Greening the Common Agricultural Policy

Written evidence submitted by The Royal Society for the Protection of Birds (RSPB) (GCAP 21)

The RSPB welcomes the opportunity to respond to the EFRA Committee’s inquiry into the European Commission’s proposals to ‘green’ the Common Agricultural Policy.

Executive summary


1. There is an urgent need to expend more attention and funding on the natural environment in the context of EU agriculture.

2. While the focus on ‘greening’ has largely centred on the Commission’s proposals for new measures under Pillar 1, existing CAP mechanisms must also be addressed. Agri-environment should have a central and growing role; cross compliance must be improved; and gaps in funding the CAP provides for environmental delivery must be addressed.

3. The extent to which the greening proposals will improve the status quo is limited – a missed opportunity to support EU farming to become more environmentally and economically sustainable.

4. Each of the proposed measures must be designed so they deliver genuine environmental benefits.

· Ecological Focus Areas have significant potential to benefit the farmed environment, but must only include features or land uses which are genuinely environmentally beneficial. Positive management of EFAs should be encouraged through agri-environment schemes.

· Permanent pastures of high environmental value urgently need proper protection and support. However, the current proposals could actually incentivise their destruction. The current definition of permanent pasture fails to distinguish between intensive grass crops and extensively managed grasslands of the highest environmental value. The proposed reference year of 2014 may incentivise landowners to cultivate their pasture before this date. The RSPB instead calls for a Pillar 1 premium to provide support for extensively managed pasture.

· The crop diversity measure will not deliver the proven benefits of agronomically sound crop rotations. It risks incentivising livestock farmers who grow a small area of fodder crop to cease arable production altogether, which could be detrimental to farmland birds. Ideally this measure should be replaced by a crop rotation requirement, but at the least the setting of the minimum area threshold must be reviewed.

5. The EU’s long term food security depends on maintaining the productiv e capacity of agricultural land . ‘Greening’ the CAP is therefore not optional: it is a necessity. It is hard to determine what impact the proposals will have on food production , but evidence suggests it will not be significant .

6. The RSPB supports the principle of more efficient regulation , but maintaining environmental standards must be non-negotiable. Some of the cross-compliance simplification proposals would undermine the Policy’s environmental performance.

7. If executed well, greening provides an opportunity to improve agri-environment delivery by acting as an enhanced baseline upon which such schemes operate. Managing the transition to the new CAP will be key and farmers who are already in an agri-environment scheme when greening measures become mandatory must not be put at a disadvantage compared to those who are not.

Overarching comments


8. The RSPB has a long history of involvement in CAP reform. We have been instrumental in the development of agri-environment schemes, and Environmental Stewardship in particular, and making the case for a transfer of funds, and policy emphasis, from Pillar 1 to Pillar 2.

9. 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] .

10. Previous CAP reforms have contained some positive elements, particularly the creation of Pillar 2, decoupling of subsidies from production and the introduction of cross compliance.

11. Many of these changes were developed to signal the shift away from outdated and unjustified payments, with decoupling in particular introduced as a transitional process. However, the proposed end point of this ‘transition’ urgently needs to be spelled out. Without a clear route map, farmers are poorly equipped to make the necessary business adjustments and are unlikely to ‘buy-in’ to the reform process.

12. Whilst there is room for simplifying all elements of the policy, both to reduce bureaucratic burden for farmers and land managers and to improve the policy’s efficiency, there must be no erosion of principles which improve cost-effectiveness and accountability of the policy for citizens.

13. To meet future challenges, the CAP needs to help ensure 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.

14. Direct payments are a wasteful and inefficient way of doing this – indeed, it is likely the Single Payment Scheme is impeding moves in this direction [4] . Direct payments do not encourage farmers to take a long term view, they are not linked to public goods nor do they secure sustainable land management – as they also have little impact on food production, what are they for?

15. We want to see a planned and gradual phasing out of the current direct payment system. This would provide an opportunity to temporarily target a proportion of CAP support toward measures which boost the long term sustainability and competitiveness of farming e.g. improving farming’s return from the food chain through added value products, savings through resource efficiency etc.

16. Increased 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 at the precipice in much of the EU, and the Natura 2000 network of protected sites, many of which depend on sensitive farming methods.

