205
aimed at delivering benefits for biodiversity, as well as climate change mitigation
under EU Regulation 1307/2013 (Direct Payment Regulation). The greening measures require farmers to observe EU-wide rules on crop diversification, the protection of permanent grasslands, as well as the establishment of Ecological Focus
Areas, as a condition for receiving direct payments (income subsidies) during the
2014–2020 programming period (EU Regulation 1307/2013, Articles 43-47). In
particular, the European Commission envisioned that they would ‘ensure that all
farms deliver environmental and climate benefits through the retention of soil carbon and grassland habitats associated with permanent pasture, the delivery of water
and habitat protection…and the improvement of the resilience of soil and ecosystems through crop diversification’ (2011a). The significance of the greening measures is further underscored by the decision to make 30% of direct payments
(income subsidies) subject to their compliance.
Despite initial claims by the EU Commission regarding the potential for these
measures to improve the environmental dividends of the CAP, implementation
appears to have fallen short in a number of ways (Matthews 2013). For instance,
implementation of the greening measures has been significantly restricted by exceptions to the general rules and minimum standards that were originally intended to
have the broadest possible application (Hart and Menadue 2013). Thus, in 2018,
3 years after the greening measures entered into force, the JRC estimated that 71%
of EU farmers remained unaffected by their introduction and incurred no compliance costs to this effect (Louhichi et al. 2018). For the 29% of farmers who were
affected, the vast majority were only marginally so, with the Court of Auditors finding that, on average, the greening subsidies significantly exceed the cost to farmers
of meeting the greening requirements (2017).
The high rate of farmers that are wholly or partially unaffected by the greening
measures raises serious doubts about the level of ambition reflected by the current
agri-environmental framework (Hauck et al. 2014). Indeed, environmental action
groups have continuously warned that low thresholds for compliance, combined with
broad exemptions from the general rules were destined to render the greening measures largely ineffective (Hart and Menadue 2013). They also levelled wide- scale
criticism against the Commission for its design of the measures. In particular, the
Institute for European Environmental Policy has questioned the choice by the
Commission to introduce crop diversification, which requires farmers to grow a minimum number of crops relevant to the size of the holding, rather than crop rotation,
which requires farmers to change the crops grown on each land parcel from one year
to another, with evidence that the latter is likely to produce greater environmental
benefits over time (Hart 2015). This was also recognised by the Commission in a 2011
Impact Assessment, which found that the introduction of crop diversification ‘may not
bring the full environmental benefits of crop rotation’ (2011b). Despite this conclusion, the Commission nonetheless chose to support the adoption of the crop diversification measure on the basis that it would better fit the annual nature of CAP payments.
Together with other notable shortcomings, which are beyond the scope of the
current discussion, the implementation of the greening measures has certainly left
much to be desired in terms of their environmental impact. With regards to
Agriculture in the European Union: Seven More Years of Environmental Austerity?
aimed at delivering benefits for biodiversity, as well as climate change mitigation
under EU Regulation 1307/2013 (Direct Payment Regulation). The greening measures require farmers to observe EU-wide rules on crop diversification, the protection of permanent grasslands, as well as the establishment of Ecological Focus
Areas, as a condition for receiving direct payments (income subsidies) during the
2014–2020 programming period (EU Regulation 1307/2013, Articles 43-47). In
particular, the European Commission envisioned that they would ‘ensure that all
farms deliver environmental and climate benefits through the retention of soil carbon and grassland habitats associated with permanent pasture, the delivery of water
and habitat protection…and the improvement of the resilience of soil and ecosystems through crop diversification’ (2011a). The significance of the greening measures is further underscored by the decision to make 30% of direct payments
(income subsidies) subject to their compliance.
Despite initial claims by the EU Commission regarding the potential for these
measures to improve the environmental dividends of the CAP, implementation
appears to have fallen short in a number of ways (Matthews 2013). For instance,
implementation of the greening measures has been significantly restricted by exceptions to the general rules and minimum standards that were originally intended to
have the broadest possible application (Hart and Menadue 2013). Thus, in 2018,
3 years after the greening measures entered into force, the JRC estimated that 71%
of EU farmers remained unaffected by their introduction and incurred no compliance costs to this effect (Louhichi et al. 2018). For the 29% of farmers who were
affected, the vast majority were only marginally so, with the Court of Auditors finding that, on average, the greening subsidies significantly exceed the cost to farmers
of meeting the greening requirements (2017).
The high rate of farmers that are wholly or partially unaffected by the greening
measures raises serious doubts about the level of ambition reflected by the current
agri-environmental framework (Hauck et al. 2014). Indeed, environmental action
groups have continuously warned that low thresholds for compliance, combined with
broad exemptions from the general rules were destined to render the greening measures largely ineffective (Hart and Menadue 2013). They also levelled wide- scale
criticism against the Commission for its design of the measures. In particular, the
Institute for European Environmental Policy has questioned the choice by the
Commission to introduce crop diversification, which requires farmers to grow a minimum number of crops relevant to the size of the holding, rather than crop rotation,
which requires farmers to change the crops grown on each land parcel from one year
to another, with evidence that the latter is likely to produce greater environmental
benefits over time (Hart 2015). This was also recognised by the Commission in a 2011
Impact Assessment, which found that the introduction of crop diversification ‘may not
bring the full environmental benefits of crop rotation’ (2011b). Despite this conclusion, the Commission nonetheless chose to support the adoption of the crop diversification measure on the basis that it would better fit the annual nature of CAP payments.
Together with other notable shortcomings, which are beyond the scope of the
current discussion, the implementation of the greening measures has certainly left
much to be desired in terms of their environmental impact. With regards to
Agriculture in the European Union: Seven More Years of Environmental Austerity?