Written evidence submitted by The Royal
Society for the Protection of Birds (RSPB)
1. The RSPB welcomes the opportunity to
respond to the EFRA committee's enquiry into the European Commission's
proposals for CAP reform after 2013.
EXECUTIVE SUMMARY
2. The current CAP reform round offers a
clear opportunity to realign the policy with societal expectations
and respond to a suite of environmental challenges.
3. The CAP must build on previous positive
reforms to tackle challenges of sustainable land management, long
term food-security and farm business competitiveness by evolving
into a policy underpinned by a "public money for public goods"
approach.
4. The European Commission proposals for
reform contain some positive elements but still fail to present
a clear vision for the future of the CAP.
OVERARCHING COMMENTS
5. The RSPB has a long history of involvement
in CAP reform. We have been instrumental in the development of
agri-environmental schemes, and Environmental Stewardship in particular,
and making the case for a transfer of funds, and policy emphasis,
from Pillar 1 to Pillar 2.
6. In run up to the current reform period,
we have joined forces with a range of environmental and farming
stakeholders to call for a shift to sustainable land management[1],
set out principles for a new policy[2]
and make specific proposals for the CAP after 2013[3].
7. Recent CAP reforms have contained some
positive elements, particularly the creation of a second pillar,
decoupling of subsidies from production and cross compliance.
8. Many of these changes signalled a shift
away from outdated support mechanisms, with decoupling in particular
introduced as a transitional process. The destination urgently
needs to be spelled out. Without a clear route map, farmers are
poorly equipped to make the necessary business adjustments and
are less likely to "buy-in" to the reform process.
9. Whilst there is room for simplifying
all elements of the policy, both to reduce bureaucratic burden
for landowners and to improve the policy's efficiency, there must
be no erosion of principles which improve the accountability of
the policy for citizens.
10. To meet future challenges, we propose that
the CAP needs to help underpin global food security, enable farmers
to run profitable and market-focussed business, propel a rapid
transition towards more sustainable land management and reward
the provision of environmental public goods where these are underprovided.
11. Direct payments are a wasteful and inefficient
way of doing this - indeed, a recent study[4]
suggests the Single Payment Scheme is impeding moves in this direction.
The SPS does not encourage farmers to take a long term view, it
is not linked to public goods nor is it securing sustainable land
management - and studies suggest it has little impact on food
production. Therefore what is it for?
12. We want to see a phasing out of the current
SPS system. This would provide an opportunity to temporarily target
a proportion of CAP support toward measures which boost the competitiveness
of farming in a non-environmentally damaging way eg improving
farming's return from the food chain through added value products,
savings through resource efficiency etc; along with the ongoing
support to farming for environmental public goods.
13. Improved resources for Rural Development
and a re-focussing of support towards environmental and climate
change objectives, if implemented soundly, would go a significant
way to addressing issues of resource degradation and biodiversity
loss in Europe. A retargeting of support towards environmental
objectives would also need to address the pressing issue of High
Nature Value farming, which is in rapid decline in much of the
EU, and the Natura 2000 network of protected sites, many of which
depend of sensitive farming methods.
14. Well designed and funded environmental support
schemes must form a key component of the CAP after 2013 and the
success of agri-environment schemes in the UK needs to be built
on in the future CAP. The vast majority of land in England is
now in an agri-environment scheme, and by committing to provide
public goods in this way farmers can guarantee a basic level of
income over five years, providing a degree of security against
volatility without becoming dependent on income support.
THE COMMISSION
OPTIONS FOR
REFORM
15. At present, none of the options presented
by the Commission provide a vision for the future of farming and
land management in Europe or a clear set of reform objectives
for the CAP.
16. Option 1 suggests little more than a further
"Health Check" of the CAP and as such would fail to
respond to societal expectations for reform or to address the
suite of challenges facing the farming sector. The UK government
should strive to ensure this limited reform option is rejected
during forthcoming negotiations.
17. Option 2 contains some positive steps towards
greening of the CAP, particularly the new and compulsory greening
payment under Pillar 1, which is conditional on some potentially
beneficial management approaches such as crop rotation and fallow
land. However, despite some environmental improvements, the majority
of payments and support structures proposed under Option 2 have
dubious rationale. Four of the five direct payments proposed have
no environmental dimension beyond cross compliance and the payments
proposed for small farmers, marginal areas and coupled support
could be implemented across the EU in ways which negatively impact
the environment and UK competitiveness.
18. We believe that the Commission's Option 3
for reform, which is explained in more detail in the Commission's
impact assessment document[5],
has considerable, but as yet untapped, potential to provide
a clear, justifiable and sustainable vision for CAP reform. This
could be achieved through a transitional phase out of the SPS
systems with improved support for EU farming competitiveness and
a "public money for public goods" approach underpinning
all payments.
19. The current reform period offers a golden
opportunity to reorient the CAP and clarify its objectives. If
this is not grasped, not only will the opportunity to realign
the policy with societal expectations be missed, the likely €200
billion in CAP payments to 2020 could also be wasted.
