APPENDIX 7
Memorandum submitted by the Royal Society
for the Protection of Birds (S 11)
1. INTRODUCTION
1.1 The RSPB welcomes the opportunity to
submit evidence to the Agriculture Select Committee.
1.2 The RSPB is the largest wildlife conservation
charity in Europe, with over one million members. We take action
for wild birds and the environment, with a strong interest in
conserving all biodiversity. The RSPB is the UK partner of BirdLife
International, a global network of conservation organisations
working in over 100 countries.
1.3 The greatest threat to birds—and
biodiversity more widely—is habitat loss. The loss of habitats
all over the world is being driven by a range of factors, many
of which are inextricably linked with national and international
economic policies. International trade and the rules that govern
it thus have a direct and important bearing on the RSPB's core
concerns.
1.4 Of particular interest to the RSPB is
agricultural policy and practice as this has major impacts on
biodiversity. The RSPB has significant expertise in agriculture
policy and, with BirdLife International, has been heavily involved
for many years in working to ensure sustainable agricultural policy
in the UK, Europe and world-wide. We have focused particular attention
on reform of the Common Agricultural Policy (CAP) in Europe. However,
the CAP sits within an international agricultural agreement, the
review and re-negotiation of which will have a major bearing on
how agriculture develops in the future. The RSPB believes that
its expertise in, and understanding of, agricultural issues can
help inform this process.
2. GENERAL POINTS
2.1 The EC's Common Agricultural Policy
(CAP) is still in need of substantial reform in order to promote
more sustainable agriculture and rural development. Since the
failure of the Agenda 2000 process to make significant changes
to the CAP, the mandated WTO negotiations on agriculture provide
a further opportunity to achieve them. These negotiations also
present an opportunity to use trade policy to pursue the food
security and development objectives of developing countries.
2.2 It is widely recognised that intensive
agriculture has harmed the European environment. A recent European
Commission report confirms this, and also confirms that this is
not accounted for in policy-making, saying, "Intensive industrial
farming has taken little or no heed of its impact on the environment.
This aspect is still not a central component of discussions or
decision-making at either individual or collective level"[2].
This view is reinforced by the lack of recognition within the
European Commission's proposed agriculture negotiating agenda[3]
of the importance of tackling intensive agricultural practices.
2.3 An understanding of the environmental
and social impacts of current policies and the relationship between
trade policies and intensive agriculture is crucial for the mandated
negotiations on agricultural trade that form part of the WTO's
"built-in-agenda". Although such an understanding is
required by Article XX of the Agreement on Agriculture (AoA),
which says that these negotiations should take into account "non
trade concerns" (eg the environment), there is no indication
from MAFF or the EU that this understanding already exists or
that specific measures are being taken to develop it. The RSPB
believes that there should be a social and environmental impact
assessment of the AoA—either before, or as part of, the
negotiations—in order to inform their scope and direction.
2.4 It is clear that farming in the Yorkshire
Dales is very different from farming in the mid-west of the USA.
Agriculture is very much an integral part of the landscape in
most of Europe—a different situation to that which exists
in some other parts of the world. Sometimes referred to as the
"European model" of agriculture, these differences need
to be recognised and the objectives for European agriculture clearly
expressed. This is important so that on the one hand this concept
is not used to justify maintaining the CAP in its current form
and on the other hand, so that trade policy takes these differences
into account.
2.5 The main objective of the AoA—to
achieve "substantial progressive reductions in support and
protection" (ie liberalisation)—needs to be changed.
The focus of the agreement should be on using the trade system—whether
liberalisation or some form of agricultural or environmental support—to
pursue the production of safe, healthy food in a sustainable way
and to support food security, environmental protection and enhancement
and rural development. Changing the AoA's main objective would
help provide a better direction for negotiations.
2.6 The term "multifunctionality"
is used in the European Commission (EC) agenda for agriculture.
This is potentially a step forward as it is a recognition that
agriculture is more than just producing the lowest cost food for
international markets; environmental, social and cultural values
are also at stake. However, it is vital that "multifunctionality"
is not used as an excuse to maintain or extend the EU's current
environmentally damaging, socially destructive and unfair agricultural
regime.
2.7 The WTO talks will be judged on how
successfully the concept of "multifunctionality" can
be converted into action so that agricultural trade policy helps
promote more sustainable agriculture, foster food security, protect
the environment and boost rural economies. To this end, the RSPB
would like to see the negotiations on agriculture address the
real issue of how to manage international trade to benefit people
and the environment, rather than engage in an ideological battle
between so-called "free-trade" on the one hand and "protectionism"
on the other.
