Integrated thinking


Water and agriculture are inextricably linked but in Germany, there are water pollution problems caused by farming that must be urgently addressed

The upsurge in land cultivation that has taken place over the past 60 years, coupled with the high use of fertilisers and pesticides and intensive mass animal farming, has led to significant increases in yield and productivity but also to massive environmental pollution. These factors increasingly threaten our drinking water resources.

One of the core problems is nitrates, commonly found in fertiliser, which ends up in groundwater resources. Due to this, farming is one of the main drivers of water pollution by nitrates. This is not a new problem. Cooperation agreements between water resources managers and farmers, and to some extent central water protection programmes at a regional level over the last 30 years, go some way to preventing nitrates from entering drinking water resources.

So far, billions of euros have been spent on compensatory payments to farmers in return for using less nitrates and pesticides in their work and therefore reducing the risk of these ending up in drinking water resources.



Let us first consider the nitrates problem in Germany. In the European Commission’s report on the implementation of the Nitrates Directive (91/676/EEC), Germany is ranked in the penultimate place before Malta for nitrates pollution. One reason for this is the unacceptably poor nitrogen efficiency of only 50%, caused by inadequate specifications in the implementation of the directive in Germany as well as a lack of controls and checks. The EU launched proceedings against Germany on the grounds of a non-satisfactory implementation of the EU Nitrates Directive.

And here’s why: agriculture makes up 0.8% of the German gross domestic product, which is an extremely low share; it employs 2.5% of all employees and it receives half of its income from subsidies. However, the legacy that is left for our children can increasingly be measured as environmental pollution of vast proportions.

In agricultural areas, half of the groundwater is already contaminated to such a degree that it may no longer be used as a drinking water resource. Looking at Germany as a whole, we can assume that 10-15% of drinking water resources are severely contaminated with nitrates. A conservative agricultural policy led by the German farmers’ association has systematically dismissed, suppressed and denied the associated environmental impact, and proposed solutions from the agricultural lobby are still lacking. Any German car manufacturer is more transparent than a farm as far as environmental pollution is concerned! This is no longer socially acceptable. Industrial agriculture is increasingly perceived as a burden for the environment by citizens.

But let us return to the drinking water resources. Due to the long response time of the ‘agricultural system’ and the nitrates-contaminated groundwater bodies, action must be taken immediately – now!

The most important objective is to cut the nitrates excesses to under 50kg N/ha per annum, measured according to the farm gate balance (PARCOM method). This requires, in particular, the long overdue improvement of nitrogen efficiency. The regulatory implementation of this is to be achieved by a bundle of clearly defined, binding and controllable measures, infringements of which are punishable by law. We also need to link all relevant environmental data and make it publicly available. It is high time to introduce a modern, environmentally compatible agricultural system, the associated normative framework and the latter’s enforcement as well as the transparency of agricultural data for the ordinary citizen.


The last revision of the European Common Agricultural Policy (CAP) got off to a good start. The then Environment Commissioner, Janez Potočnik, announced a fundamental realignment of priorities: ‘greening’ was to become the hallmark of agricultural policy between 2014 and 2020.

The future CAP must be green: “It is essential that the future CAP contributes the public goods we need to meet the environmental and climate challenges we are facing today. I do not see how the amount of public funds spent on agriculture can be legitimised unless the future CAP makes a significant contribution to reaching the EU’s environmental and climate targets. We must tackle these challenges today to avoid much bigger problems in the future. I strongly believe that prevention is better than cure. If there is a CAP in the future, it must be green. And we must not only sanction farmers who do not respect environmental rules, we must also reward those who do provide environmental public goods, because the market does not reward them for that.”

Janez Potočnik, ‘The future CAP must be green’, The 4th Forum of the Future of Agriculture, 2011

EurEau supported the greening measures of agricultural practices as incentives for farmers and emphasised that water resource protection is one of the most important components in attaining sustainable agricultural practices. As such, EurEau stressed in 2013 that more specific ‘blueing measures’ should be included in the new legislation to pave the way for a water resource protecting farming, covering specific water related requirements in:

  • Plant nutrition and fertilisation.
  • Land utilisation and cultivation.
  • Plant protection (pest management).
  • Water management.
  • Organisation and management.


Apart from the initial euphoria, not much is left of this commitment to a more environmentally sound agriculture. On top of that, many Member States – among them Germany – are not dedicated to implementing the Nitrates Directive, even within the scope of periodic revisions. Thus, the requirements for the sustainable protection of drinking water resources are still not taken seriously, as if everyone still failed to see the importance of the elementary objective of the Nitrates Directive, i.e. the reduction of nitrates contamination from agricultural sources. Even in the face of all the appeals on the part of the water utilities and environmental associations, basic aspects are still lacking.

There is common agreement among experts that it is necessary to:

  • Determine the fertiliser requirement specifically for the respective site.
  • Introduce broader peripheral strips of land along bodies of water and controllable distance regulations.
  • Establish reduced upper limits for organic nitrogen fertilisation without exceptions and without derogation rules for fermentation residues.
  • Adapt the blocking periods to plant requirements and vegetation periods.
  • Introduce the gross farm gate balance for nutrient comparisons and their assessment, without deduction of any environmentally relevant nitrates and phosphorus losses and to subsequently disclose this as environmental data.
  • That storage capacities for nine months in the case of liquid and six months in the case of solid farm fertilisers are sufficient to meet the requirements of demand-based fertilisation.
  • That exceeding the upper limits for organic nitrogen fertilisation and the permissible nitrogen excess will be punished as a regulatory offence.
  • That regulatory offences will entail a monetary fine.
  • That if quality objective limits for groundwater and surface water are exceeded, further requirements on fertilisation will be imposed.


