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Commission Proposals on CAP: Will this become another decade of biodiversity decline?

We are pleased to welcome this guest contribution from Trees Robijns, Agriculture and Bioenergy Policy Officer, NABU (BirdLife in Germany) and Ariel Brunner, Senior Head of Policy, BirdLife Europe and Central Asia, who react to the Commission legislation proposals on the Common Agricultural Policy post 2020 published earlier today.

We have seen it all before: CAP reform. The same old CAP reform. To many of us following the process in detail, we are always in the run up to, in the middle of, or in the aftermath of a CAP reform. It feels like a never ending story of small incremental steps which, only to the absolute “uber-CAP-nerd”, lead in a clear direction.

Today, we had another déjà vu. The Commission had a press conference, NGOs and farmer organisations reacted strongly. Agri ministers meeting in Sofia this weekend will probably welcome the proposal in diplomatic speech and Parliamentarians will start to prepare thousands of amendments. We are all on the treadmill and we know where it ends: essentially at the status quo.

Meanwhile, the countryside keeps dying.

This is when citizens, voters and civil society have to say: stop! No more of this! The environmental crisis is too big to go through this game again and again without an outcome. Let’s remember the facts.

Farmland birds are disappearing from the countryside across Europe at a dazzling speed (for those who need a reminder: here are some examples from France, Denmark, Belgium and the 56% decline in the EU Farmland bird index). The scientifically documented insect decline in Germany shows a more than 75 percent decline over 27 years in total flying insect biomass in protected areas.

Turtle doves are on the brink of extinction in several European countries (-77% in the EU, -95% in the UK). We are on the brink of losing the partridge (-94% in Germany and Slovakia). The EU State of Nature report shows 64 % of grassland (non-bird) species and 86% of grassland habitats are in an unfavourable state. Furthermore, 70% of cropland (non-bird) species are deemed to be in an unfavourable state.

We know agriculture is the primary driver of the collapse. This is now as much an established scientific fact as human induced climate change. Our own governments identify agriculture as the largest threats for birds and habitats. The sad reality is that we are heading for the end of the line. Commissioners and farm lobbyists can play word games with “steps forward” and “evolution not revolution”. However, the naked truth is that our natural world cannot afford another couple of rounds of CAP reform. Should current trends continue, many species and habitats will simply be gone by the time the next CAP reform is on the agenda.

Meanwhile, on the political side, the story seems to be equally disheartening. The CAP, the policy with the greatest capacity to make a difference for nature and the environment, was refused any meaningful scrutiny (to which ALL environmental legislation is being subjected) and NGOs had to commission their own CAP Fitness Check. There was even a brutal disregard for the pile of critical Court of Auditors’ reports, the last one on the Commission’s own communication.

Although over 80% of citizens engaged actively with the Commission’s own “public consultation”, the Commission readily pushed it aside. Reports from Bulgaria and Slovakia showed corruption and abuse of taxpayers’ money in CAP implementation in Eastern Europe. And as a sad cherry on top: Budget Commissioner Oettinger slashed the more progressive pillar 2 funding, while doing the utmost possible to preserve meaningless and distorted direct payments.

One would think that the disaster in the countryside, combined with the policy-related problems, would lead the Commission to set the record straight. All the more shocking is the complete lack of ambition in their proposal. BirdLife baptised it as CAP Greenwash 2.0. Here is a list of the facts upon which we base ourselves (the full table can be downloaded from the link at the bottom of this article):

• We do not have sufficient funding to protect nature. We need EUR 15 Billion at EU level to implement the Birds and Habitats Directive. We have, instead, seen a decrease in environmental ringfencing and a smaller second pillar from which most of these more targeted measures should come. Removing Areas of Natural Constraints from the minimum spending requirement could have some effect (although one needs to take into account a decreased pillar 2 budget) but this will be far from enough to close the financing gap.

Climate spending will not be real money spent on measures for climate. The policy claims to be dedicating 40% of the direct payments to climate – an approach that was already heavily criticised by the Court of Auditors in the past. This means that even direct payments to intensive livestock operation or to arable farming on peatland will still be automatically considered as climate expenditure.

• The new programming structure, although good in its intention, risks becoming a Member State free-for-all fund without the necessary accountability mechanisms.

• The new objectives and indicators are not specific enough to deliver on the promised “budget for results”.

• The old system remains strongly in place, by keeping the two pillar structure and by not allowing a 100% modulation from the first to the second pillar.

Capping as was shown on this blog before, will probably be ineffective.

• There is a partially improved conditionality (old cross compliance and greening) which now includes (part of) the Sustainable Use and Water Framework Directives as well as clarifying and adding some elements to the Good Agricultural and Environmental Conditions (appropriate protection of wetland and peatland). However the flexibilities in implementation will need to be monitored closely and it does not apply to crucial parts of the policy such as investment aid.

• Several of the safeguards on investments (such as irrigation) were removed, thus driving further unsustainable farming practices

• Mandatory Eco-schemes could be beneficial, but without any ring-fencing of funding they might actually not or barely be used.

• The involvement of environmental authorities remains weak.

• The proposal allows coupled support for biofuels.

In the past (the Ciolos Reform), we could cultivate the illusion of good intentions gone wrong. This time, the Commission’s level of ambition leans closer to 0 degrees. It is all the more incredible that it is coupled with wording such as “A modernised Common Agricultural Policy must enhance its European added value by reflecting a higher level of environmental and climate ambition and addressing citizens’ expectations for their health, the environment and the climate”.

The only answer now is for the Heads of State (Merkel, Macron and colleagues) to take action. Closely followed by a European Parliament that should not forget it will face the electorate in less than a year from now. They must turn the tide and show that the EU-Budget negotiations as well as the CAP co-decision process can transform this proposal into something which will not make this the decade of biodiversity loss but the decade in which we stood up together for nature.

This post was written by Trees Robijns and Ariel Brunner.

The German version of this article can be read on the NABU blog here.
The table with the evaluation can be downloaded here. BirdLife and NABU colleagues have done their best to interpret the Commission proposals correctly. However, if you do notice any mistakes, please flag them to the authors

Photo credit: Peacock butterfly on Field Scabious flowers, by Eskling, reproduced under a Creative Commons licence

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