2.8 Finally, although the CAP is in need
of major reform, the RSPB does not believe that complete free
trade is "the answer". On the contrary, some environmentally
benign agricultural practices require government support if they
are to succeed. The challenge of the for the UK and the EU is
to convert the worst aspects of the CAP (eg export subsidies and
production-related domestic subsidies) into less trade distorting
environment or rural development-related payments.
3. SPECIFIC POLICY
RECOMMENDATIONS
3.1 Domestic support
3.1.1 The RSPB has long called for reform
of the CAP and a reduction in production subsidies on environmental
grounds. The production subsidies of the CAP have fuelled the
intensification and specialisation of farming to the detriment
of the environment, resulting in the direct loss of wildlife habitats
and the gradual deterioration of many of those remaining. Farmland
birds and other wildlife which rely on farmland habitats across
Europe have—as a direct or indirect result of changes in
habitat quantity and quality—undergone enormous declines
in the past 25 years or more. Environmental problems such as the
pollution of drinking water with nitrates from agricultural sources
of servere soil erosion are further evidence of the damaging impacts
of production-driven agriculture.
3.1.2 Agenda 2000 was a major opportunity
to implement fundamental reforms to the CAP. However, the final
package agreed by Heads of Government in Berlin was a weak compromise
between, on the one hand, those countries wishing to maintain
the status quo and, on the other, those who recognised the need
to respond to pressures on the CAP budgete, to allow for EU expansion
and to facilitate world trade. The more far reaching proposals
of some nothern European Member States, including the UK, were
effectively countered by other countries determined to protect
their agricultural industries. In this process, demands from NGOs
such as the RSPB/Bird Life International to move towards a more
sustainable system of agricultural production and support to benefit
people and the environment were largely ignored.
3.1.3 The Agenda 2000 CAP reform package
was a disappointment on a number of counts:
— it introduced price cuts in commodities
such as cereals, beef and milk but at rates less than originally
proposed, leaving some EU prices at levels higher than the world
market price;
— it will compensate price cuts through
increased "blue-box" payments such as Arable Area Payments
(AAPs) and livestock headage payments;
— it failed to make any commitment
to progressively reduce blue box payments to farmers—the
concept of "degressivity";
— it established the so-called "second
pillar of the CAP"—the Rural Development Regulation
(RDR)—but commits only 10 per cent of the total CAP budget
to this measure;
— it offers limited measures eg optional
cross compliance, to being to address the enormous environmental
problems facing the EU as a result of intensive and specialised
agriculture.
3.1.4 The failure of Agenda 2000 significantly
to switch EU domestic support away from production linked subsidies
towards environmental and social measures leaves the EU in a difficult
negotiating position as it enters world trade talks. Members of
the Cairns group of countries[4]
and the US have already taken a stance, prior to the start of
the agriculture negotiations, against what they consider to be
the "protectionist" and trade-distorting policies of
the EU. Blue box payments, which account for a large proportion
of the CAP budget, are likely to be vulnerable to attack and the
EU will be joined by few other countries (perhaps only Japan,
Norway, Switzerland and South Korea) in defending them. A commitment
during Agenda 2000 to make these payments degressive might have
sent a signal to the US and others that the EU is committed to
reducing production support while at the same time facilitating
the switch into more environmentally benign and less trade distorting
forms of agricultural support.
3.1.5 We believe the EU will be forced by
a combination of trade pressures, expansion eastward and increasing
production levels, to undergo further reform of the CAP by 2002/3.
We wish to see the UK lead the way in advocating such reforms
and calling for the introduction of degressivity to blue box payments.
3.1.6 Making blue box payments degressive
would allow a switch in funding to environmental and social measures
mostly provided for through the new RDR. Such measures constitute
green box support since they are not linked to production and
therefore are less trade distorting. The RSPB has supported such
measures for many years and has been a strong advocate of the
use of agri-environment and rural development schemes to deliver
environmental and social benefits in rural areas. In the meantime,
the option to modulate[5]
CAP subsidies—agreed as part of the Agenda 2000 package—is
a clear opportunity for Member States to start now to shift subsidies
away from production and towards support for environmental and
social objectives. We would like to see the UK and other Member
States making use of this option which we believe would also send
a signal to WTO partners of a commitment to reduce production
subsidies.
3.1.7 As long as blue box payments such
as AAPs and livestock headage payments exist, we would like to
see the UK apply environmental conditions to them to protect the
environment from the worst impacts of intensive agriculture. We
seek a commitment from MAFF that environmental conditions will
be applied in the UK and have submitted proposals to MAFF on this
issue in response to the consultation paper "A new direction
for agriculture" issued in August.
