Proposed reforms to the European Common Agricultural Policy, which are due to come into force in 2014, have caused a great deal of controversy across the 27 member states. Last month, MEPs announced they would not be making any further decisions on CAP proposals until after the allocated budget has been finalised. This, added to controversy over aspects of the proposed reforms, has led to speculation that reforms will not be finalised in time and may be delayed by one or even two years.

This week, European financial watchdog, the European Court of Auditors, speculated that proposals as they stand would be too complicated to implement, focus too heavily on compliance rather than performance and would result in increased administrative costs.

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Of all of the debated aspects surrounding the reforms, the Commission’s proposed ‘greening measures,’ which would see 30 per cent of pillar one funding becoming dependant of fulfilling certain environmental conditions, have stirred the most controversy.

Environmental considerations spark disagreements

Although it is almost certain that the forthcoming CAP package will carry greater environmental responsibility, which Commissioners have said is necessary to justify the huge expenditure on CAP to a European public which holds environmental protection as one of its principal concerns, the exact implementation remains to be seen.

Under the Commission’s draft proposals, published in autumn 2011 following a series of leaked false starts, farmers would be required to provide ecological focus areas (EFAs), crop diversification and maintain existing areas of permanent pasture at farm level. In order to receive full support payments, farmers would have to follow greening measures and could incur penalties as well as losing funding for failing to do so. Organic farmers would automatically receive the greening payment.

At 30 percent of the agreed CAP budget, which has yet to be approved, the new measures will account for around €90 billion between 2014 and 2020 across all member states. Although reforms have been welcomed by some for attempting to link secure food production with environmental protection, there has been a large degree of scepticism from the farming industry and many politicians, including the UK government, which wants to see an eventual end to subsidies.

The NFU has questioned the environmental benefits the new measures would bring and suggested the focus on cross compliance may mean they are inflexible and insensitive to the different environments across Europe, which will require different approaches to greening.

The union has candidly stated that it believes food production should remain a priority, however, environmentalists and policy makers have pointed out that dramatic drops in biodiversity and finite resources, which are increasing in cost, are threatening agriculture’s long term viability. There have been calls from conservation and farming groups for a ‘paradigm shift in agriculture’ towards a more sustainable and equitable model.

NFU Scotland has organised a conference to be held at the end of the month at the Moredun Institute near Edinburgh to discuss to proposed reforms and investigate other possible approaches which the union claims will better suit Northern European farmers. Policy experts and politicians speaking at the NFUS event will discuss the best outcomes for Northern Europe, where the landscape, weather and production patterns share similarities, as the union believes these areas have not been accorded due consideration.

The conference will look principally at the ‘greening’ aspect of the reforms. There are currently three elements to greening – crop diversification (three-crop rule), permanent grassland, and ecological focus areas.

Three crop rule

Crop diversification would require that where the arable land covers more than three hectares and is not entirely under grass or left fallow, at least three different crops would be grown. None of these would be less than 5 per cent of the arable land and the main one would not exceed 70 per cent. This three-crop rule is aimed at arable areas to avoid monocultures.

Critics have suggested the rigidity of the crop diversification proposal causes difficulty in terms of application at farm level, and suggested agricultural monocultures are not an issue in some member states. They also state that not all areas of the EU have the same range of crop options: northern Europe experiences comparatively high rainfall and low temperatures, providing short windows of weather for key field operations, which they claim will make crop diversity difficult to implement. Parts of Scotland could struggle to find three suitable crops, particularly on livestock farms where spring cereals are grown only for on-farm feed.

Permanent grassland

Greening will also require farmers to maintain as ‘permanent grassland’ the areas on their holdings declared as such at the start of the new direct support measures. So the definition of permanent grassland is key. The proposals suggest that anything over five years should be deemed permanent grassland. This is an attempt to protect soil carbon.

Critics have suggested that the proposals could prove limiting, in that improving grassland efficiency could play a key role in efforts to help tackle climate change, through better yielding grasses, increasing efficiency and reducing emissions. NFU Scotland representatives suggested “The proposal would curtail the potential for reseeding pastures necessary to meet future production and climate change demands.” 

Ecological focus areas

The ecological focus areas (EFAs) element in the proposals demands that at least 7 percent of a farm’s eligible hectares, excluding areas under permanent grassland, are left fallow, have farm woodlands, contain landscape features, or are used as buffer strips, etc. EFAs are aimed at improving biodiversity.

However, as with the other demanding proposals, it has been pointed out that monitoring compliance would be expensive and difficult to implement. This consideration has also been criticised for failing to take farm size or soil type into account.

NFUS to examine impacts in Northern Europe

At the NFUS meeting, delegates including Defra secretary Caroline Spelman, Scottish Rural Affairs Secretary Richard Lochhead and MEP George Lyon will discuss the proposals over two days. NFUS said it wants to promote discussion of ways in which reforms can “deliver environmental benefits without imposing greater compliance costs on farmers and administrators alike.” 

Amongst the union’s suggestions for alternative measures, which  mostly focus on means to avoid complying with greening measures, are a ‘menu approach,’ offering more targeted or tailored schemes where Member States or regions could define their own set of measures that are more directly responsive to local environmental challenges and farming systems.

It has also suggested extending exemptions from greening measures to other sectors, as with organic (though it has not been clear about what benefits these other sectors provide), extending Good Agricultural and Environmental Condition (GAEC) requirements to include green measures, or increase funding for greening measures as voluntary initiatives, either by enabling farmers to ‘opt out’ or by retaining agri-environmental options as part of the pillar two rural development options.

CAP criticisms

Although there is widespread disagreement over whether the new rules will be workable, and farming unions across Europe have balked at the proposed greening measures, the reforms have been praised for offering considerations to young farmers and small farmers post-2013.

The CAP has been criticised by neoliberals as trade distorting, though this is contested as initiatives such as ‘Everything but Arms’ mean Europe imports more from developing countries than the USA, Canada, Australia and Japan combined. However, CAP has been criticised for benefitting larger farms at the expense of smaller units, a criticism which has been extended to the current reforms. In May 2007, Sweden became the first EU country to take the position that all EU farm subsidies should be abolished, except for those related to environmental protection.

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