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Lord Roper, Chair of the Lords EU Committee, also said that the Committee "strongly regret" the fact that the CAP appears to have missed the opportunity for introducing new approaches through innovation. They stated that in the face of our current economically challenging times, greater disruption to European economies could make the CAP, and other long-standing budgetary models, "obsolete overnight".

In a wide-ranging letter to, the EU's Commissioner for Agriculture and Rural Development, the Committee have also said that:

• although they are pleased that funding for investment in agricultural research should be more than doubled, they are very disappointed that no substantial reduction in the agricultural budget has been made;

•  a temporary risk management measure for unforeseeable  and significant risks around adverse climactic events, animal or plant diseases or pest infestations must be implemented, albeit one available for a time-limited basis; and

• that there is a fundamental problem with the proposal that subsidies be linked to environmentally-friendly efforts made by farmers, in that its 'one size fits all' approach lacks flexibility; rather, such "greening measures" should be identified at a national or regional level and recognise the substantial efforts that European farmers have already made.

Private Sector Farm Advice

In the letter, Lord Roper also comments that the proposed Pillar 2 Regulation contains much that we welcome, particularly the prominence given to issues of knowledge transfer from laboratory to farm and that the proposal that the Farm Advisory Service should extend beyond cross compliance. However, he also comments that the proposals give insufficient recognition to the role of the private sector advice in the farm advice structure. There is an issue of the tension that can arise between, on the one hand, advice orientated in favour of certain products and, on the other hand, sustainability.  We see this issue as one that needs to be reflected in the final Regulations.

Lord Carter of Coles, Chair of the Lords Agriculture, Fisheries and Environment EU Sub-Committee, which examined the Commission's proposals, said:

"There is much to welcome in the CAP proposals, particularly the new prominence being given to knowledge-sharing between scientists and farmers, the extension of the Farm Advisory Service beyond cross-compliance and an increase of 30% in Union financing for a variety of innovation-related measures.

"However, we feel that many opportunities have been missed to make a real difference to the agricultural industry and for farmers and producers all over Europe. Our challenging and difficult economic times demand bold and ambitious plans if we are not only to guard against making the CAP redundant, but also to make the most of the opportunities we have.

"In our report published in July last year, we highlighted the need for Europe to act both quickly and coherently to ensure that the EU's agricultural industry is ready for whatever challenges may come our way. The reform of the CAP is our opportunity to ensure that all necessary changes take place and protect the agricultural industry for years to come."

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