The CAP Health Check
BirdLife International is deeply disappointed with the recently concluded “CAP Health Check”. The EU Commission and Member States governments avoided any serious analysis about how the CAP is delivering against agreed EU policy objectives, one of which is to halt the decline of biodiversity by 2010, or whether it is responding to the expectations of EU citizens and delivering value for (taxpayers’) money. The result is an absence of significant improvement to the overall policy. The CAP will remain substantially unchanged until 2013. Minor tweaks have been introduced however, and Member States have now the responsibility to make the maximum use of these to try and bring at least marginal improvements before 2013.
From an environmental point of view, five priorities are of outstanding importance:
Ensure increased funding for rural development programmes
The proportion of the CAP budget directed to Pillar 2 (Rural Development measures), and its associated environmental measures, continues to be unjustifiably low despite the importance of Pillar 2 payments in delivering public goods that European citizens expect and need from farming. Though the Health Check proposed a modest progressive increases to the modulation rate to 13% in 2013 (as opposed to 20% initially proposed by the Commission in 2002), the final deal settled on a paltry 10%. While this represents a tiny shift of funds, and is only available in 13 of the EU 27 Member States, it could still be used to beef up at least some badly starved agri-environmet schemes. Member States that have this possibility must use it to target funds at addressing the environmental crises surrounding biodiversity, water stress and climate change that Europe is facing.
Ensure cross compliance delivers its current objectives and is strengthened, not weakened
Cross compliance is the system that is supposed to ensure that farmers receiving subsidies at least comply with environmental legislation and respect basic good practice. The Commission and Member States chose to ignore the heavy criticism levered on the implementation of cross compliance by the EU Court of Auditors in a special report whose publication has been delayed until just after the approval of the Health Check (http://caphealthcheck.eu/court-of-auditors-report-on-cross-compliance-is-damning/). Member States must urgently improve their Cross compliance rules, their controls and penalty systems and make use of the few tiny improvements brought by the Health Check.
- The meaning of ‘landscape elements’ protected under Good Agricultural and Environmental Condition (GAEC) has been better clarified, this should mean, for example, Member States will no longer be allowed to exclude from protection hedgerows or wetlands; however, protection of such elements is being misrepresented as a mitigation measure for set-aside loss.
- Nothing has been done to halt permanent grassland destruction. The current system allows a loss of 10% of ‘permanent pastures’ at national or regional level (which can mean almost complete loss in the most vulnerable areas), and also allows for the ‘offset’ of semi-natural biodiversity and carbon rich grasslands by a similar area of artificial grass cover on arable land. The ambiguity in the definition of ‘pasture’ and the allowance of offset severely undermines the stated objectives of the measures. This issue is of particular importance for many new Member States who contain a high proportion of High Nature Value grassland, grassland that is virtually impossible to restore once lost.
- A new welcomed obligation has been introduced to manage buffer strips next to watercourses. This is a positive measure in terms of water quality and soil erosion with positive impacts on biodiversity. However, no consistent approach of minimum area coverage of buffers and management prescriptions across Europe has been adopted. The risk is that Member States will interpret the rule in such a weak way as to make buffers virtually meaningless for the environment.
- To ensure the effectiveness of the cross compliance across Member States, the Commission needs to produce clear technical guidelines to assist Member States in the definition of their specific and locally tailored rules, particularly on Good Agricultural and Environmental Conditions (GAEC). The Commission must also ensure that Member States actually implement the rules.
Replace set aside with meaningful environmental measure
The previously mandatory set-aside scheme has been abolished under the Heath Check and although the Commission has openly acknowledged the values to wildlife and environmental benefits set-aside delivered, it has failed to offer a meaningful tool to ensure these benefits are not lost following its abolition. The introduction of mandatory buffer strips, even if correctly implemented, would be insufficient in terms of scope (in-field options are crucial for many bird species) and would not deliver anything like the scale of past set aside obligations (which were obligatory on every arable farm). BirdLife proposes a replacing the set-aside scheme with a comprehensive system of Environmental Priority Areas (EPA) across the farmed landscape, with a 10% of Utilised Agricultural Area managed for the environment. This is the only way to ensure the survival of biodiversity across Europe and to allow the ecological connectivity species will need in the face of changing climate. Although the Health check does not require Member States to do anything in this direction, it does allow countries to introduce such a system. Member States must show the courage to do the right thing.
Please click here for BirdLife's letter to EU Commissioner for the Environment Stavros Dimas on set-aside and related press release.
Use new funding mechanisms to target High Nature Value farming systems