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The European Commission’s draft proposal for the CAP Health Check is lacking in vision and glaringly fails to address the pressing environmental challenges facing Europe.
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Weak CAP Health Check proposal fails to stand up to environmental crises

29-02-2008

Brussels, February 29th 2008 – BirdLife International [1] regrets that the European Commission’s draft proposal for the Common Agricultural Policy (CAP) Health Check [2] - which was leaked to AGRA Facts [3] yesterday - is lacking in vision and ambition, caves in to the usual vested interests and glaringly fails to address the pressing environmental challenges facing Europe, from climate change to biodiversity loss and growing water shortages.

While the Commission’s green paper made ambitious promises to address these “new challenges” and bring the CAP into line with citizens’ expectations, the actual draft proposal fails to deliver and is clearly underpinned by a ‘business-as-usual’ approach (see detailed analysis in notes)[4].

The EU is facing a dramatic crisis over biodiversity and climate change, while the CAP is certain to come under close scrutiny during the EU Budget Review process; against this background, it is difficult to understand the approach proposed by the Commission. —Dr. Clairie Papazoglou, Director of the BirdLife European Division

Reacting to the leaked document, Dr. Clairie Papazoglou, Director of BirdLife European Division, said: “The EU is facing a dramatic crisis over biodiversity and climate change, while the CAP is certain to come under close scrutiny during the EU Budget Review process. Against this background, it is difficult to understand the approach proposed by the Commission. We can only hope that this proposal will be vastly improved during the inter-service consultation in the run-up to its official publication in May.”

Ariel Brunner EU Agriculture Policy Officer said: “This proposal offers very little hope for the countryside. It fails to address biodiversity loss, climate change and the looming water crisis. One is tempted to conclude that the real aim of this ‘non-reform’ is simply to keep the CAP’s major beneficiaries happy, rather than address Europe’s essential problems.”

For more information, please contact:

Herlinde Herpoel, Media and Communication Officer at BirdLife International -
+32 494 542 844, Herlinde.herpoel@birdlife.org

Notes for Editors:

[1] BirdLife International is a global alliance of conservation organisations working in more than 100 countries and territories. BirdLife is the leading authority on the status of birds, their habitats and the problems affecting them. For more information about the work of the BirdLife European Division click here: http://europe.birdlife.org

[2] The “Health Check” was promised when the CAP was reformed in 2003. Further reform is likely when the EU budget is reviewed in 2009. A period of consultation now follows with a final proposal likely in May 2008. The reforms will be adopted in approximately one year’s time.

[3] Agrafacts 28/02/2008, No. 19-08 – “Health Check special: details of Commission draft proposals.”

[4] BirdLife International’s comments on the Commission’s CAP ‘Health Check’ proposal, based on information published by Agra Facts, looks at how well it addresses environmental challenges like biodiversity decline, accelerating climate change and the looming water crisis.

Cross compliance: a few improvements, but major gaps

Cross compliance is the system of basic rules, based on existing legislation and minimal good practices that farmers receiving public payments have to respect. The Commission proposal addresses a few key failures of the current system by bringing under explicit protection landscape elements such as hedgerows and ditches. It seems to fail, however, to address other key problems such as preventing the ploughing up of permanent grasslands, a crucial measure for protecting biodiversity and avoiding accelerated climate change. It introduces a welcome obligation to maintain buffer strips along water courses as a means to reduce water pollution, but utterly fails to address the unsustainable use of water, including illegal water abstraction that is driving hydrological collapse in many Mediterranean regions.

Set aside: window dressing and real harm

Widespread scientific evidence shows that the set-aside mechanism has brought significant environmental benefits in mitigating the impact of intensive agriculture on biodiversity and the wider environment. The Commission’s proposal to abolish set-aside, at a time when Europe’s most intensively farmed regions face a new wave of intensification, fuelled by high prices and the rush toward biofuels, is tantamount to severing the life-line of many declining species. The Commission has publicly acknowledged this, but the current proposal does not offer any credible alternatives. While the proposed improvements to cross compliance are welcome, they will not offer anything in line with what was provided by set-aside, let alone address the growing impacts of intensification.

Modulation, adding water to a watered down tool

Modulation and capping of higher subsidies are the main tools available for transferring funds from untargeted subsidies toward paying farmers for the delivery of specific public goods. The Commission proposal includes an overall transfer of less than €5bn from the so-called “Pillar 1” to “Pillar 2” (rural development), down from €7.4bn that the Commission had proposed in its green paper last year. These figures are dwarfed by more than €130bn that the EU will be spending over the same period on highly wasteful and unfairly distributed direct payments.

Rural development: poor content and conflicting objectives

The Commission is proposing to use [scarce] modulation funds to supplement rural development expenditure in order to address the “new challenges” (climate change, water, bioenergy and biodiversity conservation). The list of proposed investments include some welcome ones such as wetland restoration, support for organic farming and soil protection. However, the Commission fails to suggest any targeted measures for the conservation of biodiversity, despite a claim to the contrary. Finally, it suggests using scarce resources to boost biofuels production, despite the overwhelming evidence accumulated in recent months that such production will, in most cases, be environmentally harmful and, at best, meaningless for tackling climate change (while it is in fact highly likely to lead to increased emissions through indirectly boosting the destruction of tropical forests and wetlands).

Article 69, a wasted opportunity?

The so called “article 69” mechanism also allows for the retargeting of funds, within the CAP’s first pillar, towards specific environmental and quality objectives. This tool could be scaled-up, adapted and targeted at supporting Europe’s High Nature Value (HNV) farmers, those practicing mainly traditional extensive farming, such as extensive grazing. These farmers provide key services to society in terms of biodiversity conservation and landscape preservation, but are struggling to compete on the market and are heavily penalised by the current distribution of subsidies. Instead of focusing this tool at this specific priority, DG Agriculture is proposing a ‘mish-mash’ of objectives that are likely to lead to widespread abuse whereby each Member State will be able to channel funds towards its most powerful farming lobbies, rather than toward the most deserving farmers.

Move to flat rate payments, little courage and no leadership

One of the most heavily criticised aspects of the CAP is the very uneven and clearly unfair distribution of funds that sees a small minority of large intensive farmers pocketing the vast majority of subsidies. Although not resolving the problem of a lack of justification for the receipt of subsidies, a move toward a flat rate payment, whereby every hectare of farmland receives the same support, would be a step in the right direction of redistributing subsidies from the highly competitive intensive farmers to struggling marginal farmers. The Commission acknowledges this, but shies away from proposing a generalised flat rate system. It rather prefers to leave the choice to Member States who have shown little appetite in the past to face up to their big farming lobbies, and are even less likely to do so if their neighbours go on ‘showering’ money onto their own rich and powerful.

Minimum Single Farm payments, going after the poor?

While the Commission avoids the issue of excessive payments to the CAP’s largest beneficiaries, it seems eager to hit Europe’s most vulnerable farmers. The proposal to scrap the CAP’s smallest payments will have an overwhelming impact on one of the most vulnerable social components of the European countryside - that of the small and poor semi-subsistence farmers, millions of whom are concentrated in the New Member States. These farmers, living at the margin of the market economy, are often very poor but deliver outstanding public goods in the form of the management of high biodiversity habitats and valuable landscapes. The argument that it is “too expensive” to reach such beneficiaries is perverse. Direct payments are a de facto income support mechanism, not linked to any delivery of public goods. Saying that it is much easier and efficient to deliver income support to the few and wealthy, rather than to the poor and numerous, is morally dubious. Eliminating some of Europe’s best land stewards can only harm the environment further.


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