Greening the Common Agricultural Policy

Written evidence submitted by Professor Nic Lampkin, Director of the Organic Research Centre, and Visiting Professor, University of Reading, School of Agriculture Policy and Development (GCAP 18)

 

Context to our evidence

The Organic Research Centre is the UK’s leading independent research centre focusing on the development of organic/agro-ecological approaches to the delivery of sustainable food systems. Further information on the Centre can be found at www.organicresearchcentre.com

Prof. Nic Lampkin is an agricultural economist who has been involved with several EU-funded research projects on European rural development, agri-environment and organic farming policies, has been engaged with the development, implementation and evaluation of organic farming action plans at European, English and Welsh levels. Most recently, he has been part of a team reviewing European organic farming policies for the European Commission, the final report for which was submitted in November 2011. He is the Organic Research Centre’s lead person on CAP reform issues, further information on which can be found under the Policy and Debates section of the ORC website.

Greening of the CAP – ensuring environmental gains

The EFRA Committee asks whether the proposal to green direct payments will generate significant environmental benefits.

We believe that the payments to farmers under Pillar 1 need to address both socio-economic issues such as income levels and income security in agriculture and the delivery of environmental, animal welfare and other public goods to benefit society in general. The greening proposals represent a first step in this direction and should be encouraged and developed in a way that delivers genuine environmental benefits while not imposing excessive administrative burdens and transaction costs on producers or society. We recognise that there will be a need for trade-offs and simplification to achieve this, but there is room for improvement to ensure real delivery is achieved and protected.

Of the specific greening proposals:

· The protection of permanent grassland is to be welcomed, but there is a need to recognise that there is already an Environmental Impact Assessment requirement where permanent grassland is to be cultivated and the use of this protection should be emphasised. If the statistical definition of permanent grassland as grassland of more than five years age is retained, there are many UK production systems which involve 7-10 year grass leys and periodic breaks with cereal and root crops, which contribute positively to biodiversity. There is a need to ensure such systems are not inadvertently discouraged by this measure. There is also a need to ensure that setting a future base year such as 2014 doesn’t lead to farmers ploughing up grassland, including high value grassland, before then in a bid to circumvent the requirements.

· Cropping diversity is also worthy of encouragement – our work on organic/agro-ecological approaches, including agroforestry, makes clear that crop diversity can make a strong contribution to enhancing biodiversity and the delivery of ecosystem services, including building soil fertility, protecting crops from pests and diseases, and supporting bees and other pollinators essential for crop fertilisation. We believe the requirements need to be strengthened on this, to include a compulsory requirement for leguminous crops that contribute to biological nitrogen and carbon fixation as well as pollination services. The bureaucratic aspect can be moderated as areas allocated can be monitored through the annual single payment returns (although England does not currently collect individual crop data, fields are separately identified in the single payment returns and their utilisation can be reported with only limited additional administrative burdens.

· Ecological focus areas also have significant potential environmental benefits, as the Swiss experience has demonstrated. Our understanding is that these areas are not to be derived specifically from cropped land, and that they can include various non-crop habitats commonly found on farms, including hedges, trees, uncropped field margins (currently being encouraged as part of the Campaign for the Farmed Environment). It is important however, that farmers’ previous efforts to establish uncropped habitats under ES and other agri-environmental schemes are recognised as valid contributions to the threshold, and that the greening ecological focus areas are not imposed as an added requirement to areas already being delivered. There is also a need to ensure that the ecological focus areas are distributed close to cropland, so that on larger farms with large fields, we don’t end up with mini nature reserves surrounded by a cropped biodiversity desert with no inter-connections. We consider 7%, the level also applied in Switzerland, to be an acceptable compromise, with 5% delivering only modest benefits, while 10% would be challenging for farms in regions where hedgerow and other wood habitats are currently limited. Administratively, these areas may be more difficult to measure and record, but many are already recorded, for example sown mixtures to support wild bird populations.

· Organic farming is the fourth key element of the Greening proposals. From the organic sector’s point of view, this is a welcome development, reflecting the fact that there are significant environmental benefits from organic land management, which are also acknowledged by the European Court of Auditors and the UK’s National Audit Office. In biodiversity terms, the benefits are found within the crops as well as in field margins, so the emphasis on ecological focus areas to compensate for low biodiversity in cropped land is less relevant, while crop diversity, in particular the use of legume-based grass leys to build soil fertility and organic matter, and the maintenance of permanent grassland, is a standard part of organic management. Therefore the proposed automatic qualification for the Greening top-up is fully justified. In administrative terms, organic farming is regulated by specific EU legislation and there is a already control system in place, so there is no additional legislative or administrative requirement to implement this. However, there is a need to ensure that there are no conflicts between this greening element and Pillar 2 measures.

