It seems that those involved in the review of the sustainable use directive for pesticides (SUD) are acknowledging that many member states have issues with the detail in the proposals, or at least some element of them.

This is not to suggest that they have changed their minds or that they have officially altered the proposals for change, but it is interesting to see that they acknowledge the problems.

Much of the reaction was published recently in what is termed a “non-paper”, which is a sort of official recognition of opinions that have been presented around many aspects of the sustainable use of pesticides regulations (SUR) proposals.

The comments used here refer mainly to matters relating to the proposals for sensitive areas. This is the same issue that we in Ireland find ourselves caught up in because all 26 counties in the Republic are classified as a single zone for nitrate sensitivity.

Consequence

Because the whole country is a single sensitive zone, the revised proposals indicate an effective 100% reduction in pesticide usage whenever the new regulations come into being. This may not have been the actual intention, but it was the potential consequence.

As a result of reaction from member states, the council working party is suggesting that alternative definitions for sensitive areas be explored, as the initial proposal affects a disproportionately high area in many member states.

The suggestion is to reduce the scope of the definition of sensitive areas and a reduction in the total area covered by the definition of sensitive areas. Member states would then focus on those areas deemed most relevant to pesticide use. So the implication of the proposal would not be gone away, but it could be more focused.

Removal

The paper also suggests the removal of nitrate, nutrient, urban waste water from the sensitive areas definition, with more targeted attention on the most relevant sensitive areas. These might still have implications for some fields in tillage, but they might be seen as more relevant.

Many other aspects of the SUR proposals were also commented in the document, with a general reaction to remove the ban on pesticides in specific areas while only allowing the use of biocontrol agents or low-risk plant protection products.