3.1.8 The use of green box measures goes
to the heart of the debate about the multifunctionality of European
agriculture. The Ministers of Agriculture of the EU and reprsentatives
of the Commission have emphasised the multifunctional role of
agriculture on several occasions now. However, there is scepticism
among WTO members (including countries such as Australia, New
Zealand and the US) that the term justifies protectionist policies
or acts as a means of giving trade-distorting (or production)
subsidies to farmers "by the back door". If multifunctionality
is to be a real bargaining tool used by the EU in its trade negotiations,
the EU must do two things:
(a) among its World Trade partners, secure
an understanding of the European model of agriculture and the
relationship between agricultural production systems and environmental
and other public goods—ie clearly define "multifunctionality";
(b) demonstrate that agriculturally related
payments made to farmers for environmental or social reasons really
do deliver environmental or social benefits that could not be
achieved in another way.
3.1.9 There are many examples of the fundamental
relationship between certain types of agricultural system and
benefits to biodiversity and rural communities. Sheep grazing
in the dehesa systems of Spain, olive production in Greece and
extensive beef production from wet pastures in the UK are all
examples of farming systems which produce food in a way which
is environmentally beneficial while helping to support rural communities.
Without public support, many of these systems would struggle to
survive and the public goods associated with them would be lost.
3.1.10 In Europe, perhaps more than on some
other continents, there is an intrinsic relationship between farming
and wildife. Many of our most important species, habitats and
landscapes are the result of, and depend on, environmentally sensitive
farming practices. Without such farming practices, Europe would
not have the rich diversty of birds and other wildlife that we
have today. The recent loss of wildlife and habitats across Europe
is a result not of farming per se but of the way in which farming
practices have become increasingly intensive and specialised.
The fundamental relationship between farming and wildlife in Europe
is poorly understood by many WTO partners from countries where
the conservation of wildlife is an activity which largely takes
place away from farmland. Building an understanding of the relationship
between farming and wildlife and of the wider multifunctionality
of agriculture, represents a huge challenge for the EU. The UK
has an important role to play in meeting this challenge and could
do much to inform WTO partners of the environmental and social
function performed by European agriculture.
3.1.11 The justification of green box payments
will depend not only on fostering an understanding of the relationship
between farming, wildlife and rural communities in Europe but
on demonstrating the environmental and social benefits of green
box support. The benefits of measures such as agri-environment
and rural development schemes must be clear and tangible to WTO
partners. At an OECD conference held in Helsinki in 1996, many
WTO partners questioned the nature of EU green box support delivered
through the agri-environment regulation (reg 2078/92) and the
output of schemes implemented under it. A review of agri-environment
schemes across the EU[6]
found that the environmental benefits of these schemes in many
Member States were not clear, that programmes lacked clear objectives
and targets and monitoring was not undertaken. Considerable progress
has been made by many Member States since then to improve the
performance of agri-environment schemes and to implement monitoring
programmes to determine their environmental benefits. However,
much remains to be done in this area if agri-environment schemes
are to be seen as credible vehicles for delivering agricultural
support through the green box mechanism.
3.1.12 A review of green box criteria and
of the support measures currently used within it should be undertaken
by the EU without delay to prepare for the agriculture negotiations.
The new RDR is likely to become an important element of future
green box support. The European Commission should ensure that
RDR programmes—of which agri-environment schemes are now
part—submitted by Member States do genuinely contribute
to meeting the objectives of sustainable agriculture and rural
development. The UK, which has historically taken a lead on the
design and development of agri-environment schemes in the EU,
must now take lead on the development of its RDR programmes to
ensure that clear environmental and social benefits will be delivered.
3.2 Market Access and Subsidised Exports
3.2.1 We believe that there are strong environmental,
as well as economic and political reasons for eliminating most
import tariffs and all export subsidies. However, as is outlined
in section 3.3.1 the RSPB does see the potential for using the
tariff system in a targeted way to encourage more sustainable
agricultural production and urges the UK Government to explore
appropriate options. For example, the possibility of charging
lower tariffs on imports of certified organic and/or fairly traded
products.
3.2.2 Agricultural price support under the
CAP has encouraged the intensification of European farming, which
has significantly damaged the environment. High prices have also
increased the cost of agri-environment schemes introduced to reduce
and reverse this environmental damage.
3.2.3 The RSPB would like to see all agricultural
price supports abolished, eliminating the need for general tariffs
and export subsidies on agricultural goods. We strongly believe
that environmental concerns are better addressed through agri-environment
schemes and targeted trade measures, than through general subsidies
and import tariffs. Some intervention stocks could be maintained
for reasons of food security.
