The Agri Facts Foundation (STAF) states again that the Netherlands Environmental Assessment Agency (PBL) has hidden information in its publication on crop protection. According to the foundation, the PBL has omitted a lot of relevant information and the report is hardly verifiable.
STAF writes this in response to a letter published by the PBL. According to the PBL, it is in fact very transparent about its measurement method and the conclusions that STAF previously pulledincorrect in their view. The PBL also added an extra chapter. It describes how the conclusion; that the exceedances of the standard for plant protection products have decreased by 15%.
STAF maintains its point that it remains difficult to interpret the 15% decrease. A problem for STAF is the definition of exceeding the standard. PBL has chosen a strict definition, in which a measurement point with exceedances counts as an exceedance of the standard. However, a definition could also have been chosen in which a standard exceeding is based on measurements at the various measuring points.
Definition of Standard Exceedance
It is now possible that the number of violations of a certain product at a measuring point has fallen from 10 to 1. According to the definition of PBL, this does not matter: Even if the number of violations at a measuring point has decreased, it is and remains a standard violation. STAF and LTO state that, if the definition were to be used on the basis of multiple measurements, the target of 50% fewer standard exceedances would have been amply achieved.
STAF criticizes the fact that the PBL, despite the fact that it was aware that there are several definitions for exceeding standards, did not mention this. STAF therefore states that the PBL has not reported the full range of improvements, but has only put forward 1 option. The statement of the PBL that the 94 measuring points that were used are representative of the national measuring network is also incorrect. In addition, the PBL has used a stricter assessment method than prescribed by the EU.
Image damage
STAF writes that agriculture and horticulture have been unnecessarily damaged in their reputation by not placing the 15% in the right context. This is the responsibility of the PBL. That is why STAF asks once again to republish the 'Interim Evaluation for Crop Protection', but now in the right perspective. When asked, research coordinator Geesje Rotgers states that legal action can be taken. "Lawyers are watching from the start of this process and STAF is sure of its case. The complexity is being abused."
Click here for the letter from Staff to the PBL for a detailed argumentation.
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