Greening the Common Agricultural Policy

Written evidence submitted by the Fairtrade Foundation (GCAP 24)

EU proposals to ‘green’ the Common Agricultural Policy specific to cotton

Background to Fairtrade

The Fairtrade Foundation is the independent non-profit organisation that licenses use of the FAIRTRADE Mark on products in the UK in accordance with internationally agreed Fairtrade standards defined by the ‘Fairtrade Labelling Organisations International’ (FLO). The Foundation was established in 1992 by a group of Civil Society organizations with an interest in international development and social justice. The Foundation is a registered charity (no. 1043886). It is also a company limited by guarantee, registered in England and Wales (no. 2733136).

The Fairtrade Foundation adheres to the definition of Fair Trade developed by the main Fair Trade networks and recognized by the European Parliament (2006), the European Economic and Social Committee and the European Commission:

"Fair Trade is a trading partnership, based on dialogue, transparency and respect, that seeks greater equity in international trade. It contributes to sustainable development by offering better trading conditions to, and securing the rights of, marginalized producers and workers – especially in the South".

Through demonstration of alternatives to conventional trade and other forms of advocacy, the Fairtrade movement empowers citizens to campaign for an international trade system based on justice and fairness.

1. INTRODUCTION

CAP has been the subject of a lot of changes during the last decade. Even though it has arguably maintained the idea of ‘agriculture exceptionalism’ – as subsidies concerned – by justifying the payment of subsidies to farmers as a need to keep European productivity levels high, as described in the Treaty of Rome, in recent times it has become difficult to defend the exceptional need of European agriculture subsidies, environmental arguments have been ‘coupled’ with agrarian ones to justify the need to keep farmers on the land. Its objectives have also been changed moving towards greener schemes and moving away from production-oriented policy. While on the one hand is difficult to cut agriculture subsidies all together, on the other hand is slowly reducing subsidies in order to give farmers enough time to adjust and become more compatible in the international market. It has also been argued that subsidies is what keeping farmers producing more and therefore can be seen as a motive to work. Main purpose is eventually to cut away from producing and concentrate in conservation issues by promoting sustainability. [1] That’s why the last years CAP has introduced several environmental schemes for farmers to comply through the cross-compliance mechanism – which means they have to keep their land in good condition, also known as the ‘notion of good environment condition’ - that in order to receive the subsidies, certain environmental standards have to be complied. These schemes are also needed as CAP also has to adjust with the new EU Sustainable Development Indicators (SDI) that have been introduced as part of the EU Sustainable Development Strategy in 2009 [2] that will last until 2020. [3] The previous year though have shown that environmental directives are not that easy to monitor at all, even though in theory CAP is going towards a ‘greener’ direction, only 5% of the farmers that receive subsidies are actually checked each year which raises questions about the reliability of the monitoring part of CAP.

EU MSs have been asked to prepare a set of SDI independently in order to integrate them into their national system [4] but as happens with all environmental directives there is enough space left to MSs to define what the standards of these indicators are and suit it independently. It is worth noting that Greece’s means of measuring sustainability – meaning monitoring, evaluating and improving strategic development decision making – are still underway, while the rest of EU 15 are doing very well. Though this might be justified with the recent economic problems that the country is having, and therefore, such a strategy should also mean to be integrated with the economic strategy. After 2004 and the part decoupling: In Spain, there was reduction in the number of cotton farms by 45% and a 27% of reduction in performance. In Greece, the farm reduction was only 4% for the number of cotton farms and a 24% of performance. Nevertheless this reduction was only based on the bad weather conditions rather than the CAP reform.

As far as European cotton production is concerned, it falls under these predominantly environmental indicators (SDI) as set by the EU [5] :

· Climate change and clean energy

· Conservation and management of natural resources

· Sustainable consumption and production

In the following pages, it will be discussed how far cotton production is actually undermining in any way these already mentioned indicators by examining cotton footprint as well as water footprint concentrating in the following facts:

1 Cotton yields have been steadily increasing worldwide since the 1930s while the total cotton growing area has not. Extensive agriculture practice can only be achieved with use of fertilizers and irrigation as groundwater cannot cover the needs of cotton production. This kind of practice can only lead to eventual abandonment of the land as has already been seen in Northern Spain. (APPENDIX 1) Countries with largest yields are those where irrigation is extensively used and pesticides are intensively applied. GM cotton is used in some areas in the last decade but new studies have shown that GM cotton seeds are actually not as sustainable as it was thought because new kinds of secondary pests have emerged as a result and have become more resistant to it and it is no longer capable of killing pests, and furthermore leading to a new generation of pests that were not seen as a threat in the past. [6] There’s a Greek and an EU legislation that forbids the use of mutant cotton seeds.(in Greece KYA 332657/21-2-2001, FEK176).

