World Bank Regional Agricultural Pollution Study An Overview of Agricultural Pollution in Vietnam: Summary Report 2017 World Bank Regional Agricultural Pollution Study An Overview of Agricultural Pollution in Vietnam: Summary Report 2017 Submitted to The World Bank’s Agriculture and Environment and Natural Resources Global Practices Written by Emilie Cassou, with Dai Nghia Tran, Tin Hong Nguyen, Tung Xuan Dinh, Cong Van Nguyen, Binh Thang Cao, Steven Jaffee, and Jiang Ru © 2017 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000 Internet: www.worldbank.org This work is a product of the staff of The World Bank. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. 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Cover photo credits, clockwise from top-left (further permission required for reuse): • Coffee picking. © imageBROKER / Alamy Stock Photo. • Pig farm in Phu Tho. © CIAT (International Center for Tropical Agriculture) (CC BY-NC-SA 2.0). • Shrimp. © trainman111 / Shutterstock. • Pesticide spraying on rice field. © André van der Stouwe (CC BYNC-SA 2.0). CONTENTS Abbreviations........................................................................................................iii Foreword............................................................................................................... iv Introduction.......................................................................................1 Commodity focus..............................................................................................2 Findings.............................................................................................5 Livestock sector.................................................................................................5 Aquaculture sector.............................................................................................7 Crops sector....................................................................................................10 Public sector action to date..............................................................................16 Ways forward...................................................................................21 References............................................................................................................23 ii An Overview of Agricultural Pollution in Vietnam: Summary Report Figures Figure 1. Domestic food supply of all animal products..........................................2 Figure 2. Vietnam’s food product rejection rate compared, 2002–2010...............10 Figure 3. Trends in cereals production, yield, and harvested areas, 1961–2013....11 Figure 4. Farm size distribution, 2001–2011.......................................................11 Figure 5. Fertilizer application rates on rice paddy in selected Asian countries, 2010–2011...........................................................................13 Figure 6. Breakdown of agricultural GHG emissions in Vietnam, 2014 estimates...............................................................................................16 Figure 7. Increases in Vietnam’s reported agricultural GHG emissions, 1994–2010...........................................................................................16 Figure 8.  Key legal measures pertaining to agro-environmental policy since 2004......................................................................................................17 Tables Rejection of Vietnam’s fish and fishery products from its main Table 1.  export markets, 2002–2010...................................................................10 ABBREVIATIONS ASC Aquaculture Stewardship Council DARDs Departments of Agriculture and Rural Development FAO Food and Agriculture Organization GAPs good agricultural practices GlobalG.A.P. Global Good Agricultural Practice GSO General Statistics Office MARD Ministry of Agriculture and Rural Development QCVN quy chuẩn kỹ thuật (technical regulation) VietGAP Vietnamese Good Agricultural (and Aquaculture) Practice iv An Overview of Agricultural Pollution in Vietnam: Summary Report FOREWORD Between July 2015 and December 2016, the World Bank conducted a regional study of agricultural pollution in East Asia with a focus on China, Vietnam, and the Philippines, in cooperation with each country’s ministry of agriculture. This effort aimed to provide a broad overview of agricultural pollution associated with farming at the regional and national levels: its magnitude, impacts, and drivers, and what is being done about them. It also sought to outline potential approaches to addressing these issues going forward. In doing so, the study examined how the structural transformation of the agricultural sector and the evolving nature of agricultural production are shaping agricultural pollution issues and mitigation opportunities. It also identified knowledge gaps, pointing to directions for future research. Ministries of agriculture and environment are the intended primary audience of the study. It is also intended for development organizations, industry associations, and other actors with an interest in sustainable agriculture, and environmental health and protection. The “study” constitutes the totality of the work and includes multiple components, including national overviews of agricultural pollution for the three focus countries, thematic working papers, and an overall synthesis report. The present report corresponds to the national overview of agricultural pollution in Vietnam, and specifically to the summary of three working papers on crops, livestock, and aquaculture systems. The overview covers water, soil, and air pollution directly associated with activities and decisions made at the farm level or its equivalent (for example, at the pond level in the case of aquaculture). It especially looks at (a) the use of fertilizers; (b) the use of pesticides; (c) other cropland management practices (including the use of plastics, the introduction of invasive species, irrigation, and land preparation practices); (d) the burning of agricultural residues; (e) animal waste management (land and aquatic species); and (f ) the use of feed supplements, including antibiotics, hormones, and heavy metals in animal agriculture (land and aquatic). Environmental impacts relating to land-use change are beyond the scope of the study. The statements made in this national overview are based on existing literature, and on national and international data sources. An earlier version of this report was circulated to stakeholders representing national government agencies, nongovernmental agencies, and research institutions, and was discussed at a stakeholder consultation workshop in Hanoi in December 2016. The report was finalized by consolidating and addressing comments from various stakeholders. Foreword v This report was written by Emilie Cassou, drawing on background reports on Vietnam’s agricultural pollution situation by Tung Xuan Dinh (on livestock pollution), Tin Hong Nguyen (on crops pollution), Cong Van Nguyen (on aquaculture pollution), and Dai Nghia Tran (on agro-environmental policy), and with contributions from Steven Jaffee, Jiang Ru, and Binh Thang Cao. The reports on livestock, crops, and aquaculture pollution are available online, along with a table of major policies (legal measures) addressing agricultural pollution. This study was made possible with funding from the East Asia and Pacific Region Infrastructure for Growth Trust Fund, which is financed by Australia and administered by the World Bank Group. INTRODUCTION Vietnamese agriculture has experienced remarkable growth over the past 20 years. The sector’s strong performance has propelled the country into the ranks of the top five exporters of half a dozen agricultural commodities, and contributed to poverty reduction, social stability, and significant improvements in food security. Today, however, Vietnamese agriculture is edging toward the limits of a growth model rooted more in the intensification of production systems—featuring heavy use of labor, chemicals, and natural resources—than in efficiency or value addition gains. Agricultural growth is decelerating and Vietnam’s competitiveness as a provider of bulk, undifferentiated commodities is flagging as the agricultural sector faces rising competition for labor, land, and other resources.1 The environmental fallout from intensification has also begun to adversely impact productivity and the position of Vietnam’s commodities in international markets. If it is to fulfill its ambitions and remain a motor of economic development, Vietnam’s agriculture will need to start producing “more from less.”2 In this regard, tackling agricultural pollution represents a key challenge for Vietnam. Pollution has started to take a toll on the sector’s own resource base, potentially impacting soil fertility and yields, the effectiveness of chemicals in combating pests and disease, farmer health and productivity, environmental health, and the safety of food.3 Meanwhile, the wasteful use of inputs is a drag on farm profitability. The scientific evidence on the incidence and impacts of agricultural pollution in Vietnam remains limited, but more has started emerging. Meanwhile, the general population has become increasingly aware of the human and environmental health problems that agricultural pollution is generating. Growing evidence and public concern about pollution have led the Vietnamese government to adopt a new outlook and to take measures to address the problem. At the strategic planning level, the Ministry of Agriculture and Rural Development (MARD), through its Agricultural Restructuring Plan of 2013, embraced the need to reduce the sector’s emissions and environmental impacts and outlined several specific targets. Since then, multiple agro-environmental laws and regulations have been adopted by various ministries, although their enforcement is still in early stages and geographically uneven. 1 See Jaffee et al. 2016. 2 That is, generating more economic value and consumer and farmer welfare, while using less material inputs and human and natural resources, and reducing the sector’s environmental footprint (Jaffee et al. 2016). 3 See World Bank. 2016. 2 An Overview of Agricultural Pollution in Vietnam: Summary Report In retrospect, over much of the last two decades, the Animal agriculture (terrestrial and aquatic) was agricultural sector’s environmental performance selected because it is among the country’s fastest- has been subordinate to farm output expansion. growing economic subsectors, and one of the And when environmental concerns have been raised, country’s leading contributors to pollution. Vietnam they have mostly been about forest encroachment by is experiencing one of the fastest rates of growth in expanding aquaculture and cropland, that is, land-use animal product consumption in the world (see Figure change, and less about pollution related to farming 1), and sector responsiveness to rising demand is giving per se. Agricultural pollution has generally received rise to an expanding pollution problem. Pollution less attention, perhaps due in part to the complexity from this sector is expanding not only because of its of measuring a multifaceted and spatially diffuse growth, but also because of the changes in production phenomenon. The resulting scarcity of data capturing practices and industrial organization that rapid growth agricultural pollution has, in turn, limited researchers’ has engendered. ability to comprehensively study its impacts on such things as human and animal health, biodiversity, the Domestic food supply of all animal Figure 1.  