Good points in European Commission’s recommendations to Estonian CAP strategic plan

European Commission unveiled the recommendations for the Member States’ CAP strategic plans on 18th of December. This far however these haven't been much discussed, at least not in the public, so here is a modest assessment. At ELF, we have been critical more than once of the CAP and the Commissions role in it this far, but recommendations for Estonia are largely adequate. Indeed, many are in good accord with what Estonian environmental NGOs have suggested more than once. I have doubts about only a small number of recommendations.


Outside of strictly environmental topics but still with a strong indirect environmental impact is the high concentration of Estonian agriculture and the CAP direct payments. The  Commission proposes (page 2, heading 1.1) a more targeted support from the CAP in favour of small and medium-sized farms. Following this advice would also benefit the environment, since industrialisation of farming threatens air and water quality, while abandonment of HNV farming is clearly connected to smaller farms going out of business.




Commission praises Estonia for “a marked enthusiasm for organic farming” (page 3, heading 1.2). In general, this is justified, but regrettably several farmers are currently considering giving up due to unfavourable market situation and insufficient public support. Also justified is the assessment that Estonia “is not a heavy user of fertilisers” but again the trend is in fact towards increased use.


One should agree however also to the following assessment:  “On the other hand, various problems and pressures are evident. Greenhouse gas (GHG) emissions (gross and net) are rising and expected to rise further. Estonia is expected to miss the targets on reducing ammonia emissions. Not all water bodies have yet achieved a good status and nitrate concentrations are increasing in some of them, with agriculture identified as a significant contributing factor. Various habitats and species are also under pressure (for example in grassland and forest areas).” 


Of several recommendations on the same page better nutrient management, protecting peatlands, management of semi-natural grasslands and restoring landscape features are very welcome, and indeed have been repeatedly made by environmental NGOs. One would also agree with advice “to shift towards healthier sustainable diets” (heading 1.3, page 4).


Heading 1.5 (pages 5 - 6) contains recommendations in a condensed form. From environmental point of view the following ones are of most interest:

  • Improving nutrient management & reducing losses:

  • Protection of peatlands;

  • Management of semi-natural grasslands & eligibility of these for the direct payments;

  • Increase the density of high-diversity farm landscape features.


Recommendations on animal welfare, pesticides and support to smaller farms are also worth notice.


The doubtful part of recommendations includes reduction of GHG emissions from enteric fermentation. Most of the methods proposed this far are of unproven efficiency, especially if indirect effects are taken into account. The only bullet-proof way to reduce methane from enteric fermentation is to reduce the number of ruminants. This advice however should go to the countries with excessive numbers of ruminants, and Estonia is not one of them, with average animal density being well below 0.5 LU/hectare and decreasing. However, this rather small number of animals is very unevenly distributed, and especially pig, poultry and dairy farming is concentrated into big farms, resulting in relatively large methane losses from manure storage. Here proven technologies - like production of biogas using the best available technique - do exist. Thus further measures to reduce GHG emissions from manure storage could contribute much more to climate change mitigation than attempts to deal with enteric fermentation.


Focus on regeneration of cut forest is also somewhat besides the point. As the analysis under the heading 2.4 (page 12) justly states, the LULUCF sector is projected to change from GHG sink to source in 2030 as the result of replacement of older forests with younger ones. Here regeneration is of no help - the cutting rates must be reduced to sustainable levels.


Apart from these two points, the Commission staff working document provides good guidance in relation to agri-environmental issues in Estonia. It would be wise if Estonian Ministry of Rural Affairs considered these.


Post by Aleksei Lotman, Estonian Fund for Nature


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