17. Well designed, implemented and funded 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 AES and by committing to provide public goods in this way farmers can guarantee a basic level of income over 5-10 years, providing a degree of security against volatility (albeit subject to adjustment following broader CAP reform outcomes) without becoming dependent on income support.

18. At a time of economic crisis, it is more important than ever to ensure the use of public funds in the CAP has a clear justification. This means boosting those CAP funds which deliver clear public goods, particularly in the absence of a market for such goods.

19. As long as a two-Pillar CAP remains in place, it is imperative that the environmental performance of the policy as a whole (i.e. across both pillars) is improved, while making sure the two Pillars complement each other and are not working at cross-purposes. There is considerable scope to improve the environmental delivery of Pillar 1; both through existing approaches such as cross compliance and the appropriate use of national envelopes, and through new ‘greening’ measures. However, greening is not a concept that only applies to Pillar 1, it must also apply to Pillar 2. Both Pillars must work together and never be in opposition.

Section 1: The need for further greening of the CAP


20. The impetus behind the Commission’s proposals to green the CAP is to justify its considerable public investment, and as a result, improve the public acceptability of the policy.

The ongoing environmental challenge

21. Despite the flaws in the approach the Commission has taken to address this issue, which will be covered in detail below, there is exceptionally good justification to expend more attention, and funding, on the natural environment in the context of EU agriculture:

· In 2011, the European Farmland Bird Index, which monitors farmland bird populations, fell to its lowest ever recorded level [1] . Rapid changes in agricultural management in the post-war period, driven in part by CAP incentives, have resulted in a farmed landscape across much of the EU that no longer provides a sufficient amount or quality of nesting habitat, spring food for chicks or food resources over the winter period. Measures to reverse these declines have been developed for the majority of farmland species, and have been proven to work. For example, at the RSPB’s own conventionally managed commercial farm in Cambridgeshire farmland bird numbers have been restored to 1970s levels through simple agri- environment measures. However, across the UK and wider EU, they are not being deployed at the right scale, or in the right combination, to effect the change required.

· The well-documented decline in farmland birds is mirrored by declines in other farmland wildlife. The European Environment Agency noted in a recent report that "biodiversity in agro-ecosystems is under considerable pressure as a result of intensification and land abandonment" [2] . For example, soil biodiversity is vital for agricultural productivity, and although it is poorly understood compared to above-ground biodiversity, it is clearly under pressure from issues such as soil erosion on farmed land.

· The European Nitrogen Assessment [3] makes clear that the level of use of Nitrogen fertiliser in EU agriculture has considerable negative impacts on water and air quality, the greenhouse balance, ecosystems and biodiversity and soil quality.

· Agriculture both contributes to and is vulnerable to the effects of climate change. Greenhouse gas emissions reported in the agriculture sector represent around 9% of total EU emissions. [4] European soils store around 73 to 79 billion tonnes of carbon. Land management practices can increase or decrease the size of this carbon store.

· As well as adapting itself to climate change, agriculture will need to play a key role in helping wildlife to adapt, as highlighted in Lawton’s report ‘Making Space for Nature’. [5]

The environmental policy context

22. Whilst agriculture is explicitly linked to a suite of environmental challenges, it is also the principle means to address them. Agriculture covers almost half of the EU land area, and over 70% of the UK and consequently has a major impact on wildlife and natural resources. The CAP must play a significant role in converting the current broadly negative environmental impact of EU farming to a positive one. The policy must also play its part in meeting wider EU targets on biodiversity, water quality and climate.

The food security context

23. Our natural resources of soil, water and biodiversity underpin agriculture’s ability to produce food and other commodities. Without healthy and stable soils, adequate water supplies and the services of pollinating insects, our food production potential would be fundamentally compromised.

24. While food security is a complex issue covering affordability, dietary choices and waste, to name just a few, it is clear that currently enough is produced to feed everyone. Poverty, not global shortage, is the major reason certain people cannot access enough food. It is also clear that many of our production systems are not sustainable in the long-term for reasons including our dependence on finite resources, over-abstraction of water in many parts of the EU and the cultivation, and associated loss, of carbon-rich soils. We are therefore have a food security imperative to address our food production systems now so that our natural environment is able to support food production, and a viable farming sector, long into the future.

