8 The
balance of funding between direct payments and payments for environmental
public goods
136. The balance of funding between direct payments
linked to cross-compliance and targeted payments in return for
additional public goods is one of the key debates at the heart
of this round of CAP reform. The Commission's Communication indicates
a desire to allocate more of the money to 'public goods', in particular,
measures to protect and enhance the environment, tackle climate
change and improve the sustainability of the food supply chain.
Commissioner Ciolo? described this as improving the environmental
performance of the CAP, or 'greening', saying:
With the greening, we propose that our farmers do
more, in terms of the management of natural resources, the quality
and fertility of soil, and biodiversity, and we will use part
of direct payments as an incentive in order to do more production
of public goods.[221]
137. The majority of our evidence supported a
greater focus on sustainability and the environmental performance
of agriculture, but there was no consensus on the level of budget
transfers or how any greening should be carried out. This section
will consider the evidence for and against greening of the CAP
and the subsequent section will consider the range of suggested
options for implementation.
Does the CAP need to be greener?
138. The European Parliament's Resolution of
8 July 2010 on the future of the Common Agricultural Policy after
2013 and the Pack Inquiry into Future Support for Agriculture
in Scotland echoed the Commission's desire to place greater emphasis
on sustainable farming in the reformed CAP.[222]
The Agriculture and Fisheries Council also "endorses the
concept of further greening the CAP towards 2020".[223]
139. The RSPB emphasised the importance of "a
re-focussing of support towards environmental and climate change
objectives".[224]
The CPRE similarly called for "a more comprehensive
Pillar 2 with a greatly increased level of funding" to provide
environmental public goods on a large scale.[225]
The Rural Economy Land Use Programme (RELU) argued that the budget
for Pillar 2 needed to be radically increased.[226]
Professor Swinbank also advocated an increased spend on
environmental schemes in Pillar 2 as part of the phasing-out of
Pillar 1.[227] Recent
studies have estimated that there is a shortfall in spending on
environmental measures in the UK compared to the cost of providing
a desirable level of environmental benefits.[228]
The CLA pointed out that food prices were likely to rise
in future meaning that farmers would need to be paid more to compensate
them for taking part in agri-environment schemes.[229]
140. Unsurprisingly, farming groups expressed
more reservations about 'greening' the CAP than environmental
groups. The TFA were concerned that the Commission's proposals
could have adverse effects on food security and said "with
the extent of cross compliance conditions imposed on farmers within
the UK context that there is no scope for further greening of
Pillar 1".[230]
The CLA supported a moderate shift towards better and clearer
public goods provision, while warning of "a very real danger
that we could overload our producers, impeding their economic
competitiveness and thus sustainability".[231]
The NFU agreed with the past trend to enhance support for public
goods, while expressing concern that "in driving farmers
into more environmental conditionality, the proposals could undermine
agricultural productivity".[232]
141. However, we heard that targeting more of
the available funding on sustainability does not have to come
at the cost of competitiveness or food production. Several witnesses
described potential 'win-wins'. The AHDB said the majority of
evidence suggested that farms that were more efficiently run in
terms of energy use would produce fewer greenhouse gas emissions
as well as being more economically competitive.[233]
'Precision farming', for example the use of sensors on tractors
to determine exactly where fertiliser is needed, has the potential
to deliver productivity and sustainability through reducing inputs.
However, these high technology solutions are expensive. Reduced
availability of chemical pesticides as a consequence of the shift
from risk-based to hazard-based assessment is also likely to require
the development and implementation of new pest-control techniques.[234]
142. For the UK, protecting our capacity to produce
food is an essential part of our future food security. Similarly,
the Foresight Global Food and Farming Futures project concluded
that addressing the sustainability of food production globally
was urgently needed in order to meet future food supply challenges.
Therefore, while we recognise the concerns of farming groups that
'greening' might reduce their competitiveness or ability to produce
food, we believe that this should not discourage the Commission.
The reformed CAP should encourage farmers to produce more while
having less impact on the environment (sustainable intensification)
as this is in the long-term interest of EU farmers and EU citizens.