profitability of farming and other industries, and the products overall net societal value of agricultural production. Index, 2000 = 100 250 – 230 – The research upon which this summary report 210 – is based represents the first attempt to assemble 190 – existing evidence on the nature and magnitude of 170 – agricultural pollution in Vietnam, looking across 150 – the livestock, aquaculture, and crops subsectors. It 130 – is also an attempt to shed light on the socioeconomic 110 – 90 – impacts and drivers of agricultural pollution, including 70 – the shortcomings of existing policies and programs to 50 – reign in the problem. 2000 2002 2004 2006 2008 2010 Domestic food supply = production+imports-exports+changes in stocks (decrease or increase) ▬▬VNM ▬▬IDN ▬▬CHN ▬▬KHM ▬▬BRA ▬▬PHL ▬▬MYS ▬▬KOR ▬▬USA ▬▬EU ▬▬THA ▬▬JPN ▬▬World Source: Based on FAOSTAT Food Balance Sheets. Commodity focus Pigs and poultry birds a re the largest and fastest- This overview focuses on the pollution effects of growing livestock populations and generate the most, production systems for a subset of agricultural and most concentrated, wastes. The businesses that commodities: pig and poultry products, and to a hold these animals have gone far down the path lesser extent cattle products; intensively farmed of industrialization, a shift characterized in part Pangasius and shrimp; and rice, maize, and by increased throughput and greater reliance on coffee. This selection reflects the significance of commercial feed and pharmaceuticals. While some these commodities in terms of both their economic of this has gone hand in hand with the emergence of and pollution contributions, and in some cases, an larger-scale operations (in 2015, semi-industrial and industry trajectory that could result in higher levels of industrial production accounted for 64 percent of pollution in the future. The selection also takes into the livestock subsector’s total output [Nguyen D. V. account ongoing governmental programs currently 2015]), industrialization has also progressed within supported by the World Bank, and thus, opportunities the dense clusters of small livestock farms that have to immediately deepen efforts to promote sustainable formed around populous consumption centers, such agricultural intensification. as Hanoi and Ho Chi Minh City. Today, both large and small operations pose an alarming pollution problem. The regions generating the most animal Introduction 3 waste are the Red River Delta, the South East, and the country’s rice basket. The Red River Delta is a distant Mekong Delta. second (and declining) contributor to rice output. Rice paddy production accounts for the largest proportion Most cattle and buffalo c ontinue to be raised in of Vietnam’s use of fertilizer and pesticides, with coffee extensive, low-intensity systems, and the wastes they and maize ranking a distant second and third in the generate have yet to cause major environmental use of these inputs (based on GSO data). problems. This is despite the fact that, as of 2014, over 80 percent of cows lived in just six of Vietnam’s Maize  ranks second in terms of its planted area in 63 provinces and central cities.4 However, this Vietnam. While previously grown primarily for food situation is changing with the emergence of large- in upland areas, over 80 percent of national maize scale, commercial dairy and beef operations. The production is now estimated to be used for animal manure generated by some of the commercial dairy feed (for both livestock and aquaculture operations) farms being established near big and midsized cities (Nguyen T. H. 2017). Maize production occurs such as Hanoi, Ho Chi Minh City, and Vinh in Nghe throughout the country. The North West, North East, An province (South Central Coast) already exceeds and Central Highlands regions account for around the land’s nutrient load capacity (Lê 2012; Duteurtre 60 percent of total output, and the most intensive et al. 2015), and the regulations in place to protect production occurs in the Central Highlands. groundwater and surface water from contamination are only weakly applied. Coffee is one of the tree crops for which Vietnam has emerged as a major global supplier. Vietnam went In relation to fisheries, aquaculture is not only on from being a minimal player in world coffee markets a path of much steeper growth than capture fisheries, at the end of the 1990s to being the second-largest but is also the larger polluter of the two fisheries global producer one decade later (based on FAOSTAT subsectors due to the use of large quantities of feed data). Almost all of it is intensively cultivated in the and pharmaceuticals. (It is difficult, with limited Central Highlands region. Coffee’s expansion and data, to compare levels of pollution generated by intensification have occurred in a largely uncontrolled aquaculture and livestock—an issue that warrants fashion, and its environmental costs include further discussion.) Within the aquaculture sector, deforestation, land degradation, and the depletion of Pangasius and shrimp production both have large groundwater—as well as water and soil pollution. spatial and environmental footprints; the area they occupy (especially shrimp5) and their intensity having The research underpinning this study focused both grown significantly over the last 10 to 15 years. primarily on pollution arising from (a) animal feeding The key region in terms of aquaculture production and supplementation practices, (b) animal waste and is the Mekong Delta, which accounted for over wastewater management practices, (c) fertilizer use, 70 percent of the farmed area and output in 2013 (d) pesticide use, and (e) the burning of crop residues. (based on General Statistics Office [GSO] data). The Red River Delta and the North Central and Central Coasts occupy a distant second and third position. Rice is Vietnam’s leading food staple and continues to account for most of the area under crops. And the Mekong Delta—where half of national rice production and 90 percent of rice exports originate6—is the 4 Hanoi, Son La, Nghe An, Lam Dong, Ho Chi Minh City, and Long An. 5 Shrimp farming occupies far more space than Pangasius does (well over 100 times more), but Pangasius is produced in higher volumes (Kam et al. 2012). 6 http://www.pecad.fas.usda.gov/highlights/2012/12/Vietnam/. FINDINGS Livestock sector Livestock production is not only growing but also industrializing and spatially concentrating—often in troublesome proximity to densely populated areas—even while remaining smallholder-dominated. This situation, which the government is trying to counteract by encouraging consolidation and spatial redistribution, has translated into a mismatch between producers’ capacity to invest in or coordinate pollution control on the one hand, and the environmentally risky industrial methods of production that have come to dominate the sector, on the other. This is in a context of weak economic incentives and limited pressure to comply with environmental regulations. The intensification of livestock production has not lived up to its potential to lessen pressure on the environment by bringing about professionalization and gains in efficiency. Instead, it has given rise to more spatially concentrated and chemically charged waste streams. And while this may be partly due to the prevalence of small-scale farming, a shift to large-scale commercial farming may not hold the solution to the industry’s pollution problems. Even though large-scale farms invest more in waste treatment than small-scale farms, in proportional terms, the efforts of large-scale farms, including ones operating near Hanoi and Thai Binh in the Red River Delta, and Ho Chi Minh City and Dong Nai in the Mekong Delta, often fall short of what would be needed to manage the large volumes of concentrated wastes they generate. Livestock pollution problems are most pronounced in the pig sector. Pigs generate by far the most waste in both absolute and relative terms (per animal). In geographic terms, livestock pollution problems are the most pronounced in the intensively farmed provinces of Thai Binh and Hanoi in the Red River Delta and Dong Nai in the Mekong Delta regions. The estimated 80 million tons of livestock waste generated each year are vectors of nutrients, pathogens, and volatile compounds that compromise water and (based on DLP-MARD 2015). In pig farming, for air quality and damage soils  example, around 70 to 90 percent of nitrogen, minerals (phosphorus, potassium, magnesium, and others), and heavy metals contained in feed are reportedly excreted to the environment (Dinh 2017). The level of wastewater contamination by 6 An Overview of Agricultural Pollution in Vietnam: Summary Report coliform caused by smallholder pig farms was found it is frequently overapplied, causing harm to soil to be 278 times higher than the permitted level, while fertility (acidification, microbiota imbalances, heavy that of commercial farms was 630 times higher than metal accumulation), and increasing the risk of crop the permitted level in one study (Phùng et al. 2009). contamination with pathogens. This raises potential Concentrations of ammonia in air emissions from pig concern about the widespread use of chicken manure farms in the North region have been found to be 7 as fertilizer (some 75 percent is used this way [Dinh to 18 times higher than permitted levels, and that of 2017]), poultry wastes being second only to those hydrogen sulfide 5 to 50 times higher (Vũ 2014). generated by pigs. Although laws and regulations have been adopted Both treated and untreated livestock wastes to prevent this situation, around 36 percent7 of also spread the pharmaceuticals that are now livestock waste is estimated to be dumped into systematically used in intensive pig and poultry the environment untreated. Partly due to the lack production.8 Although Vietnam-specific evidence of regulatory pressure on farmers who engage in this is limited on this, chronic exposure to these practice, and the unattractive economics of waste pharmaceuticals is known to be harmful to health, treatment and recycling in many contexts (compared while the abundance of antimicrobials in the to dumping), this phenomenon also reflects physical environment and in organisms is known to foster and investment constraints, including a lack of access microbial resistance to the life-saving drugs on which to space. Small