Raw water for the public drinking water supply should largely be free of pesticide residues. The intensive agriculture practised today makes use of chemical pest management to protect crops. However, depending on local conditions, protecting drinking water resources can require measures that have to go beyond the requirements of a comprehensive water pollution control.

Contrary to the specifications of plant health legislation for integrated plant protection, in practical application, the use of chemicals is given precedence over other measures for the protection of crops. For economic reasons, pesticides are the standard procedure instead of the last resort. This is only possible because the consequential costs of the use of pesticides in agriculture can be passed on to the consumer.

The further increase of the annual tonnage of pesticide sales in Germany proves that the restriction of chemical plant protection according to the German Plant Protection Act (PflSchG) and the operational implementation of EU law through the National Action Plan are failing. With the exception of 1998, the annual tonnage between 1995 and 2005 amounted to approximately 35.000 tonnes of active substances.

Since 2006, sales have increased and now amount to more than 46.000 tonnes of active substances (for 2014). This inevitably leads to water pollution; 50% of the groundwater resources are already contaminated by pesticide residues, and this is rising. As soon as the use of pesticides in water protection areas causes thresholds to be exceeded, water operators need to use more costly treatment techniques and national economic efficiency is negatively impacted.

Conspicuous findings concentrate on ‘hot-spots’. The protection of these sometimes sensitive catchment areas (e.g. karst) with a pesticide usage beyond the pollution load capacity of the location is not currently possible. PflSchG, with its approach of undivided comprehensive water protection with the ‘same protection level for all’ fails at this point; there is no interlinking of plant protection, water, agricultural and drinking water laws. In the absence of clear specifications, the implementation of European law by means of a National Action Plan leads to a dilution instead of an effective operationalisation of EU law with measurable results in the form of declining application rates and decreasing concentrations in ground and surface waters.

Pesticides’ active substances are designed to be highly effective in selective instances, while being rapidly degradable and evolving metabolites. It is not feasible to do without metabolites but these metabolites should be as harmless as possible. These requirements can be met by different thresholds or health-related indication values. EU law must be developed further in this regard by anchoring the health-related indication values in EU law. Pesticides with concentrations of nonrelevant metabolites greater than health-related indication values may no longer be licensed.

Apart from the quantities applied, the efficiency of pesticides is also of importance for an evaluation of the use of pesticides from an environmental protection point of view. Thus, modern, highly effective pesticides can – despite a lower dosage – exhibit the same hazard potential as older pesticides requiring a higher dosage. Too little is known about the synergies of pesticide residue cocktails. The previous cumulative value has not displayed any effect and must be replaced by new evaluation approaches, taken, for instance, from effect-related analytics.

As far as the nonrelevant metabolites are concerned, PflSchG comes to nothing. In addition, there is no consistency either in national or EU law. Furthermore, EU water policy is not consistently implemented in Member States and remains ineffective on account of vague objectives, inconsistent enforcement and strong lobbying from the agricultural sector. We need the consistent implementation of drastic measures based on clearly measurable target figures (tonnages and concentrations).

The interlinking of water, agricultural and plant protection policies with the following mechanisms is mandatory:

  • The interlinking of emissions and (permissible) emissions (in concrete terms: a ban on using an active substance in the catchment area if 75% of the limit is exceeded).
  • Prioritisation of ecologically compatible methods by taxing the polluting substances (pesticide levy or withdrawal of EU funding when these substances are applied).
  • Promotion of environmentally compatible methods or compensation for damages (for instance for the required treatment technology) with the funds that are thereby released.


The EU urgently needs to align chemical law, agricultural policy, water and environmental law. Integrated thinking and acting must be implemented at EU level. The coexistence of conflicting legislation weakens its influence and efficiency.

Both for pesticides in general and for nitrates in particular, binding rehabilitation targets for water resources, combined with strict measures for agricultural and other emission sources are urgently required. This means: if emission targets (75% of target value) are exceeded in drinking water resources, this must lead to the sanction-reinforced reduction of emissions (nitrates) or an application ban (pesticides), in particular on agriculturally used areas. According to the drinking water quality parameters set in the Drinking Water Directive, emission thresholds have to be set/determined in agricultural, water or environmental law.

This binding element between chemical, environmental, agricultural and drinking water policies is missing. For an effect to be achieved, payments within the scope of the CAP must be based on consistent and measurable parameters (integrated plant protection, nitrates balances, specific pesticide expenditure). Payments alone for (ineffective) measures must be stopped, i.e. every measure must be allocated to a measurable target figure. This in turn requires the consistent, binding recording of emission data for pesticides and nutrients in agriculture at the level of the individual agricultural holding. For transparency, the emission data of all agricultural holdings receiving EU subsidies must be disclosed within the scope of providing environmental information to EU citizens.

Consistent action must be taken against implementation deficits at the level of the Member States. There are implementation deficits, no awareness deficits!

The CAP, the Nitrates Directive 91/676/EEC, the Pesticide Approval Regulation (EC/1107/2009), as well as the Water Framework Directive (2000/60/EC) need to be evaluated and realigned with regard to the ‘water and agriculture’ nexus, followed by a subsequent adjustment of the legal act.

EU chemicals, agricultural, environmental and drinking water policies must be interlinked and payments for environmental performances in agriculture linked with target figures. Integrated thinking and acting is what is needed.


by Dr Claudia Castell-Exner, Deputy Head of Water Department, DVGW and Professor Dr-Ing Frieder Haakh, Technical Director, Zweckverband Landeswasserversorgung

Read more: Water Matters

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