Investment is needed to encourage the sort of transformational
changes required and there is a clear role for the CAP in providing
this.
143. We agree that the CAP post-2013
should target more of the available funding on incentivising sustainable
farming. However, 'sustainable farming' should not be synonymous
with simply 'not farming': it is essential that ways are found
to farm more productively while minimising inputs and reducing
negative impacts on the environment. We recommend that any 'greening'
of the CAP should be directed at activities that promote sustainability
alongside competitiveness.
The Commission's proposals to
'green' Pillar 1
144. While the Commission's intention to gently
rebalance the CAP in favour of environmental benefits was broadly
supported, we heard mixed views as to whether this 'greening'
should be carried out in Pillar 1, or Pillar 2.
145. The Commission has suggested a "compulsory
additional aid for specific 'greening' public goods through simple,
generalised, annual and non-contractual agri-environmental actions
based on the supplementary costs for carrying out these actions"
in Pillar 1.[235] Suggested
agri-environmental activities included crop rotation, ecological
set-aside and maintaining permanent pasture. The Commissioner
explained that the rationale for including these measures in Pillar
1 is that it would be mandatory for Member States to offer the
measures resulting in a higher level of production of public goods
than if the measures were voluntary.[236]
The Commissioner suggested that these top-ups would have a value
of up to one-third of the direct payment.[237]
146. 'Top-up' payments in Pillar 1 were also
recommended by the European Parliament's Resolution on the Future
of the CAP after 2013 and the Pack inquiry into Future Support
for Agriculture in Scotland.[238]
The European Parliament resolution said top-ups to Pillar 1 should
explicitly reward farmers for reducing their greenhouse gas emissions
or increasing carbon sequestration, while agri-environment activities
should be paid for in Pillar 2.[239]
147. The alternative to the Commission's proposals
is to transfer more of the overall budget into Pillar 2 in order
to fund a greater deployment of the existing agri-environment
schemes. Defra favour the option of greening the CAP through a
greater focus on Pillar 2 agri-environment schemes while also
phasing out direct payments in Pillar 1.[240]
A draft report by Albert Dess MEP for the European Parliament
also recommended that greening be carried out using the existing
Pillar 2 measures. However, in contrast to Defra, Mr Dess suggested
that the additional measures be entirely EU-financed and that
they would be funded by reducing farmers' direct payments unless
they implemented at least two agri-environment measures.[241]
This proposal is being considered by the European Parliament Agriculture
and Rural Development Committee.
148. The Commission's proposals to green Pillar
1 did not receive strong support from any of our witnesses. There
is a general concern that the Commission's proposals will make
the CAP more complicated to administer and would confuse the logic
of the two Pillar structure (because agri-environment activities
are currently in Pillar 2).[242]
Some farming groups felt that compulsory agri-environmental measures
in Pillar 1 risked reducing the competitiveness of farm businesses
through adding burdensome regulations and undermining farmers'
ability to make business decisions.[243]
The TFA were also concerned they would have a negative effect
on food production at a time when the prevailing messages are
that EU agriculture will need to increase its food production
capacity.[244]
149. The RSPB and CPRE felt that the Commission's
proposals did not go far enough as too few measures were linked
to environmental delivery and risked being merely a 'greenwash'.[245]
Defra agreed with this position, stating that greening Pillar
1 is "is unlikely to deliver significantly greater or more
ambitious environmental benefits" than the current programmes.[246]
The NFU said "there can be no assumption that generalised
measures will bring tangible environmental benefits".[247]
The CLA were the most supportive of the Commission's ideas,
arguing that "broad-brush environmental conditions that should
apply to most farming" could move to Pillar 1 and "higher
level and more regionally adapted environment schemes" remain
in Pillar 2.[248]
150. Several witnesses also expressed concern
about expanding Pillar 2, which is Defra's alternative to greening
Pillar 1. The central issue appears to be the difficulty of achieving
political support in Europe as expanding Pillar 2 would mean greater
financial contributions from Member States (because Pillar 2 is
co-financed). The CLA said:
The problem with shifting the policy to Pillar 2
[...] was that the opportunity was offered to the Member States
with voluntary modulation, and all but the UK ignored it because