farms—perhaps because they are less humans and animals rely. One study showed that 33 likely to attract regulatory scrutiny and also have less to 47 percent of E. coli isolated from colibacillosis in access to technologies and finance—dump a larger pigs was resistant to antibiotics such as enrofloxacin, share of their wastes than their large, commercial ciprofloxacin, norfloxacin, and erythromycin (Khanh counterparts (estimates are 40 percent compared to 2010). Another study found 80 percent of isolated E. 16 percent). coli and 77 percent of Salmonella spp. to be resistant to at least one type of antibiotic, and over 60 percent Meanwhile, even though the majority of these bacteria were resistant to two or more types (approximately 64 percent) of livestock waste of antibiotics (Phương et al. 2008 in Dinh 2017). Yet undergoes some form of treatment in Vietnam, another study—this time on E. coli from the fecal much of it remains inadequately handled. For samples of children living in a rural area outside of instance, biodigesters have penetrated the industry to Hanoi—found 60 percent of the bacterial isolates to a large extent in Vietnam, propelled by government be resistant to three or more antibiotics (Dyar et al. subsidies, and are helping to lessen climate and organic 2012). Recognizing this threat, MARD (as of 2016) pollutants from animal wastes. However, the effluents initiated regulatory action to reduce the use of growth- from these digesters are often dumped untreated, thus promoting antibiotics in feed.9 carrying organic matter, nutrients, drugs, and feed additives like heavy metals into waterways and the Wastewater from livestock farms is among the major environment. And while the application of livestock causes of drinking water pollution affecting city waste to soils as a form of fertilizer mitigates certain dwellers, according to the Department of Natural pollution problems by spreading the manure (thus Resources and Environment of Ho Chi Minh City. spatially diffusing nutrient runoff), building soil After being discharged into canals, wastewater flows organic matter that helps nutrient retention, and into the Saigon River, which is the main source of reducing methane emissions related to decomposition, water supply for drinking and domestic uses in the 7 Estimated in Dinh 2017. 8 Treatment plants in the United States have been found to remove only around half of the drugs present in wastewater (Arvai et al. 2014). 9 http://law.omard.gov.vn/LinkClick.aspx?fileticket=YJI55G8ZKWE%3d&tabid=40&mid=385 (in Vietnamese); http://gain.fas.usda.gov/Recent%20 GAIN%20Publications/MARD%20phases%20out%20of%20growth%20promotion%20usage%20of%20antibiotics%20in%20feed_Hanoi_ Vietnam_7-6-2016.pdf (summary in English). Findings 7 city. Livestock waste has now been included in the list gives rise to emissions of methane and nitrous oxide, of pollution sources that require tight control by the both powerful greenhouse gases, especially when public authority to protect water quality in the Dong the concentration of wastes leads to their anaerobic Nai-Saigon river system. decomposition. The subsector’s climate footprint is much larger, moreover, once emissions related to Despite reason for concern, few studies examine flatulence of ruminant animals and respiration of all the water, health, and other impacts of livestock animals are factored in. Farm-level, fertilizer-related wastes, leaving this critical problem for the media emissions from the production of crops that are fed to document. Often, news reports are spurred by to industrially raised animals can also be attributed to residents’ complaints about the noisome odors arising livestock farming, though this does not appear in the from clustered livestock farms, rather than more charts below (see discussion on maize below). pernicious yet less visible pollutants, such as nutrients, heavy metals, bacteria, and viruses. There is preliminary evidence that the maintenance Aquaculture sector of poor sanitary conditions that (needlessly) worsen pollution problems are also harmful to The rapid development of aquaculture in Vietnam farm productivity. Poor sanitary conditions make over the last 15 years—especially the spread of farms that much more susceptible to suffering from intensive Pangasius and shrimp monocultures in productivity losses linked to self-contamination. the Mekong Delta—has given rise to increasing Evidence is preliminary, yet project-level interventions water pollution problems, outpacing regulators’ to improve the sanitary conditions and waste capacity to manage the sector’s externalities. management practices of livestock farms have already The value of aquaculture, which is dominated by achieved clear results in terms of productivity. For the farming of freshwater Pangasius and brackish example, by introducing “good animal husbandry” water shrimp (in output terms10), increased six-fold practices, the World Bank-supported Livestock between 1995 and 2014, while that of all fisheries Competitiveness and Food Safety Project reduced rates (aquaculture and capture) increased two-and-a-half of pig mortality from 15 to 11 percent, and poultry times (based on GSO data). Strongly encouraged by mortality from 41 to 33 percent in targeted areas. It the state, the industry’s expansion has been possible also reduced fattening times from 136 to 118 days for both through the large-scale conversion of natural pigs and from 66 to 58 days for poultry (reducing the ecosystems, including mangroves,11 and through amount of feed and other inputs needed to raise the intensification. Between 1995 and 2014, aquaculture farm animals, along with volumes of waste generated) production increased nearly eight-fold (in terms of (LIFSAP 2015). tonnage), while the area devoted to aquatic farming more than doubled.12 As of 2014, the Mekong Delta Separately, the raising of livestock is a major housed an estimated 5,500 hectares of Pangasius source of climate pollution in Vietnam, and farms and 604,000 hectares of intensive shrimp manure management the fastest-growing source of farms (Phuong et al. 2015 in Nguyen C. V. 2017), agricultural greenhouse gases,  though energy and and as noted, accounted for upward of 70 percent rice production are still larger sources (see Figure 6 of national aquaculture production overall (by area and Figure 7). The decomposition of animal wastes and tonnage).13 Most of these farming operations are 10 Shrimp farming occupies a much larger area than Pangasius farming does. More than 70 percent of all area devoted to aquaculture is occupied by shrimp farms. However, Pangasius accounts for around half of aquaculture output by weight (http://pubs.iclarm.net/resource_centre/WF_2776.pdf ). 11 According to data from Sa and Hanh (2008), total mangrove area in the Mekong Delta in 1983 was about 126,000 hectares in 1983 (mainly natural forests), 93,000 hectares in 1988, 78,000 hectares in 1992, and 27,000 hectares in 1999. This resulted from uncontrolled wood extraction and the expansion of rice and shrimp farming. 12 Based on GSO data for fish and shrimp production in 2014. 13 Based on GSO data for fish and shrimp production in 2014. 8 An Overview of Agricultural Pollution in Vietnam: Summary Report intensive and semi-intensive monocultures, and the some cases, sediment is collected in sedimentation pollution problems they give rise to are broadly due ponds, but even then, the sludge that accumulates in to the excessive and improper use of inputs including ponds is often released into the environment without feed, water treatment chemicals, antibiotics, and further treatment (although it is often suitable for other drugs, and to the management of effluents. use as a crop fertilizer). Such practices continue These pollutants originate from a range of aquaculture even though, from a technical standpoint, viable production activities, or “subsystems,” including pond alternatives are available. This has been demonstrated construction, pond treatment, water intake, stocking, in intensive shrimp farms that have adopted (mostly) nursing, water exchange, sludge discharge, harvesting, closed-loop water recirculation systems, for example. and pond emptying (Anh et al. 2010a and 2010b). These systems require farmers to replenish only water lost to evaporation (on a weekly-to-monthly basis). Aquaculture pollution stems mainly from the While these can make business sense because they discharge of untreated wastewater into local prevent outside diseases from entering, and they help waterbodies. As of 2014, Pangasius farms are estimated farms meet the environmental performance standards to have generated more than 10 billion cubic meters of demanding markets, they require high upfront of wastewater containing 51,336 tons of nitrogen and investments. 16,070 tons of phosphorus (Nguyen C. V. 2017). The vast majority of these pollutants were discharged to Several other factors help explain why improper local canals and eventually to the Mekong Delta river wastewater and sludge management remain system, without prior treatment, despite the fact that widespread in shrimp and Pangasius farming. For most rural households depend on these surface waters example, because land suitable for Pangasius farming for drinking and other domestic uses. Estimates of in the Mekong Delta is very expensive, farmers try to water discharges related to shrimp farming are smaller. minimize the area devoted to waste treatment systems Intensive shrimp production generated an estimated such as sedimentation and wastewater treatment ponds. 