CAP reform is a disappointment

European Commission finally unveiled the legislative proposals for the CAP reform on 1st of June. Together with MFF proposals from 2nd of May these form a disappointing but regrettably not surprising reading.

MFF foresees some cuts in CAP financing that in itself is both something to be expected and rather positive, since as written before (read here, here and other posts on this blog) most of finances are in Pillar I that is well connected to negative environmental impacts. Regrettably the MFF proposal foresees proportionally bigger cuts in the already underfunded Pillar II, that will lose almost a quarter of its budget, while Pillar I cuts will be less that a tenth. No surprise then that there have been no cheers from environmental NGOs.

One could hope that now, as the CAP is said to be transformed to a more objective-driven and programmable policy including both pillars there is no big difference how the money is divided between the them – but this is an illusion. The main spender of Pillar I and hence the whole CAP would be “basic income support for sustainability” that has sustainability in its name only. Not even formal explanation of how the scheme is to contribute to this end can be found in the relevant article.

In stead of the current “greening” the “schemes for the climate and the environment” are proposed. Their nature and objectives are not explained, and no funding is ring-fenced. While on the positive side one must note that care seems to have been taken to avoid double funding, without clear objectives there is a significant threat for the green-wash of current “greening” to continue.

There are many other smaller issues. Coupled income support is foreseen for “economic, social or environmental reasons”. While the latter two might indeed some times be relevant, the first begs an obvious question about market orientation of the policy: should not it be the markets that would steer any sector towards what is best economically? Leaving these issues to the economists, one cannot however ignore the fact that from environmental point of view it is long known that subsidies coupled to production tend to decrease resource efficiency and increase pollution.

There are lots of weird wordings that cause confusion. Member States “may grant payments for environmental, climate and other management commitments” - does this mean that measures for environment and climate are becoming voluntary? And what these “other” commitments are supposed to mean? Hopefully however these are things that would not be too complicated to rectify, since same article 65 later states “Member States shall include agri-environment-climate commitments in their CAP Strategic Plans.”

Inclusion of risk management tools into already stressed Pillar II financing is also regrettable. One can argue if such tools are good at all, since they might provoke more risky and less resource-efficient decisions. However, given the impacts of weather and markets such risk management seems to be at least to some extent needed. But then it should be fully financed from Pillar I the very existence of which is justified by the need to secure farmers’ incomes.

The main impression is that loosening of excessive bureaucracy – while in itself welcome – has not been accompanied by the sufficiently ambitious environmental objectives. Nutrient balance is mentioned but the text lacks clear objectives for its reduction. Pesticides are barely mentioned, there is no clear objective of reducing their use and related environmental damage. Biodiversity is dealt with is a superficial way, without even mentioning the HNV agriculture or pollinators’ protection. The wording for permanent grassland is as ridiculous as ever. And so on.

Summing up: in spite of sometimes appropriate rhetoric the legislative proposal would not help transform European agriculture towards sustainability. No surprise that the environmental NGOs are upset. Looking at the CAP and MFF together the most pressing need is to strongly cut Pillar I and not allow any decrease of Pillar II funding.

Post by Aleksei Lotman, Estonian Fund for Nature