This scenario is at the most extreme end of the scale and proposes a total reform of the CAP, including the phasing out of subsidy under Pillar 1 and significantly increased funding for
36 Jana Poláková, Graham Tucker, Kaley Hart, Janet Dwyer, Matt Rayment, ‘Addressing biodiversity and habitat
preservation through Measures applied under the Common Agricultural Policy’ (Report Prepared for DG Agriculture and Rural Development, Contract No. 30-CE-0388497/00-44. Institute for European Environmental Policy: London, 2011)
37 European Commission, ‘Common Agricultural Policy towards 2020’ (Staff Working Paper – Impact
74
measures related to climate change and the environment under Pillar 2. In this instance Pillar 2 would, in effect, be the only remaining element of the CAP.38
However, the Impact Assessment identifies any benefits gained by the greater focus of rural development funding on climate change and the environment measures as failing to
counteract the significant negative impacts which the changes to Pillar 1 subsidies would have:
A phasing out of direct payments would lead to strong restructuring in the sector and much larger and more capital intensive farms. Production intensification in the most fertile regions and land abandonment in less advantageous areas would have
negative environmental consequences. Focusing policy on rural development-type environmental measures would alleviate these problems, but would not contribute to enhancing the sustainability of agriculture.39
Under this scenario there would also be a significant redistribution of the rural development budget with a new, exclusively environmental focus; this would result in the UK receiving around twice the EU allocation it received in 2013, whilst Member States such as Finland, Sweden and Spain would receive around half the funding they were allocated in that year.40
As mentioned above, the major environmental impacts of this scenario would be
intensification of agricultural practices in some areas and land abandonment in others, and
38 Ibid 72 39 Ibid 40 Ibid 74
75
whilst land abandonment may provide opportunities for ‘wilderness’ type environmental conservation, overall the combination of intensification and abandonment is forecast to have detrimental impacts on biodiversity, particularly for those already threatened species which rely on extensively managed agricultural habitats.
In addition, the phasing out of subsidy under Pillar 1 would remove the incentives for farmers to observe the environmentally friendly aspects of cross -compliance currently included in GAECS41 and SMRs42.
At this point it is appropriate to raise a question about the Commission’s choice of scenarios to include in its proposals; why was such an extreme scenario for the Re-focus option
chosen? Their own analysis has shown that the Re-focus scenario would spell disaster for the agricultural industry on many economic, social and environmental grounds and was never a realistic proposal. When compared to the Adjustment scenario, which would effectively maintain the status quo, and the Integration scenario, which involves significant reform but maintains the current format and focus of Pillars 1 and 2 of the CAP, the Re-focus scenario is impractical.
I would suggest that a scenario further along the continuum towards a focus on
environmental objectives such as the preservation of biodiversity, but which still presented a plausible option, would have been more useful in the suite of proposed scenarios, both as an option in its own right and as a tool for comparison against the other scenarios. Viewed from
41 See Glossary 42 See Glossary
76
another (more sceptical) angle, perhaps the ‘disaster scenario’ of Re-focus was chosen to make the middle-ground scenario of Integration more attractive, despite the suggestion that this does not do enough to address biodiversity loss and climate change.
The importance of the choice of these options for the protection of biodiversity should not be underestimated as we assess the policy design process; by framing the debate around CAP reform within these three options the proposals and Impact Assessment influence the focus of discussion. The Integration scenario is presented as the only feasible option for sustainable agriculture - Adjustment failing to address the issues and Re-focus going too far - so the discussion focuses around Integration-shaped reform. Some arguments call for softer greening measures for the sake of economic or social stability, some call for more stringent greening measures for the sake of biodiversity, climate change mitigation and sustainability, but the accepted model is one which looks very much like the Integration scenario.
If the Commission had presented a less extreme Re-focus scenario which gave an alternative option for CAP reform this may have changed the shape of the debate. For example, an alternative scenario with a greater focus on environmental concerns and scaled down direct payment support, but which retained Pillar 1 support for farmers in areas with natural constraints and less favoured areas. Rather than discussions around a more-or-less green version of the Integration scenario, the focus might have been around which elements of Pillar 1 direct payment support should be kept and which scaled back. This could have changed the entire direction of the CAP reform. As it was, the Re-focus scenario was presented as engendering such complete economic, social and environmental catastrophe
77
that consideration of the benefits of a milder version of some of its elements was discouraged from the first.
Evidence of the skewed choice of scenarios can be found in Section 6 of the Impact Assessment, which compares the scenarios with respect to objectives and impacts.43
Adjustment Integration Re-focus
Economic Sector output +++ ++ +
Competitiveness (short- and long- term) ++/+ +/++ +++ Response to crisis ++ +++ + Social Employment +++ ++ + Income +++ ++ + Territorial cohesion ++ +++ +
Environmental Territorial coverage ++ +++ +
Targeted measures + ++ +++ Long-term sustainability ++ +++ + Simplification ++ + +++ 44
As can be seen from the Table above, the total ‘plus points’ of the Re-focus scenario is significantly less than either the Adjustment or Integration scenario. If the Commission had presented a Re-focus scenario which offered a similar number of total points but offered the highest impact in different areas, as in the comparison between the Adjustment and
Integration scenarios, the debate between scenarios would conceivably have been more balanced.
43 European Commission, ‘Common Agricultural Policy towards 2020’ (Staff Working Paper – Impact
Assessment) SEC (2011) 1153 final/2, 76
78
For example, I would suggest that it would have been possible to propose a scenario which increased focus on environmental sustainability without reducing the agricultural industry’s ability to respond to crisis through retention of Pillar 1 support in cases of agricultural emergency. The extreme restructuring proposed in the Re-focus scenario decreases its usefulness as an option for comparison with the other options proposed.
As is it, the Impact Assessment reaches the conclusion that ‘while the adjustment option may not be sufficiently targeted and the refocus option too risky, the integration option appears to strike the right balance in progressively steering the CAP towards the EU objectives’, though it does acknowledge that ‘several stakeholders pointed towards opportunities coming from combining elements from more than one scenario.45