4.4 billion cubic meters of wastewater, containing Meanwhile, although regulations are in place to limit 25,344 tons of nitrogen, and 6,336 tons of phosphorus water pollution, wastewater treatment is perceived by (Nguyen C. V. 2017). An estimated 75 percent of many farmers as an “encouraged practice” rather than these were discharged into local rivers in coastal areas a compulsory one. Indeed, MARD and MONRE of the Mekong Delta (Nguyen C. V. 2017). Looking regulations governing the treatment of wastewater ahead, continued growth in aquaculture production have not been strictly enforced. The multiplicity of could further increase pollutant loads if major standards emitted by different regulatory agencies improvements in technologies and practices are not has also reportedly been a cause of confusion, and realized. If Vietnam achieves the ambitious production perhaps even noncompliance. Market incentives have targets that the fisheries Master Plan of 2013 lays out seemingly done more to motivate farmers, and those for 2020, Pangasius production alone will increase by seeking certification under VietGAP, GLOBALG.A.P., more than 60 percent over 2014 levels—that is, by ASC, and eco-labels seem to demonstrate better 1.8 million tons—in large part in the Mekong Delta environmental management. region. In fact, demands of export markets have To protect fish from pond water contaminants, seemingly driven improvements in environmental aquaculture farmers commonly engage in frequent management since 2010. In particular, NGOs and water exchange (up to daily), flushing used waters authorities in importing countries have periodically from ponds and recharging them with freshwater. raised environmental concerns with Vietnam’s As a result, the vast majority of the nutrients and Pangasius supply chain (relating, among others, to additives found in feed are being released, in most the management of nutrients, drugs, and pesticides, cases without treatment, to pollute surface waters. In and to the protection of wild species), a situation that Findings 9 has potentially harmed Pangasius exports at times.14 formalin/formaldehyde, potassium permanganate, Though claims made about the sustainability of saponin, potassium thiosulfate, benzalkonium Pangasius production have been disputed—and in chloride, iodophores, copper sulfate, humic acid, some cases corrected on the basis of inadequate data— and the highly toxic dichlorvos and endosulfan in the controversies they have generated seem to have the case of shrimp) (Nguyen, T. Q. 2015; Tu et al. stimulated efforts to improve both environmental 2006). Though dichlorvos and endosulfan are not regulation as well as environmental management. among the most commonly used chemicals in shrimp As a result, a growing number of intensive Pangasius production (less than 4 percent of farms report using farms have improved their wastewater and other them) (Tu et al. 2006), these two chemicals are management practices to gain access to export markets both highly toxic and are problematic even in small that require certification under such standards as quantities. Endosulfan, in particular, is a persistent GLOBALG.A.P. and Aquaculture Stewardship organochoride pesticide that is listed for elimination Council (ASC). Notwithstanding progress in the under the Stockholm Convention on Persistent Pangasius value chain, however, and more generally Organic Pollutants15 and has been banned from use among farms participating in upgrade projects, unclear in Vietnam (Hoi, Mol, and Oosterveer et al. 2013). environmental standards—with different agencies Various studies have confirmed that pathogens found issuing different standards (see below)—together with in aquacultural products and waters have developed a lack of regulatory scrutiny, economic incentives, and resistance to one or multiple antibiotics used by the technical, financial, and spatial capacity (especially in industry (Thi, Dung, and Hiep 2014; Huynh, Tran, the case of smallholders) broadly perpetuate polluting and Nguyen 2015). aquaculture practices. Some measurements indicate that acute water Under “status quo” practices, the waters and pollution, overall, remains a localized phenomenon, sludge that are released untreated are laden with but better measurement is needed. According to the nutrients, drugs, and chemicals. Pangasius farming Mekong River Commission, most of the Mekong in the Mekong Delta today is characterized by high Delta’s surface waters still broadly meet water quality stocking density and high feeding rates. Around 2 to guidelines for nutrients, organic waste, and acidity 3 kilograms of feed are needed for every pound of fish, (with reference to its Guidelines for the Protection of and around half of that feed is lost to pond waters Human Health and Aquatic Life) (MRC 2014). These either in the form of excrement or feed (De Silva et measurements also indicate that water pollution is al. 2010; Nguyen C. V. 2017). These levels of feed- acute in certain areas, however, and studies confirm use efficiency reflect the widespread use of low-quality that certain surface waters are “dramatically degraded” commercial feeds, though higher-quality feed does not (these are not specific to aquaculture) (Chea, preclude losses. Both Pangasius and shrimp farmers Grenouillet, and Lek 2016). However, these water also report the systematic use of multiple antibiotics quality measurements remain sparse and incomplete, (especially enrofloxacin, amoxicillin, trimethoprim, and do not tell a complete story on aquaculture’s—or and sulfamethoxazole), supplements (such as vitamins agriculture’s—physical impacts on the environment, and digestion aides), and a host of chemicals (lime, or on human and animal health. They provide no iodine, copper sulfate, BKC, salt, ivermectin, reading on water contamination with agrochemicals praziquantel, chlorine, cloramin T, and Zeo-yuca in the and drugs, for instance, or their ecological and health case of Pangasius; calcium hypochlorite, trichlorofon, ramifications. 14 In 2010, notably, the World Wide Fund for Nature (WWF) briefly included Vietnamese Pangasius on its red list of seafood products to avoid before moving it to its yellow list after conceding to having based its assessment on inadequate data. The European Union (EU) and WWF subsequently engaged with the Government of Vietnam to improve the regulatory framework and support Pangasius suppliers in moving toward certification, among other things (Cosslett and Cosslett 2013). Such controversies have continued to play out, as recently as in 2017. Other sources: http://english.thesaigontimes.vn/14259/WWF-Vietnam- Remove-Vietnam-catfish-from-red-list.html; http://www.switch-asia.eu/projects/pangasius-supply-chain-in-vietnam/; https://www.undercurrentnews. com/2017/02/10/vietnams-pangasius-industry-decries-fake-news-around-food-safety-scare/; https://www.undercurrentnews.com/2017/02/01/carrefour- ceases-sales-of-pangasius-in-spain/. 15 http://chm.pops.int/TheConvention/ThePOPs/ListingofPOPs 10 An Overview of Agricultural Pollution in Vietnam: Summary Report These measurements also fail to capture several Rejection of Vietnam’s fish and Table 1.  other forms of pollution. For example, aquaculture, fishery products from its main export markets, 2002–2010 and shrimp farming in particular, have been likely contributors to the drawing down of groundwater Market Value of Vietnam’s Period rejections rank at unsustainable rates, leading to land subsidence (US$ million) and saline intrusion, especially in coastal areas of the United States 73.0 #2 (after China) 2002–2010 Mekong Delta (Erban, Gorelick, and Zebker 2014; Japan 17.6 #1 2006–2010 Vuong, Lam, and Van 2015). The unsustainable European Union 14.3 #2 (after Indonesia) 2004–2010 Australia 3.6 #2 (after China) 2003–2010 drawdown of groundwater resources by various Total 108.5 #1 users also poses a risk in relation to future freshwater Source: Based on UNIDO 2015. availability for aquaculture and other activities. Separately, the measurement of greenhouse gas emissions from aquaculture remains at an early stage. Vietnam’s food product rejection rate Figure 2.  compared, 2002–2010 Food safety concerns linked to pollution have Relative Rejection Rate Indicator (RRRI) – all food products also been costly for the industry due to rejected 10 – product, and possibly due to lost sales and discounted prices—although estimates of the latter 5– are unavailable. The contamination of aquaculture products poses a food safety issue that is only partially VNM understood, yet Vietnam’s image as an exporter of VNM VNM VNM 0– quality has likely been blemished by export market incidents. Vietnam’s exports are much more closely scrutinized than products destined for domestic -5 – markets; and trade rejections linked to the detection of Australia European Union Japan United States RRRI low, first tercile RRRI medium, second tercile RRRI high, third tercile excessive levels of veterinary drugs or pathogens have ▬▬Median ▬▬5th and 95th percentile Outliers been persistent in sales to Japan, the EU, Australia, Source: UNIDO (United Nations Industrial Development Organization). 2012. https://www. unido.org/fileadmin/user_media_upgrade/Resources/Publications/TCB_Resource_Guide/ and the United States.16 In fact, the aggregate value TSCR_2015_final.pdf. of Vietnam’s fish and fish product rejections by the Note: RRRI = ratio of a country’s share of total rejections in one market to its share of total imports into this market for the entire period (2002–2010 in this case). United States, Japan, the EU, and Australia exceeded that of any other country during 2002–2010 (see they undergo less scrutiny, aquaculture products that Table 1). Vietnam’s food rejection rate, relative to are sold on domestic markets are most likely less safe the value of its food exports, ranged from high to to consume than those headed for export. medium compared to that of other countries (see Figure 2).17 In recent years, countries including Japan and Australia have threatened to interrupt certain aquaculture imports from Vietnam due to food Crops sector safety concerns (Nguyen C. V. 2017). The potential lowering effect of food safety concerns on the price Agro-input pollution has increased dramatically commanded by Vietnamese food exports has not been in Vietnam over the last two decades together with studied empirically, however. Meanwhile, because the expansion and intensification of crop farming. 16 Antibiotic residues were the leading cause of Vietnam’s crustacean product exports being rejected from the European Union (EU) in the decade spanning 2007–2017, followed by the presence of pathogens (based on an EU Rapid Alert System for Food and Feed query for January 2007 to April 2017 (https:// webgate.ec.europa.eu/rasff-window/portal/?event=searchResultList). The same applies to Vietnam’s overall agro-food exports: around 27 percent of agro-food rejection cases were due to antibiotic residues, and 23 percent were due to bacterial contamination during 2002–2010 (based on UNIDO 2015). Looking across markets, the presence of veterinary drugs accounted for 11 percent of the number of Vietnamese agro-food product rejections from the EU, the United States, and Japan during 2002–2010 (Tran et al. 2013; World Bank 2017). 