Greening the CAP as a whole

25. As long as a two-Pillar CAP remains in place, improvements to the policy’s environmental performance must take place across both pillars. While the focus on ‘greening’ has largely centred on the Commission’s proposals for 30% of Direct Payment funding to be attached to new measures under Pillar 1, there are existing CAP mechanisms that must be addressed.

A central, and growing, role for agri-environment

26. Well-designed and adequately funded agri-environment schemes are capable of delivering exceptional results, particularly for biodiversity [1] , and represent a sound use of public investment in agriculture. While problems of design and implementation across Europe have been recently highlighted by the European Court of Auditors [2] , this same study emphasised the importance of such schemes and reserved particular praise for Environmental Stewardship schemes operating in England.

27. Despite the central role of agri-environment schemes in securing environmental outcomes on farmland, and rewarding farmers for doing so, the current set of CAP reform proposals has effectively shifted the focus elsewhere. From a budgetary perspective, the proposed Multi-Annual Financial Framework (MFF) will see the CAP budget across both Pillars reduce in real terms by about 8%. Although ring-fencing for environmental measures (agri-environment, organic farming and payments to areas facing natural or other specific constraints) has been set at 25% in the proposed Rural Development Regulation this represents 25% of a reduced budget. Furthermore, agri-environment measures have been renamed "agri-environment-climate" measures. Therefore, this 25% will be expected to deliver a broad suite of environmental objectives and it is unlikely that the ring-fenced money will be adequate. There is also the risk that new climate change measures developed under Pillar 2 could undermine other environmental objectives, or actually cause further environmental harm. One example could be the inappropriate development of Anaerobic Digesters which demand purpose grown maize crops. Maize, if sited poorly, is linked to soil degradation and water pollution problems.

28. In the UK alone, where already significantly more than 25% of Rural Development funds are allocated to agri-environment schemes, it is estimated that between £1-3bn would be required, each year, to secure stated conservation objectives [3] . This is significantly less than is allocated to environmental schemes, but is comparable to the funds distributed through the CAP’s Pillar 1 payments each year in the UK.

An improved cross compliance system that meets its potential to deliver environmental improvement

29. As several studies and reports [1] have highlighted, cross compliance (a system of requirements farmers must respect to receive the majority of CAP payments) has not yet met its considerable potential to lever basic environmental protection and enhancement across the EU’s Utilised Agricultural Area. There has been a distinct lack of political will to address the fundamental problems facing the system, which include poor design, implementation (including inadequate guidance to farmers) and enforcement.

30. In addition, the system is being steadily undermined through a misguided approach to ‘simplification’. During the 2008 ‘Health Check’ of the CAP, important elements relating to the Birds and Habitats Directives were removed from cross compliance and this worrying trend has been continued into the current Commission Proposals for reform, notably a proposal to remove Birds Directive Articles 5 (a), (b) and (d), relating to the deliberate killing or capture of wild birds, damage to eggs and nests and disturbance. There are also proposals to remove the element of the Habitats Directive (Article 6 (3), (4)) that requires national authorities to assess plans and projects which are likely to have a significant effect on Natura 2000 sites and to mitigate damage if work goes ahead; and Article 13 (1) (a) which deals with the deliberate destruction of protected species of wild plants.

31. While the reform proposals state that requirements relating to the Water Framework Directive and Sustainable Use of Pesticides Directives will become part of cross compliance, it is with the caveat that this will happen only when all Member States have implemented them – therefore allowing an indefinite period of delay.

32. Such erosion, or inadequate implementation, of the Statutory Management Requirement elements of cross compliance is completely unjustified and will remove an important financial incentive to farmers and land managers (through direct payments reductions following cross compliance breaches) to respect them.

33. While there have been some positive elements added to the Good Agricultural and Environmental Condition (GAEC) requirements in the Commission’s proposals, particularly a ban on hedge and tree cutting during the bird breeding and rearing season (GAEC 8) and a potentially useful addition dealing with protection of wetland and carbon rich soils (GAEC 7) there have been other concerning changes. The current Regulation dealing with cross compliance (Regulation 73/2009) includes the wording "Ensure a minimum level of maintenance and avoid the deterioration of habitats". This is not duplicated in the proposals for reform, which could limit Member States’ ability to define good management requirements under the new GAEC framework. In addition, the GAEC relating to crop rotation has been removed (presumably under the misapprehension that the proposed crop diversity measure under Pillar 1 greening will meet this need) as has the GAEC relating to appropriate machinery use to maintain soil structure. These deletions are watering down the ability of cross compliance to deliver environmental protection and improvement.

