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Impact Assessment on Pesticide Regulations in UK Phase 2 - PS2535

Description
In March 2006 Defra published Pesticides and the Environment: A strategy for the sustainable use of plant protection products (PESSUPPP) . The strategy deals primarily with the environmental impacts of plant protection products (PPPs), however the impacts on human health have been included in a revised version which is currently under review following industry consultation. The current strategy aims to promote uses of PPPs that achieve high standards in environmental protection while maintaining the economic viability of crop production. The strategy is to be delivered through 5 action plans – water, biodiversity, product availability, amenity and amateur use relying largely on existing legislation and measures. These action plans will in due course reflect requirements under the EU Thematic Strategy on the sustainable use of plant protection products which is currently under negotiation.

In project PS2534 Regulatory Impact Assessment of Pesticide Regulation in UK Phase 1, the components of key legislation relating to the implementation of the Action Plans for PESSUPPP were identified and available cost assessments identified and evaluated for current validity. The outcome of the project was a list of components that had no, or insufficient financial impact assessment.

The objective of Phase 2 of the project is to update the costs analyses of key components for inclusion in a full Impact Assessment (IA) following the guidance from the Department for Business, Enterprise and Regulatory Reform, Better Regulation Executive (Phase 3). The guidelines state that IAs are required where policy changes will lead to changes in costs or savings for business, the public sector, third sector organisations, regulators or consumers. The components of legislation which are relevant to meeting PESSUPPP objectives, which were identified in Phase 1, have been prioritised for action and those requiring updating agreed with PSD.The main areas for analysis are the approval process - 91/414/EEC, the maximum residue legislation and the application of the Code of Practice for the use of plant protection products, and impacts on agriculture and horticulture, amenity, agrochemical manufacturers, the distribution industry and the Government. PESSUPPP relies on existing legislation and measures to achieve its objectives, some of which have been introduced over a long period of time. PESSUPPP does not introduce any significant new requirements that would result in new impacts, costs and benefits. The overall cost of PESSUPPP could be regarded as:
• Nil – because there were no new requirements
Or,
• The cost of compliance with all the regulations and requirements it refers to.
The latter is more useful in understanding the costs of regulation, and the proposed approach for Phase 2 is to use the 2007 regulatory framework and business environment as a baseline, rather than assessing the costs at the time they were introduced, which is the more accepted methodology for assessing new legislation. The components identified and selected for impact assessment will be analysed for the ‘costs of compliance’ or the savings that would occur if the requirement were removed. There should be an allowance for the ‘Business as Usual’ principle whereby allowance is made for actions that would have been taken irrespective of the legislation, such as the requirements under Farm Assurance schemes.

This approach to impact assessment is judged appropriate because the realistic decision making framework is one in which pesticide regulation is incrementally advanced or removed. A scenario of nil regulation is not very helpful since such a situation is extremely remote. This proposal will allow consideration of the costs of incremental changes with individual aspects of regulation costed in the context of the current situation of regulation and markets.

The costs analysis for each component will cover a description of the action and the costs and to whom they accrue (developed from the phase 1 framework) with an analysis of the costs that can be monetised using the current business environment as a baseline. Information for the cost analyses will be obtained from reliable sources and informal consultation with the industry and will all be itemised along with clear assumptions. The cost analyses will cover the UK and identify important regional differences. The focus will be on the costs of the components rather than the benefits which are being covered in a separate PSD study. In order to obtain cost analyses for each component there needs to be a systematic approach to the analysis that is clear and consistent. Some information is easily available while other information may be more difficult to find or need a greater degree of estimation and assumptions. All calculations and assumptions and sources of information will be captured in an excel workbook to provide a clear and logical assessment which can be amended or updated at a later stage if required.

The final report will include a summary of all the assumptions and associated costs of complying with PESSUPPP in a format suitable for inclusion in a formal Impact Assessment.
Objective
The overall objective of Phase 2 is to update the costs analyses of the key components of the legislation behind PESSUPPP identified in phase 1 (PS2534) for inclusion in a full Impact Assessment (IA) following the guidance from the Department for Business, Enterprise and Regulatory Reform, Better Regulation Executive .
Specifically:
1. 91/414/EEC – review and extrapolation of existing costs to arable sector
2. Regulation 365/2005 – review and extrapolation of existing costs to arable sector
3. PESSUPPP costs associated with the Code of practice for the use of plant protection products – agriculture and horticulture
4. PESSUPPP costs associated with the Code of practice for the use of plant protection products – agrochemical manufacturers
5. PESSUPPP costs associated with the Code of practice for the use of plant protection products – supply industry
6. PESSUPPP costs associated with the Code of practice for the use of plant protection products - amenity
7. Review of catchment based approvals and advice on compensatory and mitigation measures.
Time-Scale and Cost
From: 2007

To: 2008

Cost: £39,350
Contractor / Funded Organisations
ADAS UK Ltd.
Keywords
Agriculture and Water Quality              
Agri-Environment              
Economic Policy Evaluation              
Environment and Health              
Environmental Effects              
Environmental Stewardship              
Pest and Weed Control              
Pesticide use              
Pesticides              
Plants and Animals              
Policy Development              
Fields of Study
Pesticide Safety