17 Seafood product rejections dominated food export rejections. Findings 11 Crop output rose sharply during this period both as a •• Vietnamese pesticide use is estimated to have result of crop production’s expansion in space and its increased around three- to five-fold in the space intensification (see Figure 3). The area harvested for of roughly 25 years, with imports of pesticide food crops grew nearly 23 percent between 1995 and active ingredients having gone from 20,000 2014, by which time it stood at nearly 9 million hectares to 30,000 tons per year during the 1990s to (based on GSO data in Nguyen T. H. 2017). Whereas nearly 100,000 tons around 2015 (Lien T. 2015; there has been a significant increase in land devoted Khanh and Thanh 2010; and Truong Q. T. 2015 to maize, cassava, coffee, and rubber since the 1990s, in Nguyen T. H. 2017).19 The level of active the area devoted to rice paddy has increased more ingredient per hectare, likewise, probably tripled, moderately, and most recently has begun to decline on average, over this period (Lien T. 2015; (based on GSO data in Nguyen T. H. 2017). As for Khanh and Thanh 2010; and Truong Q. T. 2015 intensification, it has been possible through increased in Nguyen T. H. 2017). reliance on irrigation, agrochemicals, and improved seed (and to a lesser extent on mechanization). An orientation toward output growth has likely contributed to farms’ heavy and often profligate •• Between 1983 and 2013, fertilizer consumption use of agrochemicals. Today, it is the policy of the increased nearly seven-fold to a peak of Vietnamese government to support a reduction in the 26 million tons in 2013 (based on FAO data).18 area under rice and coffee production, compensated Approximately two-thirds of fertilizer is used by continued intensification and the diversification of for rice; other significant uses (between 5 and agricultural activities. Its focus has only recently started 10 percent of the national total) are for maize, to shift away from production to focus more on quality, coffee, and rubber (multiple sources in Nguyen value addition, and sustainability, however. Over most T. H. 2017). Growth in fertilizer use has generally of the past two decades, the state has pushed the sector slowed since 2004 (when it reached 25 million to meet ambitious production targets through both tons), and fertilizer use even declined for a few intensification and spatial expansion, with limited years during that decade. regard for their environmental consequences. Mekong farmers’ ability to shift from one to two and sometimes three rice crops per year in the space of a few years Trends in cereals production, yield, Figure 3.  Farm size distribution, 2001–2011 Figure 4.  and harvested areas, 1961–2013 Index, 1961 = 100 Percent 600 – 2001 2011 500 – 5 35 26 6 400 – 28 300 – 200 – 25 100 – 34 0– 41 1961 1966 1971 1976 1981 1986 1991 1996 2001 2006 2011 ▬▬Area harvested ▬▬Yield ▬▬Production Farm=<0.2 ha 0.2=2 Source: Based on FAOSTAT data. Source: GSO census 2001 and 2011 in Jaffee et al. 2016. Note: Increases in harvested area sometimes reflect the more intensive use of farmland to grow more crops per year rather than a spatial expansion of farming. China: mainland. 18 In nitrogen, phosphorus and potassium nutrient terms. 19 In active ingredient terms. 12 An Overview of Agricultural Pollution in Vietnam: Summary Report (World Bank 2012), for example, is emblematic of the mid-2000s, some consolidation of production has what Vietnam’s environmental risk-taking has made occurred, with 3- to 10-hectare farms accounting for possible. In this case, it has been based on the embrace a growing share of output (Havemann et al. 2015). of intensive monocultures supported by investments This modest pace of consolidation has possibly had in closed dyke systems coupled with the use of implications for pollution and pollution control. synthetic fertilizers (needed in part to palliate the loss Smallholders may be more prone to overusing inputs of alluvium), and chemical pesticides (needed in part (with less capacity and incentive to be more precise because of the increased vulnerability of monocultures in their use of chemicals).22 The fact that there are to pests). In the case of coffee, output expansion has large numbers of them—and that collective action not only relied on heavy fertilizer and irrigation, but institutions happen to be weak in Vietnam’s farm also partly on the tree-crop’s expansion onto unsuitable sector—also increases the challenge of policing or land.20 This legacy has no doubt contributed to the achieving behavioral change in the sector. present situation in which the majority of farmers are using more inputs than are required, not only at their The problem of fertilizer overuse is particularly own expense in terms of profitability and personal acute in Mekong Delta rice farming, and in Central health, but also at the expense of the environment and Highlands coffee production.23 A majority of both public health. rice and coffee farmers apply fertilizer at rates that largely exceed the levels recommended to maximize Meanwhile, the continued dominance of small either yields or profits. In rice farming, for example, farm size—even as farming has intensified—has most farmers have been found to apply fertilizers also potentially exacerbated pollution from crop about 20 to 30 percent above the recommended farming. As in much of the region, intensification levels (based on 2014 Mekong Delta Development has not been accompanied by an increase in average Research Institute [MDI] surveys in Kien Giang and farm size, and even where some consolidation has An Giang Provinces 2014 cited in Nguyen T. H. begun, farm size remains small (see Figure 4). Some 2017). At around 180 kg of nutrients24 per hectare of consolidation, for example, has occurred in Mekong harvested paddy during 2010–2011, the application rice and to some degree in Central Highlands coffee rate in Vietnam was about 30 percent less than it was cultivation (see Jaffee et al. 2016; Havemann et al. in Japan, China, or Malaysia (26 to 33 percent), but 2015). Even in these cases, however, the average farm 50 percent higher than it was in Indonesia, and over remains small. The average farm size for rice is just 200 percent higher than in it was in the Philippines over 1 hectare in the Mekong Delta, yet approximately and Thailand (see Figure 5). In coffee farms, nitrogen 0.2 hectares in the Red River Delta (based on GSO application rates have been found to exceed levels 2012 data in Nguyen T. H. 2017). Medium- and recommended by agricultural extension services by large-scale production is still rare, although efforts are 50 percent, and phosphorus by 210 percent. being made to cluster the rice plots of 30 to 50 farmers at a time and to jointly operate them as a commercial Many factors contribute to fertilizer’s often wasteful farm in what is known as the “small farmer, large field” and imbalanced use. Reasons for fertilizer overuse model.21 A large majority of Vietnam’s 640,000 coffee include its ease of use and wide availability at partly farmers have plantings below 1 hectare, although since subsidized prices—domestically produced fertilizers 20 In the Central Highlands, which produces the vast majority of Vietnamese coffee, satellite imagery from 2014 showed that the actual planted area was more than 25 percent larger than what official statistics recorded in 2010. And in Dak Lak province, specifically, 19 percent of the planted area—or 41,500 out of 221,000 hectares—was mapped as land deemed either unsuitable or marginally suitable for coffee (based on data from NIAPP 2014 in Havemann et al. 2015). 21 Actively promoted by Vietnam’s Departments of Agriculture and Rural Development (DARDs), the model supports groups of 25 to 100 neighboring farms that manage their land as though it were a single, medium-scale farm, without farmers giving up their land rights. Farmers break down the low walls between their plots, prepare the land together, manage water jointly, and plant the same crop varieties. DARDs have intervened, for example, by encouraging farmers to form groups, facilitating contracts between such groups and rice millers, and financing or providing land-leveling, advisory, and other services. 22 See, for example, evidence from China and Indonesia in Sun et al. 2012; Ju et al. 2016; Zhou et al. 2010; and Osorio et al. 2011. 23 Fertilization practices have been less closely studied in maize systems. 24 Nitrogen, phosphorus, and potassium. Findings 13 Figure 5.  Fertilizer application rates on rice the use of pesticides has grown dramatically since paddy in selected Asian countries, imports were legalized in 1986 despite over a decade 2010–2011 of efforts to moderate this trend.27 Average pesticide Kg of N, P and K per ha of paddy use in Vietnam compares to levels seen in the United 300 – States and the EU on a per hectare basis (based on 250 – FAO data), but its use is highly concentrated in rice 200 – production. In rice systems, the use of pesticides is thought to have largely exceeded what was necessary 150 – to achieve observed levels of output growth (Bui, Vo, 100 – and Nguyen 2013, and Nguyen et al. 1999 in Nguyen T. H. 2017). 50 – 0– Part of the explanationis that only a minority MYS CHN IND VNM BGD IDN PHL THA of pesticide sellers, extension agents, and farmers Source: Based on International Fertilizer Industry Association data (fertilizer consumption) and FAOSTAT data (paddy harvested area). understand correct pesticide use,28 and efforts to promote integrated pest management (IPM) have benefit from subsidized energy and preferential tax fallen short of expectations. Farmers continue to rates—as well as diminished soil fertility,25 and the widely disregard guidelines on dosing, mixing, timing, influence of marketers, including extension agents and method of application. For illustration, one study in some cases. Waste also occurs because soil testing found that 50 to 60 percent of rice farmers were using remains rare in Vietnam, as does the custom-blending pesticides at rates that exceeded recommended levels of fertilizers to meet site-specific needs; and available because they believed that higher doses were more fertilizer is often of poor quality. Fertilizer losses are effective (Bui, Vo, and Nguyen 2013 in Nguyen T. H. often made worse by fertilizer’s manual, surface, and 2017). Another study found that 38 to 70 percent of poorly timed26 application (which make it prone to farmers in southern provinces were using pesticides runoff), and overirrigation (notably of coffee). The at rates exceeding recommended levels, with nearly overuse of fertilizer is also self-perpetuating, as ever 30 percent mixing many types of pesticides together at more fertilizer is used to palliate the detrimental effects the time of application despite this being a dissuaded that its overuse has on soils and their fertility. This is practice (Tran Thi Ngoc Lan et al. 2014). similar to how the abuse of pesticides begets ever more reliance on these chemicals to fend off the resurgence Farmers often also disregard guidelines on the of pest populations that have been aggressively but not disposal of used pesticide containers, or the handling judiciously managed. of application equipment—sometimes for lack of better options. Pesticide containers are routinely Pesticide overuse is also rampant in certain parts dumped, along with their chemical remnants, directly of Vietnam, where farms have quickly gone from into fields, canals, and streams, as in both the Mekong minimal pesticide use to relatively high levels and Red River Deltas (Pham et al. 2012). One study (compared to recommended ones), with concerns found more than 70 percent of farmers in the Mekong though about overuse pertaining especially to rice,  Delta to be dumping pesticide packaging into canals even higher levels are used in vegetable farming on or rice fields; only around 17 percent of farmers were average (Anh 2002 in Pham et al. 2012). As noted, reported to collect the containers and either bury them 25 Including in connection to the already noted loss of soil alluvium caused by dykes; and potentially in connection to the use of marginal land, the continuous mining of soil by intensive farming activities, and soil acidification also resulting from them. 26 Its timing in relation to rain or irrigation. 