Authors: Stephen Meredith, Kaley Hart, Anne Maréchal

The environmental and climate ambition of the future Common Agricultural Policy (CAP) is increasingly under threat as the European Parliament and AGRIFISH Council finalise their positions on the legal texts. This runs counter to the clear progressive direction of travel set out in the European Green Deal which has been endorsed by both the Parliament and the Council at the highest level, write agricultural policy analysts from IEEP.

The much-hyped need to increase the environmental and climate ambition of the future CAP is increasingly under threat as the European Parliament and Council finalise their positions on the legal texts. Not only are the Commission’s proposals once again being watered down by the co-legislators in a bid to maintain the status quo, but the risk of regression on environmental issues is also a possibility. This runs counter to the clear progressive direction of travel set out in the European Green Deal (EGD) which has been endorsed by both Parliament and Council at the highest level.

There are a number of environmentally significant elements of the Commission’s 2018 CAP proposals currently under discussion. Since the CAP is key to delivering many of the priorities set out in the Farm to Fork and Biodiversity strategies, any watering down of the policy’s environmental ambitions (including those on climate) would put this in jeopardy. If anything, this ambition should be increased to meet these challenges.

There are six immediate issues that must be addressed if the green credentials of the CAP are to remain intact:

• Ring-fencing of funds for eco-schemes is essential for the credibility of the CAP as an environmental policy. This would provide the means for farmers to change and adopt more appropriate land management practices as part of a broader transition towards more sustainable food and farming systems. Eco-schemes should have at least the same level of funding as that dedicated to the current greening measures (i.e. at least 30% of the Pillar 1 budget, ideally increasing progressively over time).
• Unspent funding for eco-schemes should be used to address environmental objectives so that the CAP is fit to tackle the scale of the challenges. Critics of the proposed ring-fence for the eco-scheme point to the risk of unspent funds if the new schemes are not taken up quickly enough. These concerns need to be taken seriously. Balancing these risks without watering down the eco-scheme will require careful design by Member States.  Pre-allocating any underspent funds each year as a top-up to certain types of farmland of environmental importance and farming systems with a proven track record could strengthen the incentive for all farms to participate. For example rewarding top-ups to those with valuable landscape features and environmentally sensitive permanent grasslands that are actively managed, or those demonstrating significant evidence-based efforts to change their farming systems and increase their environmental performance.
• Ensuring eco-schemes are ambitious in scope is necessary so that the schemes can be used to adequately address the pressing environmental and climate issues faced by society to which agriculture and forestry sectors can respond, and thus depart from a one-size-fits-all approach¹.Unlike the current greening measures, which are largely based on complying with a closed list of practices, the eco-scheme as proposed by the Commission should give the Member States greater flexibility to respond to their environmental and climate needs and circumstances.
• Maintaining strong baseline standards through conditionality is essential. Maintaining non-productive features and areas on agricultural land (GAEC 9) is particularly important not only to protect farmland biodiversity but also to increase the resilience of agro-ecosystems. Re-opening the standard to include productive elements such as nitrogen-fixing crops would allow this standard to be met through far less ambitious or environmentally important actions.² The requirement to maintain existing non-productive landscape features and areas should also apply to all farmland, including grasslands and permanent crops. 
• Safeguards against environmentally damaging spending (e.g. coupled payments) must be put in place and should be strengthened in light of the EGD. All interventions should require an assessment of the potential negative environmental impacts as part of the CSP approval process so that such measures do no harm. In addition, interventions that fund practices which can be harmful to the environment and climate should be subject to compulsory conditions which prevent such harm in practice. In particular, coupled support for livestock should always include stocking density limits to prevent overgrazing and Member States should have to justify all such support in the light of their climate objectives. Similarly, coupled support for crops should include appropriate restrictions on fertiliser and pesticide use. 
• Any interventions which count towards the environmental and climate ring-fencing under rural development must be environmentally robust. For example, ANC payments currently make up a large proportion of the total environmental spend under rural development in many Member States. However, there is limited evidence of clear environmental targeting. All interventions should include environmental and climate conditions if they are to be considered part of the CAP’s environmental Failure to do so would diminish the environmental ambition of CAP expenditure³ and weaken the impact on the ground.

Continuing with the status quo in Europe’s agri-food system has for some time been untenable, and the renewed urgency of the environmental and climate challenges facing society means that change now is unavoidable. The final CAP deal must be ‘green’ – with the principle of sustainability firmly embedded throughout both Pillars. Politicians have been dragging their feet over CAP reform for decades. Now is the time for action. They must take this opportunity to demonstrate a commitment to transformative change in the EU’s agri-food systems. Rather than adhere to depressingly familiar negotiating stances, this requires them to grasp the nettle and follow through on the ambitions of the EGD. It is time for a robust policy framework to enable farmers, land managers and foresters to be an engine of change for the environment and climate action in the agri-food sector.

Further reading:

• Hart K and Bas-Defossez F (2018) CAP 2021-27: Proposals for increasing its environmental and climate ambition, report for NABU by IEEP
• Bas-Defossez F and Meredith S (2019) CAP 2021-27: A comparative analysis of the environmental performance of the COMENVI and COMAGRI reports on the Commission’s proposals, report for NABU by IEEP.
• Maréchal, A. et al. (2019) Aligning the post-2020 CAP with the Green Deal, briefing by IEEP

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1. In the European Parliament some amendments on the eco-scheme attempt to revert back to the narrow scope of the current greening measures. This includes moving some GAEC requirements such as nutrient management (GAEC 5) and the maintenance of non-productive features and areas (GAEC 9) into the eco-scheme. Elsewhere MEPs are calling farming practices eligible under the eco-schemes to be listed in the basic act. This runs the risk of stifling Member State creativity to design targeted and tailored solutions to address pressing environmental issues. Evidence shows that the greening measures often discouraged the Member States from being innovative and resulted in choices being selected that required minimal changes rather than promoting the uptake of more sustainable practices. See the results of the European Commission evaluation of the greening measures.

2. Under the current rules, arable farms above 30ha are required to dedicate up to 5% of their farmland areas to ecological focus areas (EFAs). The evidence shows that catch crops and nitrogen-fixing crops constituted the most popular choices taken up by farmers across the EU rather than more environmentally beneficial elements such as fallow land, buffer strips or landscape features. The Council has floated proposals to include both productive and non-productive elements under the new GAEC 9 which replaces the EFA measure. Other farmland types such grasslands and permanent crops could also be exempt from this standard.

3. ANC payments can help to tackle land abandonment in areas deemed to have natural or specific constraints and therefore can lead to a positive indirect impact on biodiversity such as maintaining HNV farmland. However, unlike other environmental interventions such as agri-environment-climate or organic farming schemes, there is no evidence that Member States are systematically targeting these areas when delineating ANC areas. ANC payments also do not have any conditions in place to prevent environmentally harmful practices from occurring. See the results of the European Commission evaluation on CAP and biodiversity.

This work has been produced with the financial support of the LIFE Programme of the European Union. It reflects only the views of the authors.