative and around 43% of sprayers have already been tested.

This figure is the cost of testing all sprayers each year.

9.0 Small Business Impact Test

More strict regulation on the application of agricultural pesticides will have an impact on agricultural and horticultural businesses. Nearly all farm businesses are classified as small businesses using the commonly used definitions of business size (usually based on the number of employees) but the three businesses portrayed here are family run businesses with one or two family partners who work in the business. Short descriptions of each business are provided and then an estimate of the cost of the proposals under consideration. To put this in context the typical profit and loss account of a business of this size is presented.

The three businesses presented illustrate the estimated financial impact on a medium sized cereal growing farm, a small fruit holding and a medium sized dairy farm. The financial cost of the measures is illustrated in relation to the value of sales and the amount of profit. For small businesses the profits are low and the cost of the measures represents an appreciable proportion of the annual profits.

9.1 Farm Size and LocationThe buffer zone and notification costs will vary depending on the location of the farm and proximity to housing. The varying costs of notification are given for different situations to give an idea of the potential range of costs.

Neighbour consultation costs have not been included and the costs of buffer zones and notification could be reduced if it were to take place.

SID 5 (Rev. 3/06) Page 25 of 30

9.2 Typical Profit and Loss Accounts for Cereal, Horticulture and Dairy Businesses

Table 34 Profit and loss accounts for cereals, horticulture and dairy

Source: Farm Business Survey

9.3 Arable - Medium sized combinable cropping farmThis farm grows combinable crops of wheat, barley, oilseed rape and peas. The farm area is 240 ha of combinable crops with additional land area in roads, buildings and small woodlands. The farm uses an agronomist and is sprayed by a fully trained spray operator who is registered with NRoSO. The farm is in Assured Combinable Crops Scheme and has its sprayer tested every year.

Impact of measuresThe additional annual costs of the measures for a medium sized combinable crop farm are £277 based on leafleting as the notification option and existing membership of NRoSO, which represents less than 1% of the profit (Table 35). If other notification options were to be considered the annual cost could be up to £206 higher. The location of the farm and its proximity to housing will make a difference to the notification costs. The same farm in a more rural location would have additional costs of £100 per year, and in a more urban situation up to £2617. Table 35 Arable Farm - Annual costs per farmMeasure Low Medium HighConsultation £23 £33 £260

5m buffer zones £18 £57 £562Notification options:Telephone £107 £253 £2255Internet £62 148 £1363Leaflets £15 £47 £460

Public Rights of Way £52 £158 £1580

Statutory Code £15

Removal of Grandfather rights

Nil

SID 5 (Rev. 3/06) Page 26 of 30

Qualification for purchase

Nil

Spray Operator training options:NRoSO NilRe-testing Nil

Sprayer testing Nil

Overall Additional Cost £100 £277 £2617Cost as % of Sales 0.06% 0.17% 1.65%Cost as % of Profit 0.33% 0.91% 8.60%Note: Overall Additional Costs exclude consultation and assume leafleting and NRoSO registration where applicable. Neighbour consultation where used would reduce buffer zone and notification costs.

9.3 Horticulture - Small top fruit holdingThis is a small horticultural holding of 10 ha in total with top fruit orchards and 1.5 ha of pick your own soft fruit. The holdings’ spray equipment is used under grandfather rights, is not tested and the operator is not NRoSO registered. The grower does take advice from a BASIS qualified adviser.

Impact of measuresDespite being a small farm with low costs of notification, the additional costs of training and NRoSO membership result in the total costs to this business of £582 per annum, which represents over 11% of the profit (Table 36). Buffer zones and notification costs (leafleting) of £134 represents 2.5% of the profit, assuming that there are no footpaths on such a small farm.

Table 36 Horticulture Farm - Annual cost per farmMeasure Low Medium High*Consultation £18 £20 £259

5m buffer zones £129 £231 £11,500Notification:Telephone £94 £102 £3,000Internet £63 £64 £2,000Leaflets £5 £9 £460


Statutory Code £15


£96


£0

Spray Operator training:NRoSO £107Re-testing £73

Sprayer testing £230

Overall Additional Cost £582 £798 £13,208Cost as % of Sales 0.75% 1.02%Cost as % of Profit 11.24% 15%*The high notification costs are more typical of a larger fruit or vegetable businessNote: Overall Additional Costs exclude consultation and assume leafleting and NRoSO registration where applicable. Consultation where used would reduce buffer zone and notification costs.

9.4 Grazed Livestock - Dairy FarmThis farm of 75 ha has 80 dairy cows and grows 20 ha of forage maize and reseeds 10 ha of grassland as 5 year leys every year. The farm does not use an agronomist. It is not a member of NroSO and the farm’s own sprayer is used under ‘grandfather rights’.

SID 5 (Rev. 3/06) Page 27 of 30

Impact of measuresThe total additional costs for a medium sized dairy farm are in the region of £509 per annum representing 1.58% of the profit (Table 37). The notification and buffer zone costs are low at only £34 per annum or 0.1% of profit. The main costs occur due to the training and sprayer testing requirement.

Table37 Dairy Farm - Annual cost per farmMeasure Low Medium HighConsultation £18 £20 £23

5m buffer zones £0 £0 £0

Notification:Telephone £39 £44 £63Internet £16 £16 £24Leaflets £5 £10 £15


Statutory Code £15


£96


£27

Spray Operator training:NRoSO £107Re-testing £73

Sprayer testing £230

Overall Additional Cost £480 £509 £586Cost as % of Sales 0.39% 0.42% 0.48%Cost as % of Profit 1.49% 1.58% 1.82%Note: Overall Additional Costs exclude consultation and assume leafleting and NRoSO registration where applicable. Consultation where used would reduce buffer zone and notification costs.

SID 5 (Rev. 3/06) Page 28 of 30

References to published material9. This section should be used to record links (hypertext links where possible) or references to other

published material generated by, or relating to this project.Defra (1998) The Code of Practice for the Safe Use of Pesticides on Farms and Holdings (the Green Code)

Defra (2006) Code of Practice for using Plant Protection Products

Assured Combinable Crop Standards 2005-2006, www.assuredcrops.co.uk

Assured Produce Generic Crop Protocol Standards 2004 revised February 2005, www.assuredproduce.co.uk

Assured Produce Generic Protocol Guidance Notes 2004, www.assuredproduce.co.uk

Scottish Quality Cereals Generic Protocol Guidance www.sqcereals.co.uk

Northern Ireland Farm Quality Assured Cereals Scheme

Voluntary Initiative www.voluntaryinitiative.org.uk

Centre for Ecology and Hydrology (2005) National Estimates of residential land adjacent to arable land using Countryside Survey Sample Data

Defra (2004) Agriculture in the UK

Garthwaite D, (2004) Pesticide Survey Report, A survey of current farm sprayer practices in the United Kingdom 2004, Report by CSL to the Voluntary Initiative.

SID 5 (Rev. 3/06) Page 29 of 30

http://www.voluntaryinitiative.org.uk/

http://www.sqcereals.co.uk/

http://www.assuredproduce.co.uk/

http://www.assuredproduce.co.uk/

http://www.assuredcrops.co.uk/

SID 5 (Rev. 3/06) Page 30 of 30

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