27 Under collective agriculture, the government supplied pesticides at subsidized prices and recommended spraying on a calendar basis, with little or no attention to field conditions (Pincus 1995 and Chung and Dung 2002 in Dasgupta et al. 2007). 28 Also see the results of a 2015 survey by the Research Center for Rural Development and others; http://library.ipamglobal.org/jspui/bitstream/ipamlibrary/818/1/ Knowledge-Attitude-and-Practice-KAP.pdf. 14 An Overview of Agricultural Pollution in Vietnam: Summary Report or sell them for recycling (Toan 2013). Approximately although the cost of these rejections and their effects 90 percent of farmers said they washed their sprayers on the industry’s reputation and sales have not been right away at the rice fields, canals, ponds, or rivers fully analyzed. (Toan 2013). It is unclear, meanwhile, that any recycling of pesticide packaging is desirable given the A concern that is parallel to the excessive and lack of infrastructure to properly collect and recycle improper use of pesticides in Vietnam is the what in 2015 was recognized as a form of hazardous toxicity of the pesticide mix. A survey of farmers in waste (implying that recycling it is not even legal). the Red River Delta, for example, found that nearly one out of three pesticides used by farmers belonged All these practices not only result in suboptimal to the category of pesticides that the World Health pest control leading to more pesticide use (brown Organization deems “extremely or highly hazardous” hopper outbreaks have been attributed to pesticide (Category I) (Pham et al. 2012). These included abuses, for example), but also increase unnecessary organophosphates, organocholrines, pyrethroids, exposure of wildlife and people to pesticides. By and carbamates, among others. In addition, several some accounts, intensively farmed rice fields have, banned or unregistered pesticides (such as methyl by some accounts, become dead zones, devoid of the parathion, methamidophos, and carbofuran) were snails, frogs, fish, mice, and other creatures that once found to be in use—though the percentage was inhabited them.29 One study in the Mekong Delta, declining. In general, it is reported that Vietnamese for example, found certain surface waters so polluted farmers have a tendency to use older, less expensive, with pesticides that they were not suitable for farming nonpatented pesticides that can be manufactured or activities (UNU-EHS 2010). Pesticide runoff has blended domestically, and that happen to be more been known to adversely affect river-based fisheries, toxic and persistent than others (Pham et al. 2012). although the extent and economic costs of this are An inspection of pesticide traders, vendors, and not well-known. Groundwater accessed through wells farmers carried out by MARD in 2010–2011 revealed has also been found to contain pesticide residues that around 20 percent farmers were using pesticides exceeding safe drinking water standards (Lamers et in violation of applicable regulations (using illegally al. 2011). This is especially harmful to farmers and imported, banned, and even fake pesticides) (Nguyen rural communities, which suffer disproportionately T. H. 201731). The continued use of banned pesticides from pesticide poisonings and potentially related is partly attributable to their relatively low prices (itself cancers (Dasgupta et al. 2007). However, it also aided by price competition32), and at least partly to affects consumers more widely because crops are their efficacy (due to their toxicity to a broad spectrum often harvested too soon after pesticide applications, of pests). In addition, the enforcement and control of resulting in unsafe levels on produce (Hoai et al. hazardous chemical use has generally been weak (Hoi 2011), and a dozen pesticides have been detected at et al. 2016). rates that exceed drinking water standards in ground-, surface, well, rain, and bottled water (Nguyen, C. G. The situation of fertilizer and pesticide overuse D. et al. 2015; Lamers et al. 2011; Toan et al. 2013). has the potential to be remedied. Pilot programs Concerning levels of pesticides have also been found and field studies have demonstrated that significant in fish samples (Hoai et al. 2011). The detection of improvements in the use of agrochemicals are possible excessive pesticide residues on plant products has also with the right practices—and can yield farmers led to trade rejections and disrupted trade flows,30 significant savings. For example, Vietnamese rice 29 One study found that pesticides to be harming the growth and survival of climbing perch (a fish) in Mekong Delta rice fields in 2007 (Nguyen T. T. 2016). 30 See, for example, the suspension of Vietnamese rice exports to the United States due to pesticide violations in 2016; http://e.vnexpress.net/news/business/ vietnam-suspends-rice-exports-to-us-after-pesticide-violations-3476874.html. Pesticide-related rejections of fruits and vegetable exports have, however, been dwarfed by rejections related to microbiological contamination (UNIDO 2015). 31 Also see reports on smuggled pesticides; http://infonet.vn/80-thuoc-bao-ve-thuc-vat-nhap-tu-trung-quoc-post153761.info. 32 See Truong Quoc Tung 2015. Findings 15 farmers participating in the “1 Must and 5 Reductions”33 this practice suggest the need for caution in making program in the Mekong Delta were able to reduce this assessment.34 their production costs by 18 to 25 percent per hectare of harvested crop without sacrificing yields (Nguyen The burning of agricultural residues emits T. H. et al. 2015). Whether they are related to low pollutants that pose a significant health hazard and awareness and technical capacity, a lack of access to may contribute to short-term climate warming. better technology, labor constraints, or other factors, Emissions include sulfur dioxide (SO2), nitrogen the impediments to scaling up this program merit oxides (NOX), carbon monoxide (CO), black carbon further investigation. Similarly, Technoserve (2013) (BC), organic carbon (OC), methane (CH4), carbon estimated that farmers’ incomes could increase by dioxide (CO2) volatile organic compounds (VOC), around 30 percent (from a base of US$1,500 per year, nonmethane hydrocarbons (NMHC), ozone (O3), at 2013 coffee prices) as a result of lower pumping and aerosols, and others (Tripathi, Singh, and Sharma fertilizer expenditures, and higher yields. However, 2013). these have been insufficient or underestimated by farmers—or perhaps too long term—to inspire Separately, agriculture is the second-largest change. contributor to overall greenhouse gas emissions in Vietnam, and rice production the leading source of Another significant pollution concern is the agricultural emissions. Rice’s footprint is all the more burning of crop residues such as straw and husks. significant if its fertilizer-related emissions are factored Studies on this phenomenon have shown burning to be in alongside those generated by the decomposition widely practiced, including by rice, coffee, and maize of organic matter in paddy fields’ standing waters farmers. One found that up to 98 percent of surveyed (which emit nitrous oxide and methane, both farmers in the Mekong Delta burned straw after the powerful greenhouse gases) (see Figure 6). Fertilizer winter-spring season, 90 percent burned it after the use, meanwhile, has been the second-fastest-growing summer-autumn season, and 54 percent burned it source of agricultural greenhouse gas emissions behind after the autumn-winter season (Tran Sy Nam et al. manure management35 (see “agricultural soils” in Figure 2014). Burning crop residues has been a common 7). As with fertilizers and pesticides, farmers stand to practice to eliminate wastes after harvesting because it privately benefit in many cases from the application is an inexpensive and quick way to prepare land for the of rice farming practices proven to mitigate pollution next crop. Certain provincial arms of MARD (such as levels. This calls for reaching a deeper understanding the Dong Thap DARD in An Giang) have reported of the incentive structures and other factors that may some decrease in rice straw burning since 2015, which be holding back their much wider adoption. they have attributed to increases in the market price of rice straw and the availability of equipment to collect and process it. The claim that burning has declined remains anecdotal, however, and there is no evidence of sustained and wider change. The challenges that China has encountered in fully controlling burning despite its well-resourced efforts to enforce bans on 33 Developed by the International Rice Research Institute in collaboration with the An Giang Department of Agriculture and Rural Development, “1 Must Do and 5 Reductions,” or 1M5R, calls for farmers to use certified seeds (the “1 must”), while reducing the use of four production inputs (seed, water, pesticides, and chemical fertilizers) and postharvest losses (the “5 reductions”). This estimate is based on the piloting of the 1M5R package in the Mekong Delta’s Kien Giang and An Giang provinces through 9 cropping seasons during 2012–2014. The study finds that 1M5R could potentially save farmers US$1.4 billion per year, assuming 4 million hectares of double-cropped rice. 34 That said, the rates of residue burning are comparatively low in China, estimated at less than 24 percent in 2013, compared to 54 percent to 98 percent in Vietnam, depending on the season (Gao et al. forthcoming; Tran Sy Nam et al. 2014). 35 Based on data reported to the United Nations Framework Convention on Climate Change (UNFCCC) for 1994 and 2010; https://unfccc.int/files/ghg_data/ ghg_data_unfccc/ghg_profiles/application/pdf/vnm_ghg_profile.pdf. 16 An Overview of Agricultural Pollution in Vietnam: Summary Report Breakdown of agricultural GHG Figure 6.  Increases in Vietnam’s reported Figure 7.  