3.3 Developing countries
3.3.1 In principle, the RSPB supports the
development of tariff systems to grant favourable rates to agricultural
imports produced in more environmentally benign and socially progressive
ways. Forexample, where internationally agreed agri-environment
standards exist—as may be possible in the caseof organic
production[7]—tariff
preferences could be granted to encourage more environmentally
beneficialproduction processes. This is consistent with the fiscal
policies of the Government to increase tax on environmentally/socially
harmful activities and/or reduce tax on environmentally/socially
beneficial activities. Developing such a system would, however,
require a change in the interpretation of WTO rules which currently
prohibits discrimination on the grounds of "process and production
methods" (PPMs). Such a system would also require providing
enhanced technical and financial assistance to support developing
country producers wishing to switch to more sustainable agricultural
production methods and take advantage of the lower tariffs.
3.3.2 The RSPB recognises the importance
of food security to developing nations. Developing countries should
be able to, where necessary, use appropriate trade policies to
protect food security and promote agricultural development. To
this end, the RSPB urges the UK Government to work with developing
country WTO partners to formulate special and differential treatment
provisions that enable them to achieve these goals. The RSPB sees
the potential for positive synergies between biodiversity conservation
and agricultural trade policies that support rural communities
in the developing world.
3.4 Genetically Modified Organisms (GMOs)
3.4.1 The UK Government has stated that
the Sanitary and Phytosanitary Agreement (SPS) "permits
a precautionary approach by providing for provisional measures
to be adopted where information is still insufficient, provided
that a serious attempt is made to establish a more informed basis
for action within a reasonable period of time"[8]
This does not match with a recent statement by Government officials
that the Government cannot impose a general precautionary moratorium
on the commercial planting of GM crops while further scientific
testing is conducted because it is illegal under trade rules[9].
We believe that the Government's adherence to this position is
preventing it from adequately regulating the possible commercialisation
of GMOs in the UK, which could have significant impacts on the
environment. It is becoming increasingly clear from this case,
and the recent WTO ruling against the EU's ban on hormone treated
beef, that the precautionary principle needs to be more clearly
and fully incorporated into trade law.
3.4.2 Some WTO members have recently requested
the discussion, in the WTO, of regulations affecting trade in
Genetically Modified Organisms (GMOs). Japan and Canada have both
called for a WTO working group to be set up on biotechnology[10]
whereas the USA wants biotechnology issues to be discussed as
part of the agriculture agenda[11].
The RSPB is very concerned that any such talks could undermine
the negotiation or implementation of an effective Biosafety Protocol
under the Convention of Biological Diversity (CBD). The last Biosafety
Protocol negotiations (in Cartagena, February 1999) broke down
because of the trade concerns of a few economically powerful CBD
signatories and it is important that these trade concerns are
not given precedence in the WTO over the protection of the environment.
The effective regulation of trade and use of Genetically Modified
Organisms (GMOs) is an important environmental issue and should
be dealt with in an international environmental agreement. The
RSPB would like a commitment from the UK and the EC that there
will be no negotiation, in the WTO, of biotechnology issues as
this could adversely affect the development and/or implementation
of an effective Biosafety Protocol.
1 November 1999
2 European Commission (DGVI, DGXI and Eurostat). (1999).
Agriculture, environment, rural development facts and figures:
A challenge for Agriculture. Brussels, European Commission. Back
3
European Commission, (1999). Communication from the Commission
to the Council and to the European Parliament: The EU Approach
to the Millennium Round. Brussels, DGI. Back
4
The "Cairns Group" is a group of agricultural product
exporting countries-including New Zealand, Australia, Argentina,
Malaysia and Thailand-that are pushing for "free trade"
in agriculture. Back
5
Under Agenda 2000, Member States can use modulation to reduce
or cap direct payments to farmers eg Arable Area Payments and
redirect the money saved into rural development or agri-environment
programmes. Back
6
BirdLife International (1996) "Nature conservation benefits
of plans under the Agri-environment Regulation (EEC2078/92) BirdLife
International European Agriculture Task Force. Back
7
The International Federation of Organic Agriculture Movements
(IFOAM) has developed principles and criteria that can be applied
to organic agriculture globally and also acts as an accreditation
body for national organic certification schemes. Back
8
DTI (1999). The UK and the World Trade Organisation: An Introduction
to the Next Round. London, HMSO. Back
9
In a written answer to a question posed by the UK Trade Network
in July 1999 on the legality of imposing a precautionary moratorium
on the commercial planting of GM crops, the Government stated
that, ". . . a general moratorium would probably fall
foul of WTO rules". Back
10
Canadian Proposal for the Establishment of a Working Party on
Biotechnology in the WTO, 1/10/99, Geneva, WTO. Proposal of Japan
on Genetically Modified Organisms, 4/10/99, Geneva, WTO. Back
11
Ambassador Susan Esserman, Deputy US Trade Representative, Statement
Circulated by the US Delegation, WTO General Council Session,
29 July 1999, Geneva, Switzerland. Back
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