Addressing gaps in the CAP’s environmental provisioning

34. In addition to improvements needed for existing measures under Pillar 1 and 2, there are long standing gaps in the CAP’s environmental provisioning that need to be addressed to genuinely green the policy, which have not been addressed in the Commission’s proposals for reform. These include:

· Targeted support to High Nature Value (HNV) farming systems which are often economically marginalised but deliver outstanding environmental benefits through sensitive land management.

· Meaningful support for farms in Natura 2000 sites, linked to management plans;

· A top-up payment for organic farming systems, linked to positive land management.

Section 2: EU Proposals to ‘green’ Pillar 1 of the CAP


Question 1 – Will the proposal to green direct payments will generate significant environmental benefits?

35. The Commission’s proposal to green Pillar 1 through the introduction of new measures linked to 30% of direct payments represents a potential improvement to the status quo. The proposals state clearly that greening measures must go beyond (i.e. deliver more than) cross compliance and as such recognise that the CAP must improve its performance in response to ongoing environmental challenges and heightened public scrutiny. However, the extent to which the proposals will actually improve the status quo is limited (and could be non-existent if they are not robustly designed and implemented). The Commission’s lack of ambition in this area is a missed opportunity to support EU farming to become more environmentally sustainable, and ultimately economically viable, in the long term.

36. The Commission’s proposals contain three new greening measures. Their potential to generate environmental benefit will be analysed in turn.

Environmental Focus Areas (EFAs)

37. EFAs have significant potential both to recognise and reward those farmers who have retained environmentally and agronomically useful features on their farm and to drive those who do not have such areas to incorporate them on their land. However, some initial comments on what farmland will be subject to the EFA requirement are necessary.

EFA applicability

38. Currently, farms under permanent pasture (i.e. many livestock enterprises) will not have to implement EFAs. We need to look at ways to make permanent pasture subject to the EFA requirement for the following reasons.

39. Firstly, intensively managed grasslands are associated with a suite of negative environmental impacts including loss of soil carbon through regular cultivation and re-seeding; high stocking densities or cutting regimes which limit the value of the grassland as a nesting resource for ground-nesting birds [1] ; greenhouse gas emissions through the application (and production) of nitrogen fertilisers; links to diffuse pollution of watercourses. There is therefore a clear need to mitigate the impacts of intensive grassland management and this can be done, at least partially, through EFAs.

40. Secondly, EFAs would provide an additional means to recognise livestock farmers who have retained landscape features on their farms (such as hedgerows and wet features) and who have extremely valuable areas of biodiverse rich permanent pasture on their farms.

41. In the current proposals certified organic farms will be exempt from all greening measures. While the RSPB agrees that scientific evidence highlights the overall benefits of organic systems for the environment, all organic farms are not necessarily more beneficial than conventional systems. Extending the greening measures to organic systems would place no additional burden on those farmers who already deliver a high level of environmental benefit, and would bring others up to a higher standard of environmental delivery. The RSPB does believe that organic farms should be recognised for the environmental benefits they deliver in general but feel this would be more appropriately delivered through an additional top-up payment through Pillar 1.

EFA coverage and eligible features

42. The Commission proposal is for 7% of all farms (currently excluding permanent pasture systems) to be managed under an EFA. The RSPB believes that as this requirement will include landscape features, 7% should be considered an absolute minimum.

43. What landscape features or land types are allowed to count towards the EFA requirement will have significant bearing on its ability to deliver for the environment. While land out of production is likely to constitute a proportion of EFA on many farms, it is extremely important to recognise that EFAs are not a return to set-aside and that many farms will be able to deliver much of their EFA requirement through non-fallow means.

44. The Commission has rightly proposed that landscape features should count towards EFA and they should encompass hedgerows; lines of trees; single trees; small ponds and wet areas and areas of scrub. These features provide both environmental benefits through, e.g., nesting and feeding resources for many farmland bird species, and agronomic benefit through e.g. reducing erosion risk of soil from wind and rainfall. Current issues surrounding eligibility for CAP Direct Payments have led to the removal of scrub and areas of gorse from many farms across the EU (including in the UK), with negative environmental impacts. Therefore including them in EFAs would provide an extremely useful incentive to retain them on farmland.