2 Because of the extensive use of water salinization cannot be avoided in semiarid Mediterranean climates (such as Spain and Greece) where evapotranspiration exceeds both rainfall and the amount of fresh water used for irrigation. Cotton has been sown under plastic in order to improve water management but this in turn affects the look of the landscape and poses problems for waste material recovery and recycling.

3 Lately, cotton’s contribution to pollution of water table and surface with nitrates is considerable and some areas of Greece have been classified as ‘vulnerable’ under the Nitrate Directive.

4 The lack of crop rotation in some areas risks exhausting the soil in time while intensifying soil erosion in already fragile areas (linked with point 1). This fact also increases the plant health risks and in time can lead to increased use of pesticides. In addition, pesticides are killing non-target organisations causing chain reactions to biodiversity.

5 There is also need for farmers’ education; it’s been proven that there could be a reduction of more than 30% of pesticides used in cotton production if farmers only knew how to use them properly.

Worldwide cotton ecological footprint [7] :

- It covers 2.5% of the world’s cultivated land but uses 16% of the world’s insecticides, more than any other single major crop.

- High levels of agrochemicals are used in the production of non-organic, conventional cotton. Cotton production uses more chemicals per unit area than any other crop.

- The chemicals used in the processing of cotton pollute the air and surface waters.

- Decreased biodiversity and shifting equilibrium of ecosystems due to the use of pesticides.

Water footprint of cotton consumption [8] :

- Linked to a chain of impacts on the water resources

- Evaporation of infiltrated rainwater for cotton growth

- Withdraw of groundwater or surface water for irrigation or processing

- Water pollution during growth or processing

2. RESEARCH FINDINGS:

2.1. Groundwater quality and location of productive activities in the region of Thessaly (Greece) (2007)

Conducted by: A. Papaioannou, P. Plageras, E. Dovriki, A. Minas, V. Krikelis, P. Th. Nastos, K. Kakavas, A.G. Paliatsos

Department of Medical Laboratories, Education and Technological Institute of Larissa (GR),

Department of Planning and Regional Development, University of Thessaly (GR),

Department of Geology and Geo-environment, Laboratory of Climatology and Atmospheric Environment, University of Athens,

General Department of Mathematics, Technological Education Institute of Piraeus (GR), co-funded by the European Social fund and National Resource – EPAEK II [9]

2.1.1. SUMMARY:

Assessment of the groundwater quality on the basis of physical and chemical analysis and sodium absorption ratio for the period 2000-2004. The results reveal that in the region of Thessaly, agricultural and animal husbandry activities are important factors that contribute to nitrate pollution of groundwater. They also indicate degradation of groundwater quality mainly because of the pollution caused by the rural use of land and its intensive exploitation. The salination and toxicity are potential problems of groundwater quality indicating that there is a need to take direct actions for the purpose of the optimum management of water resources in the Region of Thessaly.

2.1.2. SYNOPSIS:

"The population density in bid cities as well as industrial development and intensive land cultivation in which chemical are involved, contribute to increased gathering of anions, heavy metals and toxic substances (pesticides and their metabolites) in both water and soil. Moreover, groundwater pollution depends on insufficient management of urban, industrial and domestic wasters, organic compounds and pathogenic microorganisms, which are found in groundwater receivers. Additionally, excessive and uncontrolled uses of detergents, pesticides and fertilizers have a negative impact to quality of water receivers. Especially, irrigation in hot and dry areas contributes in the transfer and deposition of inorganic compounds and salts in unsaturated soil’s zone. [….] Over the past 20 years the intensification of agricultural and animal husbandry production, which is enforced by E.U. agricultural policy, creates serious environmental problems connected with the exhaustion of natural resources. It should be noted that E.U. have proposed new Groundwater Directive, which is built on the requirements of Art. 17 of the Water Framework Directive (2000/60/EC). In particular, it assesses the options of evaluating the chemical status of bodies of groundwater, and for identifying and reversing significant upward trends in the concentrations of pollutants. It also assesses measures to prevent and control groundwater from point and diffuse sources of pollution." [10]