Given that the environmental benefits relate to land, and not to farm size, we support the Commission’s view that the greening element should not be subject to capping.

Impact on food production and competitiveness

The EFRA committee asks whether there will be any impacts of the additional greening requirements on food production and the competitiveness of the agricultural industry.

We believe the impacts have been overstated in the recent debates, and that they are likely to be insignificant. The permanent grassland element relates to current grassland areas and does not involve conversion of cropland to permanent grassland. The crop diversification element does not preclude production (or intensification) of crops that are needed for both human and livestock consumption. Our proposal that legumes should form part of the diversification requirement can include grain legumes as well as forage legumes that contribute to livestock dietary requirements and may substitute for feeds currently imported. The ecological focus area requirements are likely to be met substantially by existing areas on farms, particular if areas that have been created through agri-environment scheme participation are included (with 70% of English land now registered in Environmental Stewardship ELS and the apparent commitment of producers to support the voluntary environmental set-aside element Campaign for the Farmed Environment).

Consistency with simplification

The EFRA committee asks whether of the greening proposals are consistent with the CAP simplification agenda.

Clearly the inclusion of the greening element complicates the current Single Payment scheme arrangements, and therefore can be argued to be in conflict with the simplification agenda. However, this needs to be considered alongside the reduction in cross-compliance requirements and the limited inclusion of elements in the greening proposals to ones that are relatively easy to monitor.

Coherency with other agri-environment schemes

The EFRA committee asks how greening pillar 1 can be made coherent with agri-environment schemes.

We believe there are two key elements to this:

1. The greening elements should include recognition of agri-environmental activities that have been undertaken as part of meeting the targets, particularly with respect to the ecological focus areas. They should not be imposed as an additional requirement. However, while some are arguing that all agri-environment agreement holders should automatically qualify for the greening element, we would not support this as in some cases the agreements only provide for relatively limited agri-environmental outputs.

2. We are however concerned that the income foregone calculations for agri-environment and organic farming schemes could be adversely affected if an inappropriate assumption is made about whether or not farmers are qualifying for the greening element. We believe the standard assumption for making the income foregone calculation should be that farmers are already qualifying for the greening elements before making new commitments to entering these schemes.

Recommendations for improvement

The EFRA committee asks for recommendations for improving the greening proposals.

We have addressed this question as part of our response to the first question on the environmental benefits of the greening proposals.

Other CAP Reform issues

The EFRA Committee has indicated that it welcomes interested parties’ views on other elements of the CAP proposals.

We have identified a number of key issues via our CAP Reform web page under Policy and Debates at www.organicresearchcentre.com while a number of very specific recommendations relating to organic farming are contained in our report to the European Commission, which has not yet been released for publication. While we could address a large range of issues, many of which will not doubt be picked up by other organisations, we would like to emphasise the following points here:

· Sufficient funding should be secured for land management programmes in the 2nd pillar budget, including a fairer share of the EU total for the UK and by ring-fencing a larger share (>50%) of the rural development programmes’ budget for measures that deliver to environmental objectives including organic farming.

· Consideration needs to be given to how the wide variation in organic farming support levels between member states (including no support at all) can be moderated to reduce the potential impacts on the single market, given the key importance of the organic market in underpinning the environmental benefits from organic land management. This is particularly relevant for the UK, which has the lowest levels of organic support payments in the EU (see Figure). Greater consistency could be achieved by making the RDP organic farming measure mandatory on a similar basis to other agri-environment schemes and/or by including the organic farming measure in the group of RDP measures eligible for higher levels of co-financing, so that member state budget constraints are less of a factor influencing the support levels implemented.

· There is a need to ensure more effective exploitation of synergies between rural development measures, and in particular between the agri-environmental, organic farming and other land management measures and the farm advisory service, knowledge transfer and innovation measures. We would like to see specific cross-referencing of this in the regulation, but also a requirement for the question of synergies between measures to be addressed specifically in rural development plans. This is particularly the case for the organic farming measure, which also interacts significantly with the more market focused measures formerly in Axes 1, 3 and 4.

· We would like to see the UK place more emphasis on agroforestry options than was the case in 2007-2013. We have reviewed both the potential of agroforestry to deliver increased productivity and ecosystem services, and the policy support currently in place, and it is clear that it is worth supporting and much more needs to be done. For further information, please see: http://www.organicresearchcentre.com/?go=Research and development&page=Eco-agroforestry.

16 November 2011