PBL report on manure fraud debatable

Fraud with manure does occur without a doubt. However, the estimate of its size, expressed at the end of March in an extensive report by the Netherlands Environmental Assessment Agency (PBL), is debatable and does not appear to be scientifically substantiated.

A few days after the publication of the PBL report, questions were already being asked in the House of Representatives: How is it possible that 30 to 40 percent manure circulates in the black circuit?

The (agricultural) press also picked this part out of the PBL report en masse. That is not surprising, because the chapter on manure fraud opens with this allegation. It is stated that it is 'possible' and that RVO and NVWA draw this conclusion on 'indicated from figures quoted by the sector itself.'

Sector signal
Inquiry shows that the PBL, and the other Wageningen research reports to which the PBL authors refer, are based on articles from New harvest en Farm from January 2014.
The author of the report and PBL employee Hans van Grinsven confirms that: 'The then LTO arable foreman Jaap Haanstra and Hans Verkerk van Cumela mentioned this at the time.'

However, Van Grinsven states that this figure is not the only one he bases on in the report. 'In addition to the sector signal, we have included findings from another recent study, in which the violations (identified by the NVWA) are described and we have found that the composition of the manure samples is more frequent.'

Serious clue
'As another pillar, we have fully calculated the CBS effect, which points to the 'disappearance' of manure, up to 30 percent in some regions, for the southern livestock area. By taking maximum account of corrections for (among other things) secondary establishments, the derogation and BEX and with uncertainties, such as animal numbers, excretion per animal and manure composition, we have tried, as it were, to demonstrate that this 'over-utilisation' is not the result of manure fraud. .'

Van Grinsven states that this showed that in the Southeast Brabant region the 'over-utilisation' for nitrogen is between 4 and 28 percent and for phosphate between 8 and 29 percent. 'So the manure is there, but it has not been placed or registered anywhere. That is therefore a very serious indication that percentages to that extent have disappeared into the black circuit.'

Unworthy reporting
Hans Verkerk van Cumela strongly criticizes the conclusions of the PBL. First of all, they base themselves on a 3 year old article from the Farm, in which my statements have been completely misinterpreted and reproduced. I've only confirmed that I know the noises that there may be 30 to 40 percent manure in the black circuit, but I have never said or confirmed that this percentage is correct.'

No scientific research
In addition, Verkerk states that PBL does not base its conclusions on scientific research. 'The NVWA research results, to which the PBL refers in the report, are (partly) select checks. The NVWA therefore had indications on the basis of which the audit was planned or carried out. The only representative data from results recorded by the PBL indicate that the average number of exceedances of the usage standards is 0,7 percent. So that's very good compliance.'

Verkerk says that with the tables and information it includes, PBL has created a picture of large-scale fraud, while this is not substantiated by these scientific institutions. 'In our view, this is unworthy of the Netherlands Environmental Assessment Agency and the scientists who wrote the background report.'

'Verkerk was on committee'
Hans van Grinsven points out that Verkerk himself was part of the supervisory committee for drawing up the report 'Evaluation of Fertilizers', of which the chapter on manure fraud is part. Verkerk nuances his role and even sharpens his criticism: 'I was only a member of the supervisory committee for one sub-study that examined CBS figures on fertilizer placement in Southeast Brabant. After peeling off these figures completely, a percentage of 4 to 8 percent came out as an unexplained exceedance.'

These results paint a very different picture than the current figures on overutilization for nitrogen. Namely the figures between 4 and 28 percent for nitrogen and for phosphate between 8 and 29 percent. 'I don't know why our final result has not been included in the report by the PBL,' says Verkerk.

More criticism
Thursday 11 May, the House of Representatives will be updated by Hans van Grinsven about the PBL report. Next Tuesday, May 16, a meeting is planned between the Mesdag Fund and the PBL. Jan Cees Vogelaar, chairman of the Mesdag Fund, has already said that he sees the report as incorrect and misleading.

The entire report can be read via this web link. Chapters 6 and 7 deal with the manure fraud problem.

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