2.1.3. RESULTS [11] :

"[…] The nitrate pollution in each area is very important and must be assessed. From the concentration level of nitrate ions it can be concluded that in areas where intensive agriculture activities take place groundwater is more degraded compared to other regions. In these areas the nitrate ions concentration level is increased and exceed the allowable limits. A possible negative health effect of high nitrate concentrations is methemoglobulinemia, especially for infants. Nitrates are noticeable throughout the entire region rendering most underground water improper for human consumption. […] (The areas with higher levels of nitrates) are characterized by intense industrial and agricultural activity and the high nitrate concentrations in groundwater are related to wastes and over-fertilization, respectively […] resulting in groundwater pollution." Coastal areas have also been affected and have considerable higher levels of sulphates and chlorides in relation to other areas and it can be attributed to the fact that the vast majority of agricultural and industrial wastes are drained usually in particular sites in coast areas. "[…] a number of actions must be taken when these waters are used for irrigation […] and should take special actions in order to avoid the degradation of groundwater and soils. […] Additionally, from the determined concentration of boron it is found that there is relatively danger of boron toxicity of irrigation water in this area." [12]

2.1.4. ENVIRONMENTAL PROBLEMS MET IN THE STUDIED AREA

· Pollution from the discharge of municipal sewage, industrial waste and agricultural runoff to the soils

· Uncontrolled disposal of municipal refuse

· Overuse of the water resources

· Uncontrolled use of pesticides and air spraying practices. The agricultural cultivations in this area are cereals, cotton, sugar, lets, tobacco etc. The average fertilization of soil by fertilizers reached 15 mg kg-1 of soil. Over the past 10 years the total quantity of N- and P-fertilizers created unfavourable conditions for the environment. [13]

2.2. THE ENVIRONMENTAL IMPACTS OF TRADE LIBERALISATION AND POTENTIAL FLANKING MEASURES [14]

IEEP and GHK Consulting, Institute for Environmental Policy Final Report (2005)

2.2.1. SUMMARY:

The major environmental issues that arise in Europe in regard to the cotton sector are water mismanagement and the use of pesticides. Pressures have been exacerbated as production has intensified in order to meet global demand.

2.2.2. Table: Summary of environmental impacts of liberalised trade on cotton products, and potential flanking measures. Key impacts in bold. [1]

