HomeProgressCAP, pesticides and biodiversity. Report of the EU Court of Auditors

CAP, pesticides and biodiversity. Report of the EU Court of Auditors

'Has the CAP contributed positively to maintaining and strengthening biodiversity?'The European Court of Auditors - in the special report no. 13/20 (1) - analyzes the impact of the instruments envisaged by the Common Agricultural Policy (CAP) on the objectives of the EU Biodiversity Strategy until 2020 (published in 2011). Which has been updated, among other things, with the Communication 20.5.20. The commitments declared by the European Commission are insufficient to guarantee the achievement of Objective 3.a of the Strategy, to conserve and increase the biodiversity of agricultural land. A deepening.

EU Biodiversity Strategy, Objective 3.a

Objective 3.a of the EU Biodiversity Strategy is still a long way off, warns the Court. And it is necessary to ensure that the CAP 2021-2027 - now under negotiation - effectively guarantees the maximum extension of agricultural areas cultivated with meadows, arable land and permanent crops. Faced with the need to ensure both the improvement of species and habitat dependent on agriculture (i.e. linked to its effects), and the promotion of a more sustainable management of rural environments.

The loss of biodiversity and the collapse of ecosystems are closely linked to the climate emergency, as seen. And they represent the main threats to the survival of the planet in the coming decades, in terms of both probability and impact. As noted, without however proposing any suitable solution, al World Economic Failure (o Forum, depending on your point of view) of January 2020.

A recent study of the European Environment Agency (2019) confirmed that the intensification of agriculture in recent decades has represented one of the main causes of the reported problems. As they show:

- the Farmland Bird Index, avifauna index in agricultural areas (-34% of common species in agricultural areas, from 1990 to 2017) e

- lo European Grassland Butterfly Index, the index of butterflies in the meadows. These bioindicator insects have almost halved in a quarter of a century (-39%, from 1990 to 2017), although the death is almost stabilizing since 2013.

The latest reports provided for by Natura 2000 (even though the project is not yet completed) and by the Birds and Habitats Directives, in turn record a dramatic increase, from 69% to 72%, in habitat with an 'unfavorable' conservation status.

CAP 2014-2020 and Biodiversity Strategy, which coordination?

The Court assessed whether Objective 3a of the Strategy up to 2020 was specific, measurable and achievable, relevant and timed. What if the 2014-2020 CAP were consistent with it. First weak point, the policies in question refer to different time frames. CAP and EU budget follow a seven-year cycle, Biodiversity Strategies cover 9 or 10 years. The major gaps were identified in terms of feasibility, relevance and measurability (the 2011 Strategy had a deadline, set at 2020, and envisaged specific measures).

There are no indicators accurate and timely to evaluate the progress of the actions. Of the 13 rationalized European indicators of biodiversity (Streamlined European Biodiversity Indicators, SEBI), the Commission has regularly updated only 5. For the remaining 8, however, the latest data date back to 2014 at the latest.

The concept of 'agricultural area of great natural value'(High Natural Value, HNV) was introduced by the European Commission in 2005 for the monitoring of areas characterized by low intensity agriculture. But the Commission itself - given the substantial lack of data on the extension of HNV areas in the latest reports on rural development (June 2019) - has decided to exclude it from the post-2020 CAP.
In the absence, among other things, of the coordination envisaged by the Biodiversity Strategy with Objective 2. The restoration of 15% of degraded ecosystems.

The accounts that do not add up

The quote EU general budget dedicated to biodiversity, according to the Court of Auditors, was determined on the basis of unreliable coefficients (by 'adaptation' to the 'Rio markers' of the OECD, Organization for Economic Cooperation and Development OECD). In the 2014-2020 CAP, the Commission claims to have dedicated 8,1% of the EU budget, equal to 86 billion euros, to biodiversity, but since 2017 the Court complains that the support is ineffective.

Direct payments of the Greening, for example, they only encouraged changes in agricultural practices in 2% of arable land and 1,5% of permanent grassland. The general failure of the Biodiversity Strategy up to 2020 compared to Objective 3a was reiterated, moreover, by the European Commission itself in the mid-term review of 2015.

Direct payments, what impact on biodiversity?

Most of it of EU direct payments has no measurable direct impact on agricultural land biodiversity, notes the Court of Auditors. Indeed, according to some experts, the optional coupled payment would have negative consequences. To the extent that an increase in the levels of financed activity is encouraged, linked to the production of specific crops or animals.

The variegated picture on the other hand, rules and penalties do not guarantee a uniform application of the criteria on direct payments. Small farmers, for example, are not subject to the 1% to 5% reduction that should be imposed in cases of non-compliance with the mandatory management criteria (SMR) and the standards for good agricultural and environmental conditions (GAEC). The latter, in turn, vary from one country to another.

With the 2013 CAP reform, crop rotation has been transformed into crop diversification. Which rarely leads to an advantage for biodiversity since it does not involve a change in agricultural practices. And it has become an eligibility requirement, no longer a cross-compliance, also reducing the number of farmers to which it applies.

Greening should have encouraged the conservation of biodiversity but currently only 5% of the areas have been subject to changes in agricultural practices (the scheme does not apply to small farmers, organic farms and those who hold more than 75% of permanent grass).

The European Commission, in 2017 and 2018, stressed that States should have made greater efforts to ensure their progress and the achievement of the objectives (as required by Action 8a of the Strategy until 2020). But only four Member States or their regions (Luxembourg, Latvia, Czech Republic, Belgium-Flanders) have defined some areas reserved for permanent grassland as'environmentally critical area ', on less than 300 thousand million hectares of agricultural land in the Union.