they didn't want to put any additional money into matched funding,
into the co-financing. So, whilst we might be in principle in
favour of co-financed Pillar 2 measures, the political reality
is that there isn't the money to do it.[249]
George Lyon MEP, speaking at the 2011 Oxford Farming
Conference, agreed that Member States were more likely to embrace
greening if it was entirely funded through Pillar 1.[250]
Brian Pack warned that expanding Pillar 2 risked creating a "very
uncommon market" because "new Member States cannot afford
their share of the finance; therefore, they can't draw down the
European money".[251]
151. Defra's ambition to rebalance the CAP budget
in favour of Pillar 2 would have implications for the UK Exchequer
because the UK will have to co-finance any increased EU spend
on Pillar 2. If a large proportion of the current Pillar 1 budget
were to be shifted in to Pillar 2, UK spending on agriculture
and the environment would increase significantly compared to its
current levels. When we questioned Defra on this, their response
was "we shall be seeking to strike the right balance between
a Pillar 2 budget which will deliver the required outcomes at
best value for money and which will be affordable for the taxpayer".[252]
We are not convinced that Defra has fully considered how their
aim to shift most of the CAP budget into Pillar 2 is to be afforded.
152. Strengthening Pillar 2 is not necessarily
consistent with the simplification agenda. The CLA and NFU argued
that Pillar 2 environmental stewardship payments are more complicated
and expensive to administer than direct payments. According to
Defra, environmental stewardship schemes are cheaper to administer
than direct payments: the cost of administering an environmental
stewardship scheme payment in England is £700 per claimant
while the cost of administering an SPS claim in England is £850
per claimant.[253]
It should be borne in mind however that the cost per claimant
of administering the SPS in Scotland is only £300.[254]
153. It appears that neither the Commission's
proposals nor Defra's alternative offer a universally acceptable
solution to greening the CAP. The decision between greening Pillar
1 and expanding agri-environment schemes in Pillar 2 must be made
on the basis of which policy will be the most effective and simple
to implement, tempered with a consideration of the political realities.
The evidence that we received suggested a number of criteria against
which proposals to green the CAP must be considered.
154. The proposed additional greening measures
must deliver tangible benefits: they must be ambitious and challenging
or else they risk losing credibility and accusations of 'green-wash'.
Measures should focus on farming more sustainably, for example,
using fewer inputs of chemicals, energy and water or helping biodiversity
to co-exist with farming. 'Greening' through taking land out of
production alone is not conducive to meeting future food supply
challenges or reducing farmers' reliance on direct payments. A
commitment from farmers to carry out measures over multiple years
may deliver more environmental benefits than annual schemes.[255]
155. Uptake of the scheme should be common across
all Member States, as much as possible. The current framework
of Pillar 2 results in significant variation between Member States
in the type of activities that are funded (Figure 3). This creates
competitive distortion where some payments directly increase farmers'
competitiveness (Axis 1) while others are broadly neutral or mildly
deleterious (Axis 2).
156. One solution would be to make agri-environment
measures compulsory. However this is likely to be perceived by
farmers as just an extension of cross-compliance, which risks
reducing farmers' engagement in the process and undermining voluntary
efforts such as the Campaign for the Farmed Environment.[256]
Providing farmers with incentives to implement agri-environmental
measures would be preferable to more regulation. Reducing the
level of direct payments is one way to make agri-environment schemes
more attractive to farmers. The take-up of environmental stewardship
in England (almost 70% of available land is in an agri-environment
scheme) suggests this approach could be successful.[257]
157. We suggest there is a strong case for full
EU-funding of additional EU-wide greening measures, not Member
State co-financing. Co-financing is advantageous in that it encourages
financial discipline on the part of Member States.[258]
However, as co-financing is a direct cost to Member States they
are naturally less willing to take-up these measures.[259]
EU-financing of EU-wide agri-environment measures would break
the negative associations with Pillar 2 agri-environmental schemes,
thus increasing take-up. There would be budgetary implications
of this change as Member States would be required to increase
their EU contributions (while national contributions would fall).