45. The inclusion of fallow areas in the EFA requirement is also positive and in an arable context should encompass buffer strips; field margins and field corners. Whole fields should also be permitted. These areas, which are already present on many farms, provide a range of benefits including supporting seed and insect food resources for wildlife and slowing, filtering and trapping pollutants before they enter watercourses.

46. The Commission proposals state that afforested land should also be eligible for EFA (if planted under an agri-environment scheme). In order to ensure that a degree of habitat diversity is secured through EFA, areas of woodland should only count for a small proportion of the EFA requirement.

47. If grassland systems were to be included in the EFA requirement, in addition to the landscape features identified above EFAs could also encompass field margins cut once late in the year to allow food resources for wildlife to develop and extensively managed, semi-natural permanent pasture. For the latter, in the absence of a mapped inventory of such grasslands, these areas could be identified using outcome focussed definitions e.g. the grassland features at least 10 different plant species per square metre or alternatively could be achieved using ‘the approach taken in the Welsh Glastir agri-environment scheme to define ‘habitat land’: as "any vegetation which has a composition of less than 25% sown agricultural species as per the Environmental Impact Assessment (Agriculture) (Wales) (EIA) Regulations 2007." [1]

48. It will be extremely important to ensure that only features or land uses which are environmentally beneficial count towards the EFA requirement. Currently the Commission proposals state that terraces should be included; however not all terraces are environmentally beneficial.

EFAs and agri-environment schemes

49. Many farmers are already working hard to deliver benefits for wildlife and the wider environment, often through agri-environment schemes, and it is imperative that any new greening requirements do not penalise them. Therefore farmers must be able to count landscape features and areas managed under appropriate agri-environment options, including those which form part of the Campaign for the Farmed Environment, towards their EFA area requirement (N.B. only the ‘footprint’ of these features in terms of land area covered, and not management prescriptions, would form part of the EFA). In order to avoid issues of ‘double-funding’, agri- environment measures will need to be re-scored in terms of their ‘value’. However, for farmers who are already in a scheme when greening becomes mandatory, the new agri-environment values should come into effect when they renew their agreement.

50. It is vital that EFAs are managed to maximum environmental effect and this positive management should be explicitly encouraged through agri-environment scheme participation.

Permanent pasture protection


51. The RSPB believes that proper protection for permanent pastures of high environmental value is urgently needed, as is support for their sympathetic management. However, far from increasing protection, the current greening proposals could actually incentivise the destruction of valuable permanent pasture.

The value of permanent pasture

52. Semi-natural grasslands and those supporting priority species are incredibly valuable for biodiversity and deliver many ecosystem services that benefit society, including carbon storage and water quality provision. The National Ecosystem Assessment highlighted the value of these services and the fact that provision of many ecosystem services is greater in semi-natural, than in agriculturally improved, grasslands [1] . However, semi-natural grasslands have declined drastically in the UK, with agricultural improvement being the major driver of this loss. Although only 2% of the UK’s grassland area is high diversity semi-natural grassland, these habitats are home to 206 Biodiversity Action Plan (BAP) species in the lowlands and 41 BAP species in the uplands. Halting the loss of semi-natural habitats is a key priority if the decline in biodiversity is to be stemmed and the agreement reached at Nagoya is to be honoured.

53. The current definition of permanent pasture includes grasslands that are regularly ploughed and reseeded (so long as they are not in an arable rotation for five years) and subject to intensive management. This failure to distinguish grass crops of little environmental interest from those extensively managed grasslands of the highest environmental value is a major difficulty with policy mechanisms designed to protect permanent pasture.

The 2014 reference date

54. The draft regulations propose changes to the rules governing the protection of permanent grasslands including the requirement to maintain permanent grassland at the holding level, based on the area declared as such for a reference year of 2014 (with conversion being allowed on a maximum of 5% of this reference area). This is a considerable change from the current cross-compliance requirement (which is implemented at the Member State level in the case of the UK) and landowners who do not wish to be restricted in the future may decide to cultivate their permanent pasture before the new rules come into force.

