A recent paper in Science (unfortunately, behind a paywall unless you have access through a library or individual subscription) written by 21 authors from across Europe provides a very timely review of the impact of the recent CAP reform from the perspective how it addresses the EU’s biodiversity commitments. UPDATE There is a short summary by one of the authors here.
The EU’s overall objective in its Biodiversity Strategy for 2020 agreed in 2011 is to halt the loss of diversity and to restore degraded ecosystems. Specifically, Target 3A is to “maximise areas […] covered by biodiversity-related measures under the CAP”. While this is not a very meaningful target, it was presumably intended to imply that the CAP should do much more in the future to prevent and reverse declines in biodiversity. The authors conclude that the CAP reform does not fulfil this target.
CAP greening and biodiversity
The authors review the three main greening measures under Pillar 1 as well as the prospects for financial support to enhance biodiversity measures under Pillar 2 and find them wanting.
Ecological Focus Areas (EFAs) are limited to less than 50% of the EU arable area and permanent crops, grasslands or pastures do not need EFA. EFAs can also include land uses with doubtful benefits for biodiversity. In the absence of specific management guidelines, the authors conclude that EFAs will likely contribute little to biodiversity.
The authors are critical that the proposals foresee some further decline in the area under permanent grasslands while failing to distinguish between grasslands of very different habitat quality. The paper acknowledges that member states are required to identify and protect ecologically valuable grassland within protected Natura 2000 sites but point out that farmers can continue to receive subsidies while converting extensively-managed species-rich grassland to highly intensified, uniform and biodiversity-poor swards.
The authors also point out that cultivating three crops on large, intensively managed farms is unlikely to enhance biodiversity and that, in many member states, these targets are lower than existing average crop diversity at the farm scale.
On financial support for biodiversity measures under Pillar 2, the paper fears a reduction in national funding because of the lower overall ceiling for Pillar 2 payments and the possibility to move funds to Pillar 1. They also regret that the new regulation did not do more to improve the cost-effectiveness of Pillar 2 schemes in terms of uptake and biodiversity outcomes. Whether this funding fear is justified will not be fully known until all member states’ Rural Development Programmes are published later this year.
The paper contains two sets of recommendations, one to member states that might wish to make use of the flexibility under CAP2013 to go beyond the minimum requirements in the regulations, and the other set for the EU to consider in its deliberations over the next CAP reform. The recommendations to member states include maintaining or enhancing the budget for agri-environment schemes (AES) in Pillar 2, focusing AES on specific target groups, defining appropriate land uses and management prescriptions for EFAs, completing the mapping of grasslands into the different types and ensuring an effective Farm Advisory Service.
Recommendations to the EU
The recommendations addressed to the EU are made in the context of the requirement in 2017 for the Commission to report on the effectiveness of EFAs and to consider proposing an increase in the EFA area from 5% to 7% of the arable area on farms. The authors propose turning this into a mid-term review of the CAP. This seems unlikely to happen.
However, under Article 110 of the Horizontal Regulation the Commission is required to report on the performance of the CAP, including its impact on sustainable management of natural resources and climate action. The first performance review, which with respect to the sustainability dimension will focus on greenhouse gas emissions, biodiversity, soil and water, should be presented before the end of 2018. While this reporting deadline appears a bit late to influence the content of any new Commission proposals for the CAP after 2020, such a report would certainly be able to influence the negotiating positions of both the Council and the Parliament on any such proposal. Thus, the paper’s recommendations are worth highlighting in this context.
There are five in all:
• To publish an evidence-based assessment of the CAP’s impacts on farmland habitats, species and ecosystem services, drawing on national-level monitoring as a base for improvements;
• Increase the EU-wide AES budget, while directing it to more effective incentives and shift to outcome- rather than area-based targets;
• Improve EFA effectiveness by reducing exemptions, refining management criteria for qualification, and expanding their total area;
• Develop longer-term perspectives for more effective and comprehensive protection and restoration of grasslands and peatlands, with a particular focus on the management of high nature-value grasslands;
• Re-evaluate the usefulness of the crop diversity measure. Here, the paper appears to cast doubt whether the measure, even in a revised form, could yield substantial benefits to biodiversity but it suggests some potential options for improvement.
A future reform agenda?
This seems a promising agenda for the incoming European Parliament to take on board. In the next Parliamentary term, it will be important to ensure that the Parliament’s Environment Committee is given co-responsibility with its Agriculture Committee for drafting the Parliament’s response to Commission proposals for the CAP post-2020. This did not happen with the recent CAP reform, where the Agriculture Committee had the sole responsibility for drafting the Parliament’s response with the Environment Committee confined to the role of offering opinions only.
The paper’s focus is solely on the implications of agricultural policy for biodiversity. Climate regulation, soil health and water quality are other environmental issues of importance which must also be considered in any overall assessment.
One area where the paper is less than convincing is in its defence of a uniform application of EFAs on every arable (and, potentially, grassland) farm. Given differences in land productivity, the opportunity costs of achieving particular biodiversity targets will be different in different farming areas. This suggests that it would make sense to concentrate efforts to conserve biodiversity in areas that are less productive from a food production point of view, and to maximise food production in those areas that are most suited to this.
While this would clearly mean less biodiversity in the more intensively-farmed areas, why it should mean less biodiversity overall in the form of fewer species (which must be the justification for applying a uniform EFA threshold for all land) is not spelled out. Given the opposition to taking productive land out of production (which played a major role in the past CAP reform, including getting a mention in the European Council conclusions on the multi-annual financial framework), this issue needs to be more fully addressed before the next CAP reform.
The paper also seems inconsistent in its approach to the conservation of permanent grassland. From a biodiversity perspective, the paper argues convincingly that what is important is the protection of semi-natural and extensive grasslands, and it is dismissive of the biodiversity value of intensively-managed re-seeded grassland and grassland monocultures. Yet it still argues to maintain the overall area of permanent grasslands, including those that are intensively-managed. This smacks a little of over-kill.
The case against ploughing up permanent grasslands is not only or mainly a biodiversity case but is also made on climate regulation grounds, to avoid the release of soil carbon. But it is not evident that overall greenhouse gas emissions from grassland and the animals that graze it is necessarily less than from arable land converted from pasture, depending on the management practices in place. On the other hand, restricting the adaptability of land use in the face of climate change through re-introducing supply management-type instruments into the CAP does not seem a sensible approach to pursue. This is another area where more convincing arguments are needed to support the policy agenda put forward in the paper.
Finally, the paper does not address the possibility that, under its recommendations for a higher budget for AES schemes in Pillar 2 (presumably funded by shifting resources from Pillar 1) as well as more onerous EFA requirements possibly up to 10% of the arable or even total area of a farm, many more intensive farmers might simply choose to opt out of the EU payment system altogether.
As I have previously argued (see this post), focusing on the fine-tuning of the greening (and cross-compliance) requirements of the CAP only makes sense in the context of a Pillar 1 budget sufficiently large to continue to attract the overwhelming majority of farmers into the scheme. Yet many of us feel that maintaining a large Pillar 1 budget for direct payments cannot be justified and would prefer to see this funding used in more targeted schemes.
Despite these caveats, the paper is a formidable summary of the weaknesses of the current CAP reform from a biodiversity perspective, and its agenda for reform should be fully explored by the new Commission and Parliament once they are in place after the autumn.
Photo credit: Wikipedia used under a Creative Commons licence.
This post was written by Alan Matthews.