The absence of valid indicators impact or result of cross compliance and greening on the biodiversity of agricultural land available to the Commission does not allow, also in this case as above, to correctly assess the level of biodiversity protection.

The potential of the II CAP pillar

Agro-climatic measures environmental protection, organic farming and Natura 2000 are, according to the national authorities visited, the most effective measures of the rural development programs for the protection of biodiversity. Potentially capable of fulfilling Action 9 of the 2011 Strategy, 'better target rural development to conserve biodiversity '.

Farmers though they tend to apply less demanding but low impact measures (the 'light green measures'). Rather than the high-impact ones (the 'dark green measures'), which are more expensive, specific and complex but are subject to more funding. And efforts to improve arable land are also scarce, which is associated with much of the responsibility for the decline in biodiversity.

Only 2 of the 46 sizes established agro-climatic environmental conditions are based on results, the rest on land management. According to the Court and the experts, the former have the greatest impact on conservation and increase of biodiversity. They ensure greater room for choice for farmers with respect to how the land is used and above all they make them responsible, binding them only to results. Not to mention the greater public recognition of their role.

In any case, it is difficult evaluate the impact of rural development plans since, also in this case, appropriate indicators are missing in the Monitoring and Evaluation Framework of the CAP 2014-2020. In 2006 the Commission added another 28 agri-environmental indicators which, however, were not regularly updated, some not even published.

The recommendations of the Court of Auditors

The decline of biodiversity in agricultural land it is a certain fact, despite the difficulty in measuring the degree and impact of the actions of the Strategy up to 2020. The international commitments relating to the Convention for Biological Diversity and the respective Aichi objectives were not respected. If by 2030 it is intended to achieve Objective no. 15 of 17 Sustainable Development Goals (SDGs) in the UN Agenda 2030, 'Life on Earth', a transformation is needed. The Court of Auditors makes 4 recommendations, addressed to the European Commission:

1) Direct payments account for 70% of EU agricultural expenditure but their impact on biodiversity is limited, if not negative. Concrete and measurable actions are needed in the post-2020 CAP, in synergy with the Member States, for the full realization of the Agriculture objective of the new Strategy up to 2030. It will also be essential to review the procedures for registering budgetary funds for biodiversity and the penalty system (deadline 2023),

2) the post-2020 CAP must increase direct payments linked to environmental public goods, especially biodiversity. Bearing in mind that rural development instruments have currently had the greatest impact on the conservation of biodiversity on agricultural land (deadline 2023),

3) increase the contribution of rural development, given its greater potential compared to direct payments, and ensure that the National Rural Development Plans include actions in favor of biodiversity in agricultural land (deadline 2023),

4) introduce valid indicators to assess the results and impacts of the CAP instruments on agricultural land biodiversity (deadline 2022).

The Commission's replies

The European Commission had already identified these shortcomings in the evaluation report on the impact of the CAP on habitat, landscapes and biodiversity (2019). Underlining how, in addition to not having used the CAP tools sufficiently, the conception and financing of environmental agro-climatic measures for companies that practice intensive agriculture are not yet able to encourage the introduction of management changes useful to protect the biodiversity.

In the reply to the Court of Auditorshowever, Brussels argues that coordination with the Member States would be adequate and that the CAP instruments would have made it possible to make numerous improvements at the local level. Without providing any evidence in this regard, except instead acknowledging that biodiversity raises serious concerns on a general level.

The future CAP, continues the Commission, will be more projected on results with suitable indicators. But he points out that they are not the only ones usable and in some cases like the agricultural areas of great natural value, a unique index is inappropriate given the different availability of data and different physical situations.

The overestimation complaint expenditure on biodiversity is not demonstrable and the coefficients used by the Commission would be duly developed in the absence of an OECD validated method. And the voluntary coupled payment scheme, notified to the World Trade Organization (WTO) under the blue box, would not have a negative impact on biodiversity as it is intended for specific products and in difficult situations. Furthermore, according to the Commission, the complaint against cross compliance, wholly associated with a positive impact on biodiversity, is unjustified.

There are no 'light green' or 'dark green' measures, the Court has slipped into oversimplification, the Commission insists. Moreover, the reduced application of the latter is essentially due to their application in limited and specific areas.

Basic to follow the logic of the Commission's reflection is the concept according to which direct payments are not aimed at the protection of biodiversity (except greening), but, without a doubt, 'the broad adherence to these measures by farmers allows raising awareness of environmental standards through cross compliance'.

Future perspectives

The new Biodiversity Strategy up to 2030, the Agriculture objective declines as the need to allocate at least 10% of agricultural areas to characteristic elements of the landscape with high diversity. For example buffer strips, complete or rotational fallow (introduced in 1988 but no longer mandatory since 2009), hedges, non-productive trees, terracing or ponds, also to prevent soil erosion, intensify carbon sequestration, filter air and water. In addition to the new objectives with respect to the reduction of chemical pesticides (-50% by 2050) and the increase in land destined for organic farming (+ 25% by 2030). Words words words.

A land richer in biodiversity it is usually even more productive. L'agroecology it will have to guide the change, within which a privileged space is also left to the protection of the genetic variety and of the pollinators.

Dario Dongo and Marina De Nobili


(1) European Court of Auditors. Special Report No 13/20. Biodiversity on farmland: CAP contribution has not halted the decline


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