55. There are major weaknesses in the current cross-compliance mechanism [1] to encourage maintenance of permanent pasture which will limit its use in terms of preventing valuable grasslands from being ploughed up ahead of the 2014 reference date. This mechanism applies to land which was under permanent pasture in a reference year (2003, 2004 or 2007) and operates at the Member State or r egional level. If the ratio of this land to other farmland declines by 10%, authorities must take steps to reverse the decline. However, as the permanent pasture definition includes regularly reseeded grass, the control at national level is very crude, as it allows valuable permanent pastures to be destroyed, while new and less environmentally valuable pastures are created elsewhere, with potentially no statistical change for the country.

56. Furthermore, the dangers posed by the 2014 reference date are all the more concerning given the well documented evidence [2] that Environmental Impact Assessment (Agriculture) Regulations which should protect pastures of high value for biodiversity are failing to do so due to poor implementation and enforcement. Anecdotal evidence suggests that some land agents are already alerting farmers that ploughing up their permanent pasture now could avoid the new greening rules.

The definition of permanent grassland

57. The definition of permanent grassland [1] fails to distinguish true permanent grassland from pastures that are regularly reseeded. It specifies land that has not been in a crop rotation for five years or longer but doesn’t require that it has not been ploughed or reseeded in this time. While the last sentence is helpful in recognising the value of non-herbaceous species suitable for grazing, it does stipulate that grasses and herbaceous species must predominate – depending on the interpretation of ‘predominate’ this could render certain areas of biodiversity rich grazing land ineligible.

A premium for extensively managed pasture

58. The RSPB has called for a Pillar 1 premium payment to provide support for extensively managed pasture. Such a mechanism is urgently needed to counter the pressure to abandon or intensify management and would be self-regulating on the basis that more productive pasture is unlikely to be entered due to the associated restrictions on management. These should include a ban on ploughing, reseeding or inorganic fertiliser application. There should be options for Member States to define maximum livestock densities and minimum management regimes. This premium would replace some measures under broad-and-shallow agri-environment schemes, freeing up funds for more targeted measures.

Crop diversity

59. This greening measure was originally ‘crop rotation’ rather than crop diversity but failed to make it into the final proposals due to the Commission’s insistence that crop rotation could not be delivered under an annualised, Pillar 1 approach.

60. While the measure could provide a basic level of crop diversity across the EU’s arable area it will therefore not deliver the proven benefit that agronomically sound crop rotations can do including: enhancing soil fertility; improving nutrient and water use and avoiding the build-up of pests and diseases.

61. There is also a significant risk that the measure could incentivise livestock farmers who grow a small area of crops for fodder to cease arable production altogether rather than be required to implement the crop diversity measure. In areas of the country where grassland systems dominate, pockets of arable production are extremely valuable resources for farmland birds. Any measure that may encourage farmers to move out of arable production would be very detrimental to such species.

62. There is therefore a need to amend this greening measure. Ideally, it would be replaced by a crop rotation requirement which could easily be verified at the farm level by checking records for which crops were planted in the previous years.

63. Alternatively, if the crop diversity measure is retained the minimum area threshold when the measure kicks in (currently proposed to be 3 ha) must be reviewed to avoid the perverse consequence of reducing arable production in grassland dominated areas. This could be a simple increase of the arable threshold (potentially determined at the Member State level following consultation with stakeholders) or a threshold relating to the proportion of arable land on the farm rather than the absolute area.

Question 2 – What will be the impact of additional greening requirements on food production and the competitiveness of the agricultural industry?

64. The scale and severity of environmental challenges facing EU farming mean that further greening of the CAP is not optional: it is a necessity, required to help protect the natural resource base of farming and the viability of farming, and food production, into the future.

65. Food security is rightly highlighted as a major issue related to the CAP . However, food security is about much more than the quantities of food grown. The reason s for world hunger can be better explained by poverty than by production problems: many people simply cannot afford to buy food. Increased production also does not automatically lead to less global hunger – the number of undernourished people in the world has increased by 9%, despite a 12% rise in global food production per capita since 1990 [1] . The most pressing problem currently therefore, is to address issues of global poverty and access to food rather than to increase the amount of food available.

66. While more food will need to be grown in the coming decades, the EU’s long term food security depends on maintaining the productive capacity of agricultural land, including soil quality, soil carbon, water management and associated ecosystem services. Ensuring sustainable and sufficient food production systems is of paramount importance and the CAP can be a positive force in this context .