THE BALANCE
BETWEEN PRODUCTIVITY,
COMPETITIVENESS AND
SUSTAINABILITY
20. At a recent address to the European Parliament[6],
Agriculture Commissioner Ciolos made it clear that the concept
of agricultural competitiveness must be updated to end the "false
conflict" with sustainability. Clear economic signals must
be given to farmers to fully integrate the environment into their
activities. These words are a positive indication that genuine
greening of the CAP is being considered by the Commission as part
of the Lisbon agenda.
21. Any CAP reform scenario that is not explicitly
linked to environmental public good delivery and improved sustainability
would not only represent a missed opportunity to tackle environmental
degradation across the EU but could also threaten UK competitiveness
by allowing Member States to target support at domestic sectors
or re-couple support within their borders. This would run counter
to the common aspect of the CAP, erode the level playing field
for farmers, and could even produce negative consequences if intensive
sectors are targeted for support.
22. Globally, EU agriculture needs to focus on
competitive advantage in high value and added value products.
The UK, as part of the EU, should further develop this competitive
advantage, part of which is the appeal of products from systems
with higher environmental standards eg organic, LEAF marque and
Conservation Grade. The delivery of environmental public goods
must be seen as a key part of UK agricultural competitiveness
and not a burden or incidental by-product.
THE MOVE
AWAY FROM
THE HISTORIC
TARGETING OF
PAYMENTS
23. The distribution of the considerable CAP
budget must be viewed objectively. We must move beyond the view
of many Member States that "who gets what" is the most
important issue. Instead, it is the issue of "who gets what
for what" that the next CAP must address.
24. There is a clear case for policy intervention,
through the CAP, to secure environmental delivery due to the market
failure to reward many environmental public goods. The CAP must
target support at the systems of farming which deliver high levels
of environmental benefit (such as High Nature Value farming) and
facilitate the uptake of more sustainable farming practices (including
agri-environment schemes).
25. A 2009 report[7]
produced for the Land Use Policy Group estimated that £1-3
billion would be required each year to meet publicly defined environmental
objectives through agri- environment schemes in the UK. This is
considerably less than the current Pillar 2 allocation for the
UK but comparable to the CAP allocation as a whole.
THE ROLE
AND VALUE
OF CAP PAYMENTS
IN ADDRESSING
FUTURE FOOD
SUPPLY CHALLENGES
26. The 2009 "Scenar 2020" study[8]
identified that in the absence of direct payments, food production
in the EU would actually increase. There is no explicit food production
link (perhaps unsurprising given the decoupling of payments as
part of the 2003 CAP reforms) and therefore any argument that
direct payments contribute to EU and global food security by underpinning
farming is incorrect.
27. Food security is a critical issue but at
core rests upon the long-term productive capability of EU farming
through protection and enhancement of natural resources - a sentiment
shared by a recent Institute for European Environmental Policy
study[9].
This justifies a shift away from untargeted direct payments in
the CAP to payments in return for environmental public good delivery.
28. A recent LUPG report[10]
highlights the "added-value" of a common EU policy to
tackle environment issues and justifies reforming the CAP along
such lines.
TIME-SCALE
FOR REFORM
29. The RSPB is calling for fundamental CAP reform
but we recognise there must be a sensible transition period for
farmers. Unfortunately, the Commission document fails to articulate
a transitional period as there is no clear picture of what the
CAP will ultimately evolve into.
30. Farmers and land managers must have a clear
direction of travel in order to make the necessary business adjustments
and ensure sufficient "buy-in".
31. There is an urgent need for more clarity
and ambition from the Commission and for Defra to launch a renewed
vision for CAP reform to energise the debate.
December 2010
1 Beyond the Pillars: Wildlife and Countryside Link's
policy perspective on the future of the CAP (2008) Back
2
Proposals for the future CAP: a
joint position from the European Landowners' Organization and
BirdLife International (2009) Back
3
Proposal for a new EU Common Agricultural Policy (2010) BirdLife
International, European Environmental Bureau, European Forum on
Nature Conservation and Pastoralism, International Federation
of Organic Agriculture Movements- EU Group and WWF - World Wide
Fund for Nature. Back
4
Report for the European Parliament's Committee on Agriculture
and Rural Development (2010) The Single Payment Scheme after 2013:
New approach-New targets. IP/B/AGRI/IC/2009_038 Back
5
European Commission The reform of the CAP towards 2020: Consultation
document for impact assessment Back
6
Réformer la Politique Agricole Commune, c'est faire un
choix de Société. Discours à la Commission
de l'Agriculture et du Développement rural du Parlement
Européen Bruxelles, le 18 novembre 2010 Back
7
CAO et al (2009) Estimating the Scale of Future Environmental
Land Management Requirements for the UK. Report to the Land Use
Policy Group. ADAS UK Ltd and Scottish Agricultural College. Back
8
Nowicki et al (2009) Scenar 2020-II - Update of Analysis of Prospects
in the Scenar 2020 Study - Contract No. 30-CE-0200286/00-21. European
Commission, Directorate-General Agriculture and Rural Development,
Brussels. Back
9
Cooper, T, Hart, K, and Baldock, D. (2009) The provision of public
goods through agriculture in the European Union. Report prepared
for DG Agriculture and Rural Development. Institute for European
Environmental Policy, London Back
10
Tamsin Cooper, Håkon By and Matt Rayment (2010) Developing
a More Comprehensive Rationale for EU Funding for the
Environment. Paper prepared by IEEP
for the Land Use Policy Group Back
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