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So how green is the Health check “green paper”?

The Commission’s “CAP Health Check” communication acknowledges the fact that European Farming and countryside face unprecedented environmental challenges: continuous biodiversity decline, increasing climate change and a looming water crisis. The Communication fails however to come up with credible proposals for dealing with these challenges. It was hoped that the Commission would use the Health Check to outline a long-term sustainable vision for European farming and land management. Instead, the Communication seems bent on a business as usual scenario.
A failure to introduce substantial changes to the CAP to bring it in line with citizens’ expectations and transform it into a tool for sustainable land management would have grave consequences. It would determine the failure to achieve the EU objective of halting biodiversity decline and would put in question the ability of the EU to effectively mitigate and adapt to climate change. It would also severely undermine the credibility and legitimacy of EU expenditure on farm subsidies, precisely while such expenditure will be coming under increasing scrutiny during the EU budget review process.

The following points resume BirdLife International’s analyse the Commission communication, rating its environmental performance on some of the key issues at stake. The following rating system has been used:
Five stars- Ambitious and well thought of proposals highly likely to deliver positive outcome.
One star- Exceedingly weak or misguided proposal, highly likely to fail in delivering any environmental improvements.
No stars- An actual step back, a likely negative outcome aggravating existing environmental crises.

Set-aside
Green rating – no stars
Set-aside, the obligation to leave small pockets of non cropped land, is being abolished despite its incidental but well documented benefits to wildlife and water. The Health check promises only to review replacement measures but suggests these will only be voluntary. The EU is just three years away from missing its objective of halting biodiversity decline and climate change is forcing species to move in search of new habitat. European farmland desperately needs more environmental quality but is likely to get even less than the present level. Voluntary measures will not be able to deliver as rising commodity prices mean that agrienvironmental schemes will be “uncompetitive” in the most intensively cropped regions- precisely the areas where set aside is providing a lifeline for biodiversity. The Commission must come up with a credible proposal to guarantee that the benefits of set aside are retained and that all European landscapes are made more permeable to species movement in order to ensure climate change adaptation. This can be achieved, for example, by introducing an Environmental Priority areas obligation as part of the definition of Good Agriculture and Environmental Conditions.

Environmental standards
Green rating- 1 star
Under the CAP, all farmers receiving subsidies must respect environmental legislation and some basic good practice rules such as not destroying hedgerows or taking measures to avoid soil erosion. The enforcement of these requirements is not evenly implemented across Member States with many countries avoiding correct implementation. The Health check ignores this, suggesting simplifying the rules without making it clear whether this would not result in further watering down. The health check does propose that similar standards be set for water and climate change but gives too little detail of what actual rules may be and how would they be made to work. Ensuring that cross compliance is effectively implemented throughout the EU is essential if CAP subsidies are to retain any public credibility. Facing climate change and water issues require precise engagements such as the full protection of all long term permanent grasslands from conversion that releases their carbon stock and effective measures to ensure water saving and legal water use.

Subsidy limits
Green rating- 1 star
This is the third time the Commission has proposed a ceiling on subsidies to individual farmers or landowners. Farmers with large amounts of land are likely to split their estates to avoid cuts. Further more, analysis of the proposal suggest very little funds would be redistributed and the current spending pattern that sees about 80% of funds going to around 20% of the biggest and most intensive farmers wouldn’t change significantly, even if the rules are not circumvented. Redirecting the huge funds currently wasted on income support to the rich, toward supporting sustainable farmers is a key issue but a much more meaningful proposal is needed.

The Vision
Green rating- 2 stars
There is no long-term plan for the CAP although the Health check does recognise the importance of the policy in tackling wildlife declines, water pollution, water shortages and climate change. Without a clear vision for the future, the massive amount the EU spends on farm subsidies is likely to come under pressure in the EU budget review in 2009. Both the environment and farmers need a long term perspective for a policy promoting sustainable farming and rewarding farmers for the delivery of public goods. Only such a clear vision is likely to justify, on the long run, the allocation of significant EU resources to farming and land management.

Money for the environment
Green rating- 2 stars
€45bn of taxpayers’ money is spent on the CAP each year, but most of it is spent on untargeted direct payments that are not linked to environmental or social improvements. Only 20 per cent of CAP funds are spent on rural development and environmental measures. The proposal to increase modulation, I.E; the transfer of funds from the CAP’s first pillar to the second is positive and could provide increased funding for sustainable farming, improved environmental quality and rural development. However, the level of ambition outlined by the Commission is extremely disappointing. In 2002, the Commission proposed a modulation rate of 20%. With the much clearer picture of the severe underfunding of Rural development and increased environmental stress, the current proposal has reduced that figure to 12%. Such a proposal would be an improvement on the staus quo but is a far cry from what is needed.

Biofuels
Green rating- 4 stars
The health check would scrap subsidies for biofuel crops. This is good news for the environment as these subsidies are not based on greenhouse gas savings or environmental safeguards. However, this subsidy is increasingly dwarfed by the incentives given to biofuels through the energy policy.

National envelopes
Green rating – 4 stars
Member States can spend 10 per cent of subsidy funds on environmental and social measures but the rules are so rigid that few countries have done so. The health check communication opens up the prospect of better targeting, simplification and an increase in the amount that can be transferred. If properly elaborated this proposal could contribute to supporting sustainable farming, especially in marginal areas.

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