67. It is extremely difficult to determine what impact the proposed greening measures will have on EU food production. Several commentators have claimed that the EFA requirement specifically will result in 7% of productive agricultural land being taken out of production. This is clearly incorrect as the Commission’s proposals state that landscape features and certain land uses will be eligible . Where there are farms that contain no such landscape features or appropriate land uses (such as buffers), there is a clear need for such farms to incorporate them, both for environmental and agronomic benefit.

68. As an illustration, f or the RSPB’s Hope Farm in Cambridgeshire , a conventionally managed arable farm growing winter wheat, oilseed rape and spring beans in rotation , n either the crop diversity nor the EFA requirement will pose any major implementation problems . The three crops sit comfortably within the size thresholds as set out by the proposals (the main crop cannot count for more than 70% of the farm, the third no less than 5%) . The farm’s field management measures under Environmental Stewardship (ELS), such as buffers, pollen and nectar mixes and skylark plots account for about 5% of the farm area. Including the farm’s hedgerows and other landscape features would bring the total to comfortably over 7%.

69. An assessment of the EFA requirement has also been carried out by the Institute for Agroecology and Biodiversity (IFAB) on its impacts on winter wheat production. This study used a higher EFA requirement than the 7% proposed (10%) and took a conservative approach to how much land landscape features would account for (2 %). It found that there would be a short term drop of yield by 4.9 %, but by 2020 yields would be about 4 % higher than 2013 due to projected productivity improvements in cereal production. It also found that the annual yield fluctuation for winter wheat in Germany is higher than the effects of an EFA-introduction.

70. Research from the farming industry itself also suggests that the projected impacts from greening requirements on food production are likely to be non-significant. Written in the context of feed stocks for anaerobic digestion, the industry [2] states that increasing crop rotations to include a (feed stock) break crop would lead to a reduction in second wheat output of 3.5% in the UK. It specifically states that this "difference in output may be seen as a modest change" (pg 25).

Question 3 – Are the greening proposals consistent with the CAP simplification agenda?

71. The Commission’s proposals for reform are certainly not simple, however it must be recognised that in order to deliver environmental and societal benefits, the Policy will need a degree of complexity.

72. While many Pillar 2 schemes, such as effective and well designed agri-environment schemes are not simple, they do deliver clear benefits. As such, the RSPB maintains that a simpler and more effective CAP structure would be a one-Pillar approach based on the current Pillar 2.

73. However, this reform round will not see the CAP evolve significantly from its current architecture and greening must therefore be achieved across both Pillars in as simple a way as possible whilst still achieving clear environmental benefits.

74. In the context of Pillar 1 cross compliance, some of the simplification proposals if implemented will undermine the Policy’s environmental performance. As highlighted in Section 1 above, there are extremely worrying proposals to remove Articles relating to the Birds and Habitats Directives from the scope of cross compliance. The RSPB supports the principle of moving to more efficient regulation, which reduces unnecessary burden while improving outcomes. However, maintaining environmental standards must be non-negotiable and improving environmental delivery is urgently needed.

Question 4 - How can greening pillar 1 can be made coherent with agri-environment schemes?

75. The proposed greening measures must complement and underpin agri-environment schemes. If executed well, greening provides an opportunity to improve agri-environment delivery by acting as an enhanced baseline upon which such schemes operate.

76. However, as highlighted above, managing the transition to the new CAP will be key and farmers who are already in an agri-environment scheme when greening measures become mandatory must be able to count their appropriate agri-environment options towards their greening requirements.

77. It is also extremely important that positive management of EFA land is explicitly encouraged through agri-environment schemes to get maximum benefit from the EFA measure.

Question 5 – What are your recommendations for improving the greening proposals?

