Those seeking to influence the design of the CAP post 2020 should understand the process of designing Strategic Plans, and the opportunities and constraints inherent in this process. In a recent working paper, I try to explain how Strategic Plans will be constructed and the key entry points for those seeking to improve the environmental and climate ambition of these Plans. The paper is written from a development perspective but the messages have a more general relevance.
The paper does not discuss how the CAP legislation itself might be improved from an environmental or development perspective. The Parliament’s Committee on Development and Environment Committee have submitted their Opinions to the agriculture committee with a range of suggestions in this regard (the latter still only available in Italian), although few were taken on board in the AGRI Committee voting . The paper takes the Commission’s legal proposal as its starting point, and the scope this gives to Member States to design more targeted national policies in the context of the proposed overall shift from a compliance-based to a performance-based policy. Both the Council and Parliament intend to amend the Commission’s proposal, so some options for national flexibility that appear to be open in the proposal may well be closed in the final legislation, although other opportunities may emerge as a result of amendments to the proposal by either the Council or Parliament.
Member States are currently starting the process of developing their Strategic Plans, using a template provided by DG AGRI. In theory, draft Plans are supposed to be ready by the end of this year, to give time for the Commission to review and approve them in the early part of 2020. However, even the Commissioner has accepted that this timetable will slip. The main problem Member States face in devising these Plans is that the legislative framework remains unknown and is likely to remain so at least until towards the end of this year. However, the first stage in designing a Plan is the SWOT analysis to identify needs which can proceed in any event. Many Member States have begun to engage consultants to undertaken this task. Groups interested in participating in the process will need to find out the dates when consultations will be held seeking input from stakeholder groups.
The main recommendations of the working paper, drawn up from the perspective of development interests seeking to ensure that the Plans address the UN Sustainable Development Goals and the Paris Agreement, are summarised in the following. The focus is on the environmental and climate area. Other interventions included in the Commission’s legal proposal can also impact on the external dimension of the CAP. These include the targeting of decoupled payments, the use of coupled payments and support for risk management instruments. But how these issues should be addressed in the national CAP SPs is not addressed in this paper.
- Four of the nine specific objectives (the three climate and environmental objectives (d), (e) and (f) as well as (i) in Article 6 of the draft Strategic Plan Regulation) are the most relevant ones to focus on. A CAP Plan does not have to address all specific objectives – this depends on the outcome of the SWOT and needs assessment. Development interests should ensure that the CAP Plan addresses all four of these specific objectives.
- Apart from the eco-scheme financed from Pillar 1, the most effective interventions in addressing these four specific objectives are likely to be financed from Pillar 2. Thus, development interests should press for the greatest possible transfer of resources from P1 to P2. It should also be considered whether there is a case for additional national financing for certain interventions in P2 linked to relevant objectives if CAP funding for P2 interventions is insufficient.
- It should be a priority to ensure ambitious national targets for the environmental impact indicators (and the corresponding result indicators) are included in the CAP Plan. The absence of specific targets for the impact indicators would make future evaluation toothless.
- Development interests might consider pressing for the inclusion of additional specific result indicators relating to the four specific objectives in addition to the common indicators spelled out in the Regulation. In addition, it would be useful to make a close linkage between indicators used in the CAP Plan and those suggested to measure progress towards the SDGs. Further work to identify overlaps and omissions would be useful.
- Development interests should prepare a possible template for how the Art. 92 commitment to ensure increased ambition regarding environment- and climate-related objectives should be interpreted and demonstrated in the CAP Plan.
- Development interests should consider seeking additional GAEC standards linked particularly to climate mitigation as part of enhanced conditionality. Alternatively, these standards could be included in the voluntary schemes (either eco-schemes or AECMs) so that farmers would be compensated for the additional costs incurred, or they could be put on a statutory basis.
- The flexibility for Member States to define their own level of minimum standards plus the possibility to include other national standards if they are designed to achieve the objectives of conditionality opens a broad perspective in using conditionality to help address the SDGs.
- There should be greater focus on promoting results-based AECMs. While a more flexible use of the opportunity cost concept could allow some farmers to receive an income in situations where otherwise the farm would cease to exist, AECMs are not intended to provide an income stream to farmers through remunerating them for the provision of ecosystem services.
- Eco-schemes provide a mechanism to introduce value-based payments for environmental services. Because of their dual role in providing both income support and achieving environmental benefits, avoiding ‘green-washing’ will be one of the major concerns in the design of eco-schemes.
- Designing eco-schemes to permit multi-annual payments would be highly desirable to achieve the maximum environmental impact.
- Member State targets and interventions to avoid dangerous climate change are now set out in their National Energy and Climate Plans and it is likely these targets will be carried over to the CAP Plans. Where these NECPs do not include specific targets for the agriculture sector, relevant impact targets should be included in the CAP Plans. In any event, development interests should ensure that the policies and measures funded under the CAP Plan are robust enough to ensure that the agreed emissions reduction target will be met.
- Financial compensation to farmers to encourage the use certified soy in animal feed rations as a management commitment could be provided under Article 65 of the Strategic Plan Regulation. Whether or not this is a sensible way to address the adverse external impacts of EU soy imports should be further explored.
The full paper with argumentation is available here. Did I miss anything?
This post was written by Alan Matthews