13 Conclusion on the Commission's
Three Options
229. Although the Commission outlines three options
for the CAP post-2013, it appears to us that these do not represent
a genuine choice.
230. Maintaining the status quo as outlined in
Option 1 is undesirable as the historic system of payments cannot
be continued to 2020 without severely compromising the relevance
of the CAP and entrenching distortions between Member States.
Moreover the future CAP must place greater emphasis on sustainability
alongside productivity, reducing the adverse effects of farming
on the environment and making a positive contribution to achieving
the EU's targets on climate change and biodiversity. Equally,
abolition of direct payments and market measures as suggested
in Option 3 is clearly not advisable in the period to 2020 given
farmers' dependence on income support and trade protection, nor
is this option likely to win support in the European Council or
Parliament.
231. However, this does not mean we should accept
the middle way, Option 2, as it stands. While we support the principle
behind greening Pillar 1, we are concerned that the proposed system
of multi-tiered payments will be complex to administer and risks
adding additional layers of regulation for fairly marginal environmental
benefit. We recommend that the Commission instead look at greening
the CAP through the existing structures in Pillar 2 backed up
by strengthened incentives and targets to ensure uptake is achieved
widely across Europe.
232. We have expressed several additional reservations
about the proposals for direct payments. We consider that capping
direct payments and giving additional financial support to small
farmers would be disadvantageous to UK producers and would not
enhance agricultural competitiveness. We question the value of
a new definition of an active farmer that could generate additional
administrative burdens. However, we welcome some aspects of Option
2, including the commitment to a more equitable distribution of
Pillar 1 and Pillar 2 funding and strengthening of knowledge transfer
instruments.
233. We believe that the Commission's
Option 2 offers the most benefits to UK farmers, rural communities
and the agri-food industry. However we have reservations about
some of their ideas, in particular, 'greening' Pillar 1 through
compulsory additional agri-environmental measures. We recommend
that Defra offers its support to Option 2 while working proactively
in Europe to negotiate changes to some aspects of the proposals
and explore additional options for 'greening' the CAP, as outlined
in our recommendations.
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