The last lap on greening: the death knell for EFAs?

The ‘Ecological Focus Areas’ (EFAs), were the boldest and potentially most effective of the three measures for greening Pillar One of the CAP when proposed by the Commission in October 2011. In the recent negotiations involving the Council and European Parliament however they have been at the forefront of what has become a ‘race to the bottom’ with their content being whittled away from several directions. Yet another such dilution has been proposed at this very late stage, with the new CAP within a week of agreement on the present timetable.

As highlighted in our recent paper ‘A greener CAP: still within reach’ the negotiating mandates of the European Parliament and the Agriculture Council this Spring introduced a range of thresholds and eligibility criteria for the three greening measures that reduced the proportion of land to which they applied by up to 40% on average and over 90% in some countries. We argued that these exemptions were excessive and needed to be rolled back if greening were to be credible.

However, a paper from the Irish Presidency to feed into the final week of discussions on greening, appears to attempt to water down any remaining potential for the greening measures to deliver environmental impacts yet further. The paper proposes a set of weighting coefficients which would apply to the various elements that farmers could choose to make up their Ecological Focus Area (EFA).

In principle, the idea of applying such coefficients could be an administratively convenient way of highlighting the relative environmental benefits of the different elements of an EFA - if done in a systematic way, based on the available evidence. Instead, the proposal increases the 'value' of certain features by such a large amount as to bring into question the benefit of implementing an EFA at all.

For example, under this proposal, a single tree can count as 200 m2 towards a farmer’s EFA requirement to devote a percentage (not fixed) of their arable land to an environmental use. One metre of hedge would count as 25 m2 or 50 m2 if the farmer owned fields on both sides (see table here). These coefficients seem hugely exaggerated in some cases and not commensurate with the available evidence on their relative environmental impact. The need to take any new action in order to meet the EFA requirement will disappear on many farms but without withdrawing the paperwork that will be required.

Even the relative values provided by the weightings proposed do not seem to make much sense. Given that a hedge averages 2 metres in width, the coefficients essentially imply that keeping a hedge in place has an environmental impact 12.5 times greater than land left fallow, which is another option. The coefficient for an individual tree is also somewhat extreme, suggesting that no matter its size or age, a single tree is 200 times more environmentally beneficial than one square metre of fallow land or 100 times more beneficial than 1 metre of a 2 metre wide buffer strip.

If these coefficients are agreed, they will reduce yet further the action that farmers will need to take to comply with the EFA measure. The measure that had the most potential to deliver for the environment in arable areas will have lost its capacity to have any significant environmental impact.

If the thresholds and eligibility criteria are not tightened up, then critics will be justified in questioning what in practice this reform has delivered for the environment and whether in fact we will be left with form and no substance.

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18 Jun 2013