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CAPÍTULO I: EL HECHO Y NEGOCIO JURÍDICO, LA AUTONOMIA DE LA

1. SUB CAPÍTULO I: EL HECHO Y EL NEGOCIO JURÍDICO

Croatia has no comprehensive statistical method of data collection with regard to the use of agricultural inputs. In other words, all sources used provide only partial data with limited reliability. Thus, the official figures can vary a lot, depending on the source of primary data used and the purpose for which it is gathered. However, the most common problem and mistake in these calculations is the surface of agricultural land. As demonstrated in chapter on the land use, Croatia has today some 50% less agricultural land than shown by the Statistical Yearbook. Therefore, calculations on per hectare consumption of agri-chemicals based on this large agricultural land surface do not seem to be feasible and accurate. However, this approach is used with no exception! Thus, no wonder that Croatian authorities and scientists report on relatively low per hectare fertiliser and pesticide consumption (Grgić, Franić et al. 1999; ICID 2001; Igrc-Barčić 2002; MZOPU 2002; MPŠ 2003; VRH 2003). However, the environmental pressure caused by fertiliser and pesticides Manure Inputs and agricultural area 0 0,5 1 1,5 2 1910 1988 2001 2003 L U in m ill io n

in Croatia is much greater, since these substances are spread over a relatively small surface.

Another problem related to the assessment of consumption of agri- chemicals is whether to use total agricultural land, utilised agricultural land or arable land. Croatia practices bipolar agriculture. On one hand, there are areas of abandoned or extensively managed land, mostly grassland. On the other hand, arable and permanent crops are managed quite intensively. In practice, grassland in Croatia is hardly ever treated with fertilisers or pesticides. The only areas receiving application of agri- chemicals are arable and permanent crops. Therefore, it is more appropriate to assess environmental pressure of agri-chemicals in Croatia by expressing their consumption per hectare of actually treated arable land and permanent crops or per hectare of arable land.

Because of the varying intensity of agricultural production in different regions, agrichemicals are unevenly spread in Croatia. Regions with plenty of arable land and intensive agriculture (Slavonia, Međimurje, Podravina, etc.) record quite high applications of pesticides and fertilisers, while karstic Croatia with vast areas under (neglected) grassland uses far less of these (Mesić 2002; DZS 2003; Moller 2003).

3.5.1 Fertiliser consumption

There is a widespread consensus that the consumption of fertilisers in Croatia is “relatively low” (MPŠ 2003) and “certainly some 30 % lower than before 1990” (MPŠ 2003). In other words, the consumption level of pre-1990 is inter alia set as a reference and desired target that is to be reached again. However, although some studies predicted a sharp recovery of the consumption in mineral fertilisers and a return to pre- 1990 levels by 2000 (MPŠ 1996; Grgić, Franić et al. 1999).

Croatia has too few figures on agricultural inputs at the farm level and the official statistics consist only of aggregated national figures. The DZS data on fertiliser consumption presented in the Statistical Yearbook are derived from two sources: annual statistical reports from agricultural companies and estimates based on questionnaires carried out among some 9,000 family farms. While the figures for the usage of fertilisers by companies should be quite accurate, estimates based on interviewing representatives of small number of farms are certainly less accurate. The fertiliser data presented in the Statistical Yearbook are incomplete and have been subject to criticism (Mesić 2002). The agricultural census (DZS 2003) does not give information about the quantity of fertilisers consumed, but it does give figures on the land area treated. According to these, fertilisers are spread on as much as 755,517 hectares- a surface that is equal to 70% of the total UAA or 93% of arable land.

The fertiliser data in the Statistical Yearbooks (DZS 2003; DZS 2004) are expressed as the total quantity of fertilisers used, by both family farms and companies. Unfortunately, this figure does not tell us much about the environmental load of fertilisers, as it is not expressed in terms of active ingredients. Different types of fertilisers contain different quantities of nutrients (N, P2O5 and K2O). Thus a figure indicating

consumption of 100 kg fertiliser gives no idea about how many nutrients Believed to be

low and

predicted to rise

were loaded into the environment. For instance 100 kg of urea fertilisers contains 46 kg N, while the same amount of calcium ammonium nitrate (CAN) contains only 25-28 kg N -just over half as much. In both cases, consumed is 100 kg fertiliser, but the consumption of nutrients is quite different The quantity of fertilisers consumed, expressed in terms of active ingredients is given only for companies and a similar figure for the private sector cannot be obtained by the DZS.

Nevertheless, the DZS data indicate that the consumption of fertilisers in Croatia in the period 2000-2002 was stable (in average 416,000 t), with the difference between the year with the lowest and highest consumption being only 8%.

FAO statistics give also data on fertiliser consumption in Croatia (FAO 2005). However, FAO figures are expressed as nutrients and are approximately four times higher than figures on nutrients reported by the DZS in the Statistical Yearbook. This is because DZS gives data only on nutrients used by the agricultural companies. FAO statistics are based on the figures provided by Petrokemija (Deur 2004; Piršić 2004) - the sole Croatian fertiliser producer and biggest fertiliser trader. Therefore, FAO statistics do not include fertiliser quantities imported and distributed by other companies. As the FAO calculates fertiliser consumption per agricultural year (July 1- June 30) this also causes some difficulties in comparing its figures with those from the Croatian statistics, which are always recorded per calendar year. FAO figures also indicate quite a stable use of mineral fertilisers over the last couple of years.