Reducing the level of direct payments would counteract this to
some extent however fuller analysis can only be made in light
of the entire post-2013 EU budget.
158. Any new greening proposals must be compatible
with the UK's current agri-environment programmes so that UK farmers
that have already joined these programmes are not penalised.[260]
Additional green measures should not generate undue administrative
burdens, for farmers or governments. The CLA's proposals for multi-annual,
outcome-based contracts might offer a way to do this.[261]
159. The Commission's proposals to green Pillar
1 through compulsory additional annual agri-environmental activities
have failed to win support from UK interested parties.
Defra should not support the Commission's current proposals for
greening Pillar 1 as they risk reducing the competitiveness of
UK farming and increasing the complexity of the CAP while not
delivering an improved environmental performance.
160. We recommend that additional
greening measures bear many of the characteristics of Pillar 2
agri-environment schemes, namely voluntary for farmers, incentives
rather than regulation, and multi-annual. The design of the additional
measures is crucial to the success of the scheme and the guiding
principle must be to mainstream sustainability into successful,
competitive agriculture. We believe that EU-wide buy-in is more
likely if these additional greening measures are entirely EU-financed.
Funding them from the existing Pillar 1 budget is one way to maintain
budgetary discipline while incentivising farmers to implement
the additional measures.
161. The European Parliament's draft report on
the Commission's Communication was published after we had finished
taking evidence,[262]
and has not been agreed by the European Parliament Agriculture
and Rural Development Committee. We have not examined it in detail,
but their ideas for greening the CAP appear to chime with many
of our recommendations above.
162. We encourage Defra to analyse
the impact on the UK were the Commission to take forward the innovative
ideas in the European Parliament Agriculture and Rural Development
Committee's draft report for greening the CAP through EU-financed
agri-environmental measures in Pillar 2, incentivised by reductions
to farmers' direct payments if they do not adopt some of the measures.
221 Q 187 Back
222
European Parliament resolution of 8 July 2010 on the future of
the Common Agricultural Policy after 2013, TA(2010)0286), para
53;The Scottish Government, The Road Ahead for Scotland: Final
Report of the inquiry into Future Support for Agriculture in Scotland,
Chairman Brian Pack OBE, November 2010, p 66-68. Back
223
Council of the European Union, Presidency conclusions on the
communication from the Commission: The CAP towards 2020: meeting
the food, natural resources and territorial challenges of the
future, p 3. Back
224
Ev 106 Back
225
Ev 109 Back
226
Ev w4 Back
227
Q 276 Back
228
For example the Land Use Policy Group (LUPG)'s study Estimating
the scale of future environmental and land management for the
UK (December 2009) examined the costs of farmers providing
the desired environmental services in the UK. The conclusions
of this research were that the costs were approximately three
times greater than the current UK expenditure on delivering public
goods through environment schemes, i.e. about £1.98bn compared
to about £700m on agri-environment. The Lawton report, Making
Space for Nature (September 2010) estimated the cost of establishing
a 'coherent and resilient' network of biodiversity reserves as
£600m to £1.1bn. Back
229
Q 78, Q 96. Farmers' payment for taking part in agri-environment
schemes is based on the estimated 'income foregone' through carrying
out the activity. For example, the income foregone through establishing
a field margin would be the lost area that could be cropped. If
food prices increase in future, due to rising demand, the income
foregone will also increase. Back
230
Ev 110 Back
231
Ev 115 Back
232
Ev 120 Back
233
Q 355 Back
234
Regulation (EC) No 1107/2009 of the European Parliament and of
the Council of 21 October 2009 concerning the placing of plant