Type of impact	In Europe	European flanking measures	Outside Europe	Flanking measures for effects outside Europe
Land use/landscape	Landscape change and perhaps a minor chance of some land abandonment as cotton production becomes no longer viable in Greece and Spain. NB: for Turkey, impacts are as for ‘outside Europe’.	In Greece and Spain alternative management of the land could be ensured through cross compliance measures (e.g. GAEC) and Rural Development measures such as support for organic cotton farming. Outright land abandonment seems unlikely in most cases. No new measure needed.	Continued dam building, ecosystem destruction and changes in water flow in areas of irrigated production. Increased land reclamation and habitat destruction, especially in West and Central Africa and Brazil.	Best addressed through local regulation - no new measures needed. Softer measures such as technical assistance may be useful.
Soil	Decline in salinisation; longer term improvements to soil fertility; decreased soil erosion in Greece and Spain. NB: for Turkey, impacts are as for ‘outside Europe’.	Not needed.	In irrigated areas: increased salinisation, leading to land abandonment. In all areas where pesticides and fertilisers are used intensively: decline in soil fertility, increased soil erosion leading to land abandonment	Largely to be addressed locally. Some issues could be addressed through certification schemes and provision of technical assistance.
Water quality and supply	In Greece and Spain, decreased reliance on surface and groundwater resources if cotton production is not replaced by another irrigated crop.	Not required so long as cotton production is not replaced by another equally water intensive crop. Assuming Turkey accedes to the EU cotton production could be required to meet cross compliance measures (e.g. GAEC) and Rural Development measures which support more sustainable irrigation methods (e.g. the drip method).	In irrigated areas: Increased chance of water resource mismanagement through the intensive and unsustainable use of surface and groundwater resources. Leads to low water tables, salinisation, ecological disturbance to water sources. In non-irrigated areas: Chance that farmers in areas of rain-fed cotton may look to irrigation systems to increase yields. In all areas: contamination of water supplies with pesticides and fertiliser runoff.	Largely to be addressed Locally. Some issues could be addressed through certification schemes and technical assistance.
Type of impact	In Europe	European flanking measures	Outside Europe	Flanking measures for effects outside Europe
Resource use/waste (pesticides)	As cotton production no longer becomes viable in Greece and Spain there will be a reduction in pesticide application and associated problems of runoff and contamination, as cotton production is unlikely to be replaced by an equally pesticide intensive crop. .	Not required so long as cotton production is not replaced by another equally pesticide intensive crop. When Turkey accedes to the EU, cotton production could be required to meet cross compliance measures (e.g. GAEC) and Rural Development measures which support more sustainable pesticide application.	Increase in pesticide application to combat pests, leading to increase in poisoning incidences, increased runoff and contamination of soils and water.	Largely to be addressed locally. Some issues could be addressed through certification schemes and technical assistance.
Biodiversity	Reduced chance of poisoning of wildlife and contamination of habitats by direct application of pesticides and fertilisers, indirect application of pesticides and fertilisers, (e.g. spray drift) and diffuse pollution into water sources, leading to problems such as eutrophication.	Not required so long as cotton production is not replaced by another equally pesticide intensive crop. When Turkey accedes to the EU, cotton production could be required to meet cross compliance measures (e.g. GAEC) and Rural Development measures which support more sustainable pesticide application.	Increased chance of poisoning of wildlife and contamination of habitats by direct application of pesticides and fertilisers, indirect application of pesticides and fertilisers, (e.g. spray drift) and diffuse pollution into water sources, leading to problems such as eutrophication. Decrease in biodiversity in areas of monocultural production. Fragmentation and destruction of habitats through expansion of growing area and through damming.	Biodiversity considerations could be added to certification schemes, and technical assistance could provide farmers with knowledge of more sustainable farming techniques such as IPM.
Air quality	No associated changes as a result of trade liberalisation	No flanking measures are needed.	Increased chance of dust storms caused by soil erosion in areas of monocultural production	Development of a code of good practice to manage pesticide application, sustainable agricultural techniques etc.
Type of impact	In Europe	European flanking measures	Outside Europe	Flanking measures for effects outside Europe
Climate change/greenhouse gases	No associated changes as a result of trade liberalisation.	No flanking measures are needed.	Unclear.	Code of good practice.
Plant and animal health	Decreased chance of pest invasion as cotton production declines in Greece and Spain. Pests will continue to pose a problem for cotton growing areas in Turkey.	No flanking measures are needed if cotton production declines. Organic and IPM techniques should be encouraged. Technical assistance to provide farmers with knowledge of more sustainable farming techniques such as IPM; development of organic cotton farming and labelling initiative; development of a code of good practice to reflect more sustainable farming techniques; further research into GM varieties	Increased chance of pest invasions in areas of cotton production.	Largely to be addressed locally – it does not seem appropriate for the UK to seek regulatory flanking measures to address this issue.
Distributional impacts	Greece and Spain will experience reduced environmental problems as a result of the reduction in production. The impacts in Turkey are likely to be similar to those outside Europe.	Flanking measures will need to mitigate against any problems that occur as a result of pesticide usage and irrigation or the growth of replacement crops. The EU can provide the framework to ensure cotton production in Turkey becomes sustainable, especially given the drive to increase production through the extensive irrigation of the south-east Anatolia region.	All of the above problems could occur in areas dominated by irrigation i.e. Turkey, Pakistan, Uzbekistan, Australia, Mexico. All other problems could occur in West and Central Africa, Brazil and India. The environmental impacts above could be less severe in the USA as production declines.	Flanking measures should reflect issues specific to developing countries and whether cotton is irrigated or rain-fed. The most important measure for developing countries is to manage the use of pesticides, either by reducing (IPM) or eliminating (organic) their usage. Flanking measures will still need to mitigate against problems as production is not likely to cease completely.

3. Recommendations

After the CAP decoupling of subsidies there haven’t been many cases of research yet regarding the cotton production in Greece, firstly because of the small scale of the production in the country in regard the international market (researchers prefer to do studies in areas such as China where there more cotton farms) and secondly because this kind of researches are usually funded by national governments. There have been studies to specific locations of Greece where there is intensive cotton agriculture (as the one already referred) that show an indirect connection between the intensive agricultural practice of cotton in some areas but there are not sufficient studies that are up-to-date and after the implementation of the new environmental directives introduced by the EU the previous years.

· Give extra attention to the monitoring part of CAP which is still insufficient and can be easily manipulated by MSs. For example, as seen in the research regarding water quality in Thessaly where more than 50% of Greece’s cotton is produced, there is evidence of breach of the Water framework Directive but it is not addressed in any way.

· In addition, each MS, in compliance with CAP regulations, has to establish a Farming Advisory System (FAS) that will provide information and education to farmers regarding the cross compliance mechanism but according to a study, only 5% of European farmers are using this service, which again could be seen as an inadequate practical structure of CAP regarding the actual practices of farmers. This needs to be re-structured.

· The cross compliance mechanism that was introduced is still lacking the supp ort it needs. Monitoring is still weak and cases of environmental schemes that are actually monitored (even though governments spend a lot of money on it) are actually rare. [1] Monitoring needs to be improved.

· Further, the Fairtrade Foundation recommends that cotton subsidies are fully decoupled from production to ensure a competitive and market oriented CAP.

16 November 2011

APPENDIX ONE