emissions in Vietnam, 2014 estimates agricultural GHG emissions, 1994– 2010 Percent Rice cultivation 500 – 30% Other 6% 400 – 300 – 200 – Livestock 25% 100 – 0– Synthetic fertilizer Manure Agricultural Rice Enteric Field burning of 33% management soils cultivation fermentation agri. residues Source: Based on FAOSTAT data. Source: Based on emissions data reported to the UNFCCC (https://unfccc.int/files/ghg_data/ Note: Nitrous oxide and methane. Livestock emissions include those from enteric fermentation ghg_data_unfccc/ghg_profiles/application/pdf/vnm_ghg_profile.pdf). and manure management. Other emissions include those from crop residue and soil management (nonburning), and burning. Public sector action to date included directives and circulars on antibiotics use and toxic substance residues in animal agriculture, and food There appears to have been a turning point in safety; on the (reorganized) roles and responsibilities recent years with respect to government action on of province-level authorities (DARDs); on pesticide agricultural pollution control. As noted, MARD’s product management; good agricultural practices; 2013 Agricultural Restructuring Plan reflected biogas; and more. Previously, agricultural activities growing recognition of the agricultural pollution were generally subject to broader environmental and challenge and its ramifications by central and local food safety legislation—a less sector-specific set of laws government authorities. More recently, the legal with limited connection to one another.37 One notable framework for agricultural pollution prevention exception in this respect was the Law on Fisheries and control has been strengthened and much more of 2003, though its implementation proved largely tailored to the agricultural sector’s specific set of ineffective and is being revised as of 2017. In fact, challenges and realities. A turning point in Vietnam’s fisheries regulations have followed a similar pattern, agro-environmental policy seems to have been reached having begun to gain in specificity and enforceability in 2015 as several laws and implementing measures since 2013 (technical standards were issued in 2013, came into effect or were adopted (see Figure 8). These 2014, and 2015, to try to give it more force). included the Law on the Promulgation of Legal Documents (effective 2015), which among other The work of specifying and tailoring laws and things instructs various government bodies to develop regulations is ongoing, and some of it is starting legal documents pertaining to different aspects of agro- to be accompanied by public investments in environmental protection.36 Measures also included supportive infrastructure and capacity. At the time laws on environmental protection (effective 2015), of writing (2017), for example, MARD is in the plant protection and phytosanitary matters (effective process of preparing a new circular relating to the 2015), and veterinary matters (adopted 2015); as management of agricultural chemicals, residues, and well as a host of implementing measures. The latter wastes, in which it will reportedly be guided by the 36 For example, MARD’s crop protection agency was tasked with proposing and preparing circulars and directives relating to fertilizers and pesticides, and various entities within and outside of MARD were called upon to provide comments and contribute to this process. 37 These included laws that are still on the books such as the Law on Environmental Protection (2005), the Law on Water Resource Use and Management (2008), the Law of Biodiversity (2008), the Law on Food Safety (2010), the Law on Environmental Fees (2010), and the Land Law (2013). Findings 17 Figure 8.  Key legal measures pertaining to agro-environmental policy since 2004 Law on Environmental Protection Veterinary Law Law on Plant Protection and Phytosanitation Law on the Promulgation of Legislative Documents Directive on enhancing checks and controls on, Directive on enhancing the management of production, trading, and the use of antibiotics in livestock, and punishment of, the aquaculture and food safety illegal importation, trans- portation, trade, and use Circular on regulating the monitoring of toxic substance residues in livestock and marine animal products of illegally imported pesticides Circular on the responsibilities of the sub-departments and divisions within DARDs Circular on permissible Circulars and decisions on pesticide product management, good agricultural practices, antibiotics in livestock feed biogas, bio-materials, and others Law on Fisheries (under revision) Technical regulation on the environment Law on Fisheries and pollution control Decree stipulating the Law on Environmental functions, tasks, Protection (expired) powers, and Decree on prevention Decree on fertilizer of environmental pollution management organizational structure of Decree on animal feed MARD management and aquaculture 2004 2005 2010 2013 2014 2015 2016 2017 Year measures came into effect Laws Implementing measures Technical regulations and standards Note: See details on legal measures in a separate annex available online. The figure shows major legal provisions related to environmental protection that are in effect, focusing on those relevant to farm-level agricultural pollution. Years shown on timeline are when measures came into effect. DARD = Departments of Agriculture and Rural Development. MARD = Ministry of Agriculture and Rural Development. objectives of reconciling growth and environmental difficult to trace and measure, making it difficult to protection and improving coordination, enforceability, identify and fine (or take corrective action against) and accountability. Since 2016, MARD and MONRE polluters. This is especially true with limited have been collaborating to develop guidance on financial resources for monitoring and oversight, the handling and management of used pesticide limited staff, and limited technical expertise. For containers, and to “build capacity” (including technical example, MARD’s Plant Protection Department expertise and infrastructure) to eliminate highly toxic has about 4,000 staff, and there are on the order and persistent pesticides. In parallel, the Ministry of of 10 million pesticide-spraying farmers to Finance is financially supporting MARD in backing oversee. This means that each staff must monitor local authorities in intercepting and destroying banned about 2,500 farmers, on average, a task that pesticides and fining violators. with current technical resources and essentially no support from local authorities is reportedly While this ongoing flurry of legal action represents impossible (MARD 2016a). For similar reasons, a critical step toward gaining control over farm-level the government’s capacity to control the quality pollution, multiple implementation challenges of fertilizer remains limited, leaving it relatively remain, a  selection of which are discussed below. powerless to curtail the commercialization of fake and low-quality fertilizers. Furthermore, limited •• Monitoring and controlling nonpoint sources, resources are not always put to best use—and are especially with limited (human/technical and potentially spread thin—considering that there financial) resources that are sometimes spread may be overlap in the roles and responsibilities thin. Agricultural nonpoint source pollutants are of different parts of the administration, and that 18 An Overview of Agricultural Pollution in Vietnam: Summary Report there is often no coordination among different Song Cau, Nhue, Day, and Dong Nai, even government bodies. though they have been contaminated to the point of being unfit for domestic uses, and in some •• Unclear responsibilities and lack of cases even agricultural uses (such as irrigation and coordination. A lack of clarity and coordination aquaculture).38 Another illustrative consequence of roles and responsibilites has generally is that, barring consumer fatalities (if these can contributed to weak enforcement of laws even be retraced to their source), farmers face no and regulations—perhaps because overlap in legal consequences in connection with the use responsibilites gives rise to confusion and in turn of highly toxic and banned agrochemicals, or excuses not to comply; or because some aspects the potentially hazardous overuse (or misuse) of of the law slip through the cracks without any agrochemicals, more generally. agency taking responsibility. Until recently, for example, synthetic fertilizers were under the •• That said, the government seems to be purview of the Ministry of Industry and Trade, taking proactive steps to improve resource and natural fertilizers were under the purview of use and coordination, and to strengthen its MARD, leaving no one to oversee producers of monitoring and enforcement capacity— in both kinds of fertilizer. Agro-environmental roles part by making better use of human/technical and responsibilities are assigned to a range of and financial resources. In 2015, for example, departments within both MONRE and MARD, guidelines were issued by MARD and the yet coordination among them is lacking, as Ministry of Home Affairs (MHA) to clarify is clarity on where differences in these roles and streamline the agro-environmental roles and responsibilites lie (that is, how they relate and responsibilities of different administrative to each other). For example, within MARD entities of DARDs in order to remedy the alone, the Department of Crop Production, high level of fragmentation of agricultural Department of Livestock Production, and pollution control efforts at the provincial level. Department of Animal Health each have their MARD then merged and reorganized several own environmental management division; while administrative departments at the province level, multiple functional departments within the putting just one department in charge of crops, Directorate of Fisheries—which does not have a livestock, and aquaculture pollution oversight, dedicated environmental department—also have respectively.39 In 2016, MARD also took steps environmental management responsibilities. to mobilize local resources (human, financial, and material) and develop plans to strengthen Again, the key issue is lack of coordination. Until agro-environmental monitoring, with a focus on recently, roles and responsibilities have been intensively farmed parts of the country such as similarly disjointed or overlapping at the province the Mekong Delta. Priorities that have been set and local levels, a situation recognized as leading include reducing agrochemical use; increasing to ineffective oversight of agrochemicals and the treatment and recycling of agricultural agricultural residues and wastes, and resulting residues and wastes; increasing the adoption of in troublesome environmental outcomes. To “advanced” cultivation and crop management illustrate the consequences, no legal cases have techniques; eliminating the use of certain toxic been brought or penalties imposed in connection plant protection substances (that is, pesticides), with the pollution of various rivers such as the including by controlling the importation and sale 38 Their BOD5, COD, and TSS levels are several times the standards specified for “domestic water supply with appropriate treatment,” and some parts are above agricultural use standards (A1 and B1 standards specified in QCVN 08:2008), with sources of pollution including domestic and industrial sources. Agricultural sources are likely larger contributors to the contamination of the Tien and Hau Rivers, among others, in the Mekong Delta (Bao Anh 2016 [http://thanhtra.com.vn/xa-hoi/moi-truong/nguon-nuoc-song-ngay-cang-o-nhiem-nghiem-trong_t114c1143n101615]). 