protection products on the market and repealing Council Directives
79/117/EEC and 91/414/EEC. Back
235
The CAP towards 2020, p 14. Back
236
Q 187-188 Back
237
Q 187, 189 Back
238
Final Report of the inquiry into Future Support for Agriculture
in Scotland, p 76. Back
239
European Parliament resolution of 8 July 2010 on the future of
the Common Agricultural Policy after 2013 (TA(2010)0286), para
73; Q 318, 319. Back
240
Defra, UK Response to the Commission Communication and Consultation:
"The CAP towards 2020: Meeting the food, natural resources
and territorial challenges of the future", January 2011,
p 3. Back
241
Draft Report: the CAP towards 2020: meeting the food, natural
resources and territorial challenges of the future, PE458.545v02-00,
Rapporteur Albert Dess MEP, 15 February 2011,para 22. Back
242
See the Welsh Assembly Goverment (Ev w30), the Farmers' Union
of Wales (Ev w47),the NFU (Q 128) and the Minister (Q 471). The
Agriculture and Fisheries Council also "underlines that any
further greening should be simple and cost-effective, avoid any
overlap between pillars and must be based upon the experience
of the CAP's current green policy measures", implying that
they also disagree with the proposed greening of Pillar 1 (Presidency
conclusions on the communication from the Commission: The CAP
towards 2020: meeting the food, natural resources and territorial
challenges of the future, p 3). Back
243
For example, the TFA said "with the extent of cross compliance
conditions imposed on farmers within the UK context that there
is no scope for further greening of Pillar 1". (Ev 110).
The NFU said the proposal to 'green' a component of direct payments
could result in less market focus (Ev 120) and could be "incredibly
complicated" and "anti-competitive" (Q 153). The
NFU highlighted their concerns about each of the Commission's
four suggested agri-environmental activities in Ev 122-123. Back
244
The TFA said "There is a real danger that in developing the
concept of 'eco-system services' we overegg the pudding with environmental
measures without properly balancing the needs of food security"
(Ev 111). Back
245
Ev w2, Q 18-19 Back
246
UK Response to the Commission Communication and Consultation:
"The CAP towards 2020: Meeting the food, natural resources
and territorial challenges of the future", p 7. Back
247
Ev 123 Back
248
Q 107, Q 115 Back
249
Q 93 Back
250
"Mixed views over 'green top-up' plans for CAP P1",
Agra Europe, 14 January 2011. Back
251
Q 349 Back
252
Ev 177 Back
253
Ev 176 Back
254
National Audit Office, A Second Progress Update on the Administration
of the Single Payment Scheme by the Rural Payments Agency,
October 2009. Back
255
See the CLA (Q 111-112) and UK Research Councils' Rural Economy
and Land Use Programme (RELU) (Ev w5). Back
256
See for example the NFU (Ev 121), the CLA (Q 95) and George Lyon
MEP (Q 316). Academic studies into farmers' engagement with agri-environment
schemes have supported this view for example, a study into German
arable farmers' views of ecological set aside concluded "the
voluntary aspect of the nature-conservation concept (as a future
agri-environmental programme) is highly valued by the farmers
and contributes to their acceptance of the concept"(Siebert
et al., Assessing German farmers' attitudes regarding nature
conservation set-aside in regions dominated by arable farming,
Journal of Nature Conservation, 2010). Back
257
Natural England, Environmental Stewardship Update June
2010. 69.5% of England's utilisable agricultural area (UAA) was
in an agri-environment scheme in May 2010. Natural England's target
was for 70% of UAA to be in an agri-environment scheme by March
2011. Back
258
Ev 177 Back
259
This issue is discussed further in the DG IPOL study for the European
Parliament, Direct Payments in the CAP post 2013, 2009,
p 97. Back
260
See the NFU (Ev 121), the CLA (Ev 117) and the Welsh Assembly
Government (Ev w32). Back
261
Ev 117 Back
262
Draft Report: the CAP towards 2020: meeting the food, natural
resources and territorial challenges of the future, PE458.545v02-00,
Rapporteur Albert Dess MEP, 15 February 2011. Back
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