78. There is significant scope to improve the Commission’s proposals in relation to the environmental performance of the CAP. As emphasised above, this includes specific recommendations for the Pillar 1 greening measures but also encompasses other aspects of the existing CAP:

i. Funding for Pillar 2 in the UK must be increased in line with the scale of need for environmental improvements. If an adequate Pillar 2 allocation is not secured for the UK, measures to shift Pillar 1 funds into Pillar 2 (modulation) must be deployed. Other Pillar 1 means of improving the CAP’s environmental performance must also be fully explored including the use of national envelopes or the proposed top-up payments to support environmentally beneficial farming systems. Within Pillar 2, the funding for agri-environment schemes must be guaranteed through ring-fencing. The RSPB does not believe that 25% is adequate and while we are confident that each of the UK Administrations will continue to deploy the majority of Pillar 2 funds to agri- environment schemes, the same confidence cannot be shown cross Europe. Therefore, this ring-fenced amount should be increased to at least 30%.

ii. Cross compliance must be addressed to correct its existing shortcomings and to prevent erosion of existing standards.

iii. Adequate funding must be directed to High Nature Value systems, ideally through a bespoke top-up payment but in its absence through an improved Less Favoured Area approach, national envelopes and through Rural Development measures (including the ability for Member States to develop sub programmes within their Rural Development Programmes).

iv. Specific and additional Pillar 1 support for organic farming.

v. Specific and adequate support for farms in Natura 2000 sites, linked to management plans.

vi. Each of the proposed Pillar 1 greening measures must be designed so they deliver genuine environmental benefits – see above for more detailed recommendations against each of the three measures.

vii. The package of greening measures should be enhanced to include soil cover where soil is not left bare for more than 5 consecutive weeks in either arable land or permanent crops. This can be met through optimisation of crop rotation (between spring and autumn crops), by leaving stubbles over winter, by planting catch or cover crops or by allowing native vegetation cover.

viii. Sanctions for farmers and land managers who fail to carry out Pillar 1 greening measures must be severe enough to act as genuine deterrent. This may mean reductions exceeding the 30% greening payment itself may be required.

November 2011

[1] Beyond the Pillars: Wildlife and Countryside Link’s policy perspective on the future of the CAP (2008)

[2] Proposals for the future CAP: a joint position from the European Landowners’ Organization and BirdLife International (2009)

[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; Crunch Time for CAP: Choosing the right tools for a richer CAP (2011) The Joint Links.

[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

[1] Pan-European Common Bird Monitoring Scheme:

[2] European Environment Agency (2010) 10 messages for 2010: Agricultural ecosystems

[3] Sutton et al (2010) The European Nitrogen Assessment: Sources, Effects & Policy Perspectives

[4] COMMISSION STAFF WORKING DOCUMENT (2009) The role of European agriculture in climate change mitigation

[5] Lawton, J.H., et al . (2010) Making Space for Nature: a review of England’s wildlife sites and ecological network. Report to Defra.

[1] BirdLife (2011) Seeds of Success: How agri -environment can yield results for nature and farming

[2] European Court of Auditors (2011) Is agri -environment support well-designed and managed? Special report no. 7

[3] Cao et al (2009) Estimating the scale of future land management requirements for the UK . Report to the Land Use Policy Group. ADAS UK Ltd and Scottish Agricultural College

[1] European Court of Auditors (2008) Is Cross compliance an effective policy? Special Report No. 8; BirdLife (2009) Through the Green Smokescreen: How is CAP cross compliance delivering for biodiversity?

[1] Peach, W.J., et al. Cereal-based wholecrop silages: A potential conservation measure for farmland birds in pastoral landscapes. Biol. Conserv . (2010), doi:10.1016/j.biocon.2010.11.017


[1] For example, storing greater densities of carbon, producing less nitrous oxide and pollution, having more efficient nutrient cycling, allowing greater water infiltration rates and enhanced storage (aiding flood prevention). NEA, 2010 Chap 6 Semi-natural Grasslands

[1] Reg 73/2009 Article 6 (GAEC) on encouraging the maintenance of permanent pasture for its positive environmental effects

[2] For example, as detailed in a letter to the Secretary of State for Environment, Food and Rural Affairs from members of Wildlife and Countryside Link, July 2009

[1] “Land used to grow grasses or other herbaceous forage naturally (self-seeded) or through cultivation (sown) and that has not been included in the crop rotation of the holding for five years or longer; it may include other species suitable for grazing provided that the grasses and other herbaceous forage remain predominant.”


[1] Barrett C (2010), ‘Measuring Food Insecurity’, Science, 327, 825–828

[2] ADBA, CLA, NFU & REA (2011) The case for crop feed stocks for Anaerobic Digestion: A Joint briefing paper

Prepared 30th November 2011