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The "green" CAP and permanent pastures - national reports show a fundamentally flawed model

EFNCP has published new reports looking at the application of the new CAP to permanent pastures in 6 Member States: Bulgaria, Estonia, France, Ireland, Spain and UK. The overall picture is one of a fundamentally flawed EU policy model, especially for semi-natural or High Nature Value pastures, where the mainstream CAP instruments in Pillar 1 fail to address the main challenges and even exacerbate the threat of abandonment or damaging actions by farmers in some situations.

Some of the key problems in Pillar 1 (direct payments) can be corrected in part by Member States' implementation, if they have the will and administrative resources to make use of all available exceptions and clauses, and can stand up to "conformist" pressure from European Commission auditors (DG AGRI). Pillar 2 (rural development) offers many opportunities for Member States to take positive action for permanent pastures, by investing their own financial and administrative resources, for example in agri-environment-climate measures, but there is no obligation for them to do so.

The result is a mixed picture with some positive examples of policy implementation in certain Member States, but too many examples of negative policy drivers overall, and of CAP instruments for pastures that sound useful on paper but are of very limited practical benefit in reality.

Overall, there are large differences between Member States in levels of financial support to permanent pastures under Pillar 1. If Pillar 2 payments are taken into account, these differences become enormous. For example, an extensive livestock farm in the French Pyrenees can receive hundreds more euros in support per hectare than an identical farm claiming all available payments on the Spanish side of the border.

Some of the key issues highlighted in the reports include:

Pillar 1

  • Pillar 1 payments on permanent pastures vary hugely between countries, with very low payments per hectare in some countries (e.g. Spain, applying minimal convergence), very high payments in some others (e.g. in Northern Ireland) and a range of payment levels in between.
  • The positive option of applying a bonus payment for the first hectares of a holding is implemented only in some of the Member States studied (Bulgaria, France).
  • Coupled payments for livestock again show a wide range of payment levels between countries. In some cases there is positive targeting of these payments (e.g. Estonia, Scotland), while some make the payments available to all farms, including intensive indoor systems. Some countries are not applying coupled payments at all, so there is by no means a level playing-field for livestock farming across the EU.
  • The Pillar 1 eligibility rules applied to pastures with trees, shrubs and/or other landscape features are a major issue in most countries studied. There are very large exclusions of semi-natural pastures from Pillar 1 support in some countries, such as Bulgaria, and major new exclusions in Spain as DG AGRI has demanded a much more restrictive system. Even where the system has improved, there are still considerable exclusions as in Estonia and Sweden. Some countries have found ways to avoid exclusions or losses of eligibility for pastures (e.g. England, France), but their approaches are not seen favourably by DG AGRI.
  • The EU rules governing the minimum activity required to justify Pillar 1 support mean that someone who merely cuts a field of grass every one or two years, leaving the cuttings on the ground without really farming, gets the same payment as an active farmer raising livestock and conserving species-rich pastures through appropriate grazing. This encourages "subsidy farmers" to acquire farmland but not to farm it, a situation quite widespread in some countries (e.g. Estonia and Bulgaria).
  • The CAP mechanism for preventing a decline in the extent of permanent pasture allows ploughing and reseeding of semi-natural pastures, and is thus fundamentally flawed as an environmental measure. New restrictions on ploughing or converting Environmentally Sensitive Permanent Grasslands (ESPG) merely replicate existing protection for grasslands within Natura 2000, but fail to address the widespread threat of abandonment of these grasslands, whether within those sites or elsewhere.

Pillar 2

  • Some countries are implementing positive Pillar 2 measures for semi-natural pastures, especially within Natura 2000 (e.g. in Bulgaria, Estonia, France and UK). Outwith the Natura 2000 network there is far less positive support.
  • Despite clear data held by EC on the unfavourable condition of the majority of semi-natural grassland in Annex 1 of the Habitats Directive in Spain, this country has been allowed to implement yet another round of RDPs that completely fail to respond to the challenges of the EU Biodiversity Strategy, making very little use of agri-environment-climate or Natura 2000 measures for improving the condition of these habitats.
  • The new CAP Indicator on Farmland Habitats (grasslands) is weakened by lack of comprehensive monitoring of the condition of these habitats in many countries, but good monitoring systems are of no use if Member States are not required to respond to what the indicator shows when designing or reviewing their RDPs.

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European Forum on Nature Conservation and Pastoralism
Date: 2024/06/18
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