According to a recent study assessing agricultural impact on water in Croatia, conducted by experts from the Faculty of Agronomy at the University of Zagreb (Mesić 2002), in 2000 Croatia consumed 505,000 tonnes of fertilisers (or 215,000 of nutrients). This figure is much higher than the figure shown in the Statistical Yearbook (403,316 t total fertiliser)! Data for this study were also largely provided by Petrokemija and its results have been already been quoted in some policy documents (Moller 2003; MPŠ 2003; FAO 2004).

3.5.2 Pesticide consumption

It is very difficult to obtain reliable statistics on pesticide consumption in Croatia, as there is no organisation responsible for keeping track of this. Pesticide consumption is also not reported in the Statistical Yearbook and DZS has no data related to pesticides. Some policy documents suggest that the consumption of synthetic plant protection agents in Croatia has been quite stable over the last couple of years, amounting to approximately 3,300 tonnes of active ingredients per year (MZOPU 2002; MPŠ 2003). The MPŠVG’s Department for Plant Protection estimates that the use of pesticides in Croatia is between 7,200-9,000 tonnes (Moller 2003). According to census data, pesticides are spread at least once a year on as much as 656,426 hectares - a surface that is equal to 61% of the total UAA or 82% of arable land (DZS 2003). Herbicides seem to account for 50-60% of all agents used, while fungicides make up 35-45% and insecticides only 5-6% (MZOPU 2002). Currently there are some 700 approved pesticides (based on some 280 active ingredients) on the Croatian market. Illegal pesticide trading/smuggling from neighbouring countries is a problem that occurs FAO data

Data from recent studies

No reliable statistics

due to cheaper prices abroad. This practice is known to the public, but the quantities of illegally imported pesticides are never estimated and/or reported.

Although Croatian plant protection specialists suggest that the use of pesticides per hectare in Croatia is approximately 2.5 times lower than in the EU (Igrc-Barčić 2002), this does not seem to be the case. A recent calculation (Znaor and Karoglan Todorović 2004) shows that when calculated per actual surface of arable land, Croatian pesticide consumption in the period 1999-2003 amounts to 4.2 kg of active ingredients per hectare of arable land. This is substantially higher than the figure of some 3 kg that can be found in other recent documents (Znaor 2002; Moller 2003; WRI 2003). The new data from EUROSTAT (EUROSTAT 2003), suggest that the average pesticide consumption in 1999 (last year with complete statistics) for EU-15 was 3.1 kg of active ingredients per hectare of arable land. In the same year, Croatian consumption was 3.6 kg- a mere 16% higher than the average of the EU-15. However, the average pesticide consumption in the EU-15 has most likely lowered in the meantime. This is because several EU countries (notably Benelux and Scandinavian) have initiated serious national pesticide reduction programmes since then. In addition, new pesticides containing less active ingredients are being applied and a number of farms have been enrolled into agri-environment programmes. However, during this time consumption in Croatia has remained quite stable.

3.5.3 Machinery and irrigation

The machinery used is outdated and inappropriate for modern agricultural operations (MPŠ 1996; MPŠ 2003). The average age of the tractors used in Croatia is more than fifteen years (VRH 2000), with former co-operatives having substantially younger tractors than private farms, whose average tractor is older than twenty years (UN-ECE 1999). The amount of agricultural machinery in use has been in constant decline since 1994, particularly in the former co-operatives (Sviržnjak 2001). In 2003 these had only 3,934 tractors (DZS 2003), which is equal to only 0.018 tractors per hectare of the companies’ UAA, and represents a drop of some 40% in comparison with 1994. At the other hand, the family farms seem to be well equipped. In 2003, these had 86,243 single and 185,954 two-axis tractors (DZS 2003), an equivalent of even 0.21 two-axis tractors per hectare of the UAA cultivated by the family farms. However, this is still some 40% less than in 1995 (DZS 1996).

According to the government’s figures, up to 1.8 million hectares of agricultural land (50 % of the total) requires drainage systems (UN, 2002). However, these are built on only 600,000 hectares (on 33.5% of the area needed) and only partly on 520,000 hectares, while 670,000 hectares (37.5%) of excessively moist soils have no drainage systems at all (UN 2002). Subsoil pipe drainage has been installed on only 162,000 hectares (out of 823,000 hectares requiring this system (UN 2002). Since almost the entire Croatian drainage system was built before 1990 and has been inadequately maintained, it is in rather bad condition (MPŠ 1996). Only 0.2% of cropland is irrigated (according to the FAO's Pesticide consumption higher than EU average Outdated machinery Poor irrigation

AQUASTAT Information System on National Water Extraction from Agriculture (FAO 2003), 0% of total water extracted in Croatia goes to agriculture).

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