Scoping the environmental implications of Pillar 1 reform 2014-2020

The Land Use Policy Group (LUPG) of the UK conservation agencies have published a report, written by IEEP, setting out the way in which a range of Member States have chosen to implement certain aspects of Pillar 1, including key elements of greening and the treatment of ineligible features and minimum activity requirements for farmers. It highlights the potential environmental implications of some of these choices and suggests a number of ways in which the environmental performance of greening could be improved. These include:

• The designation of additional areas of Environmentally Sensitive Permanent Grassland (ESPG) outside Natura 2000 areas that are currently unprotected and whose protection from cultivation would benefit the conservation of soil carbon, the retention of biodiversity, the protection of the historic environment or other environmental benefits.

• Restricting the options available to fulfil the EFA requirement to those which have been shown to have environmental benefits, including the restriction of the use of nitrogen fixing crops to those that have proven environmental benefits (such as pasture legumes) and/or the application of other conditions to mitigate the potential for post-harvest or post-cultivation leaching of nitrogen.

• Greater use of equivalent practices that are specifically designed to address environmental issues in the territory to which they are applied. To encourage the adoption of equivalent practices by farmers it is suggested that they could be made a prerequisite to the receipt of certain AECM funding, as in Austria. The possibility of Member States designing equivalent practices to be the sole route to meeting the greening requirements would also be worth exploring. The report also highlights the fact that the current control requirements, particularly for EFAs, are proving extremely challenging, both technically and logistically and that the scale of this challenge appears out of proportion to the likely environmental benefits. This has been recognised by the Commission and solutions are being considered. It is suggested that where this releases resources, a proportion of these could be redirected to developing more effective systems for monitoring and evaluating the environmental effectiveness of environmental instruments within the CAP.

Rules surrounding the eligibility for Pillar 1 direct payments continue to cause problems for certain types of land in some countries, particularly those with trees and scrub and/or with very low stocking densities, much of which is of High Nature Value. This can lead to perverse situations in which the optimal environmental management of significant areas of marginal land can render them ineligible for Pillar 1 payments. The consequences are often either inappropriate intensification of the management to render them eligible, or increased costs in Pillar 2, as payments to manage these areas, for example under the agri-environment-climate measure, include compensation for the income foregone as a result of ineligibility for the Basic Payment.

The report concludes that the next reform process, on which debates are already starting, provides an opportunity to resolve these tensions and find a rationale for the CAP that enables a coherent and consistent approach to the management of land for environmental, social and economic purposes.

For further information, please contact:

Kaley Hart, IEEP:

Maria de la Torre, Scottish Natural Heritage:

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15 Mar 2016


Kaley Hart