39 The measures in question were MHA/MARD Joint-circular No 14/2015/TTLB-BNNPTNT-BNV and MARD Circular No. 15/2015 / TT-BNNPTNT, with the latter providing more specific details on what was to change. Findings 19 of illegal and expired pesticides; and providing Moreover, they are often seen as vulnerable— guidance on the collection and treatment of used including to the effects of nonfarm pollution40— packages of agrochemicals and veterinary drugs. and lacking in capacity. And indeed, they The previously mentioned circular that MARD sometimes do lack the requisite financial capacity, is preparing also aims to improve coordination as physical space, or skills and expertise to adopt relates to agro-environmental policy. certain technologies or practices and meet certain standards. •• A lack of specificity or overlap in regulatory provisions has sometimes hampered •• Economic incentives and disincentives lack enforcement. In some cases, authorities have the power to persuade or dissuade farmers. found it challenging to demonstrate that Penalties for noncompliance with laws and violations have taken place, either for technical regulations—even when they are imposed reasons, or due to a lack of legal clarity when (see the problem of “unenforceability” under different guiding circulars are in place. In other the challenges of monitoring small farms cases, environmentally damaging practices—for and nonpoint sources, above)—are generally example, the use of electricity in fisheries—have inadequate (MARD 2016b). Meanwhile, the been a few steps ahead of regulatory provisions focus of government seems to have remained and not explicitly described or connected to a clear largely on policing and punishing bad practices course of corrective action. In some instances (even (for example, inspecting imported fertilizers where farm capacity is not at issue), authorities’ at borders, requiring the registration of ability to hold farms accountable has been agrochemicals being imported, sold, or produced complicated by duplicative regulations, leading domestically, punishing the production of fake to genuine confusion or perhaps undermining fertilizer, and threatening violators with weak the basis for their enforcement. Overlap in fines), rather than intervening preventively and aquaculture wastewater management standards using a broader array of economic incentives, issued by MARD and MONRE has reportedly including both “carrots” and “sticks,” to induce detracted from their adoption and enforcement behavior change. in the aquaculture industry. In some cases, it is the suitability of regulatory provisions that is at •• More structurally oriented measures aimed at stake, as when these are out of step with farms’ preventing pollution or its worst impacts have capacity—either to understand or to comply with remained the exception, and have seen limited them. Certain standards that are meant to govern results to date. In particular, MARD’s policy livestock production (specifically wastewater under the Livestock Subsector Restructuring management), for instance, are out of step with Program to redistribute “large-scale” commercial the realities of the large parts of the industry. livestock production in space—and specifically to move these operations away from dense •• Difficulty and reluctance of authorities to population centers and to less populated, enforce environmental laws and regulations “biosafety production areas” that are far from especially vis-à-vis small farmers, and inability residential areas—is an example of a measure of farms to comply. Although, aggregately, meant to shape the industry’s geographic layout small farmers contribute significantly to agro- and density.41 However, from this perspective, environmental pollution, their activities are, the industry has remained nearly stagnant. The as noted, difficult if not impossible to oversee. livestock subsector’s continued dominance by 40 Most recently in connection to several mass fish kills that have resulted from repeated and severe instances of industrial pollution of the Am River in Thanh Hoa and other provinces. 41 One of its targets, for instance, is to decrease the Red River Delta region’s share of national pig production from 26 percent to 15 percent by 2020, andthe Mekong Delta regions’ share from nearly 11 percent to 5 percent. 20 An Overview of Agricultural Pollution in Vietnam: Summary Report small farms (not explicitly targeted by the policy) has also not helped in this respect. In parallel to implementation challenges, it is possible that certain government policies have unintentionally and indirectly fueled polluting agricultural practices or activities. Possible examples of double-edged government intervention may include implicit fertilizer subsidies (through policies favorable to state-owned fertilizer companies), and investments in the construction of “protective” dykes (to mitigate flooding and enable more rice harvests per year, to the extent that they can have repercussions for soil fertility). Any fast-tracking of livestock farms or their licensing with little regard for environmental management plans and facilities would be another example of one policy objective (such as supporting livestock production capacity) being pursued at the expense of several others (human and environmental health).42 42 To illustrate a form of noncompliance that is often overlooked, concentrated livestock farms, such as those with over 100 pigs, are legally required to have a suitable waste treatment system, such as a biogas digester. Farms that size, however, lack a use or market outlet for the “large” quantity of energy such biodigesters generate, and have little incentive to invest in one, or to use it as designed. As a result, many farms either lack adequate waste management facilities, or release biogas and associated effluents directly into the environment, causing water and air or climate pollution. WAYS FORWARD Going forward, Vietnam can make important strides when it comes to fully incorporating sustainability considerations into the country’s agricultural intensification policies, strategies, and programs, and implementing them more effectively. This is not only a public health and ecological necessity (China’s situation warns of the potentially high costs of ineffective policy). Achieving higher product quality, food safety, and environmental performance will also be essential to sustain high levels of agricultural output and value addition, and to help Vietnam’s agricultural exports grow in relevance in the most demanding markets. The potential for gain has already been recognized in efforts to increase sales of higher-quality, branded rice, and to meet sustainable sourcing criteria sought by certain international companies, for example. Significant potential for improvement lies in the better application of Vietnam’s existing legal and regulatory framework for pollution control. For this, the state will need to intervene in ways that offer farmers better technical options, and also modify their incentives to encourage adoption and/or compliance. National good agricultural practices (GAPs) have already been developed in several domains and are ripe for scale-up. Further studies are needed to more deeply understand what constrains the adoption of these practices and to effectively direct resources to that end. At the same time, additional research and innovation efforts are needed across a range of domains to support the development or adaptation of new GAPs. Programs promoting and supporting their adoption need to be developed with full consideration for value chain realities and dynamics, and farmers’ economic incentives. Program-related messaging may also need adjustment. Often, farmers adopting GAPs do not receive higher prices for their produce, or only a very small premium. The main benefits for farmers typically lie elsewhere, in the forms of reduced input expenses and lower exposure of the farm households and their communities to chemicals and antibiotics. The state can develop more effective monitoring and enforcement programs to address agricultural pollution issues, especially on intensified commercial farms. These will be facilitated through greater cooperation among agencies including MARD/DARD, MONRE/DONRE, and food safety and health departments. Information disclosure schemes on the quality and environmental footprints of agricultural production also need to be developed to avoid unfounded public fear 22 An Overview of Agricultural Pollution in Vietnam: Summary Report and to foster market demand for products deriving in the context of national agricultural sector from sustainable agricultural practices. realities. This can also be done with respect to approaches used to implement and enforce legal Priorities going forward include: measures. 1. Enhancing awareness of agricultural pollution 7. Strengthening the enforcement of existing among the country’s policy makers, consumers, environmental laws and regulations,including affected communities, and producers by through investments in human capital and using a variety of methods, including school equipment, and the capacity and resources of curriculums, awareness days, site visits, event entities (public or community-based) with a role convening, crowd sourcing of solutions, and in oversight. public dissemination of monitoring results. 8. Developing and disseminating technical 2. Systematically considering the pollution guidance on context-relevant good and related implications of all public agricultural practices,including ones relating to policies, incentive schemes, investments, and input and “waste” management, for farmers and programs—across sectors—with influence service providers, and scaling up proven good over farming practices, compliance with agricultural practices using lessons learned farming-related regulations and standards, and from successful (and less successful) projects farming sector structure. and programs (such as VietGAP, 3G3R [3 gains 3 reductions], 1M5R, and private international 3. Incorporating agricultural pollution standards). This can be done, among other ways, assessments and mitigation plans into all future by developing programs that harness or magnify agricultural program budgeting and agricultural economic incentives for farmers (or farm service projects. providers) to adopt better practices. 4. Strengthening national and subnational 9. Funding more learning and research— capacity to systematically monitor agricultural including social science research—on pollution,perhaps initially focusing on some key pollution’s drivers and impacts, and on commodities or known agricultural pollution effective responsesto major pollution problems, “hotspots.” to support more evidence-based prioritization of public resources and the design and 5. Developing, in relation to agricultural implementation of responses. pollution “hotspots,” action plans  with time- bound steps and outcome goals. Plans can 10. Establishing formal processes to periodically be developed at different geographic scales, evaluate policy and program effectiveness, involving different levels of government, and building on emerging evidence generated by with the participation of affected producer and ongoing monitoring and pollution research, and community groups. 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