As one main element of the EU’s CAP-Reform 2013, the Greening of EU Direct Payments has been implemented for in 2015 the first year. In the last weeks some first data on the implementation of Greening and the Ecological Focus Area (EFA) were unofficially presented by the EU Commission. I want to share these data and do a bit of commenting on them.
As already reported on this website, farmers have to fulfill three criteria (crop diversification, maintenance of permanent grassland and the ecological focus area (EFA)) to receive 30% of the direct payments. There are some exemptions for very small farms (< 10 ha), some simplified criteria for small farms (10-30 ha) and some exemptions for farms with a high share of permanent grassland or fodder production on arable land. The EU-Commission provides some general information on greening and the member-states had some flexibilities in the implementation of Greening on a national level. So most of the information were provided by national authorities, since the Greening-regulations are dependent on the decisions taken in the member-states.
In December 2015, EU member states had to report the figures of the first year of implementation to the EU-Commission. On this website, I already reported on the implementation of Greening and EFA in Germany, since the German ministries (in the Federal States and in Berlin/Bonn) published the implementation data in great detail. So it was possible to draw some first conclusions, even though it is clear, that farmers choices will still change to some extent in the next years, when all the details are known and farmers have more time to take their decisions how to comply to Greening.
The EU-Commission also published a document on the national choices with respect to all the flexible element of the CAP-Reform. From this document, it is clear that on the national states took the full flexibility of national decision. With respect to the ecological focus area, different options are offered on the national level. The following figure 1 shows the number of countries in which the different EFA-options are chosen:
So the most chosen option are 1.) nitrogen fixing crops, 2.) land lying fallow and 3.) Landscape features. Figure 2 illustrates the number of options chosen in the EU member-states:
14 member states have chosen 10 or more EFA-options. Obviously, large countries like Germany, France, Italy and Hungary took the administrative challenge to provide a large number of options for their farmers (17-18 EFA options), which also includes a substantial administrative costs. On the other hand, nine of the member states only offered a moderate choice of 5-9 EFA options and only five member states offered rather few options to their farmers (2-4 EFA options).
Greening causes substantial administration costs and efforts
We know the offered EFA-options in the member states and some implementation data from single member-states. But it turned out to be very difficult to get concrete EFA-data from other member-states. Some ministries were very constructive and helpful and gave data to our research-group. However, even the EU could not get all the data by 15.December 2015. It was obviously difficult to implement Greening into the EU’s Integrated Administration and Control System (IACS) of direct payments. Many representatives, to which we were talking to in the last months, reported difficulties in implementing Greening. The result is, that many countries delivered the data from January to March 2016, and France is still to deliver. Besides the control and administration systems of Pillar II. and of Cross Compliance (CC), we now find a third bundle of regulations, where the administration has to perform controls and register data etc.. So the term „simplification“ is not meaningless in that sense, that the implementation of Greening causes a lot of administrative burden and the overlap of three different control scheme needs simplification. And simplifying without reducing the ecological impact, will be a great challenge of the next mini-reform 2017.
EU-Implementation of Greening & Ecological Focus Area 2015
The EU-Commission announced to publish the first detailed evaluation of data in May/June 2016, however at different conferences in the last weeks, some preliminary data were presented. On April 05, 2016, the European Landowners Organization (ELO) held a meeting titled “A Sustainable European Agriculture: Is Greening the Way Forward?„. At this meeting, Joost Korte, (Deputy Director-General at the DG Agri in the EU Commission) reported some first preliminary figures on Greening on the EU-level. Those figures (probably) do not include the data from France. I also received data from other sources in Brussels, however these figures are preliminary (!) and still subject to data control. However, I still want to present the data here to give some first ideas, how Greening was implemented in Europe. The debate on the further development of Greening will be done this year, because on March 31, 2017 the EU Commission will present a report on the implementation. The public needs to follow up in the debate and influence the discussion. Therefore, even preliminary data might help.
The first figures are about the question, on how much land Greening was implemented: On 73% of the land, at least one Greening criterion was implemented and around 40% of the farms had to comply to at least one criterion. Crop diversification was relevant on 79% of the EU arable land. 67% of the arable land was with obligations of 3 crops, and 12% of 2 crops. This means that 21% of the arable land was excluded from Crop Diversification, which is even more than the first estimates of Pe’er et al. (2014, in Science), who estimated 13% of the arable land to be excluded.
My own calculations and also the calculations of Thünen Institute estimate that around 10% of the farms have problems with the Crop Diversification criterion, but Farmers need to do only small adjustments. In Germany, the main effect of Crop Diversification is to correct a bit of the negative side-effects of the national Biogas-support, which lead to a high share of maize in the crop rotations. Maize is the main crop, which causes problems in Crop Diversification. I would suggest to correct the Renewable Energy Act (EEG) in Germany and leave away the Crop Diversification criterion. I don’t see much of an effect.
Based on Mr. Korte’s report, the Ecological Focus Area (EFA) was relevant on 70% of the arable land. I.e. 30% of the arable land is exempted. The farmers mainly implemented land lying fallow (35% of the arable land after applying the weighting factors), nitrogen fixing crops (38%) and catch crops (15%). Landscape elements (4.5%) and buffer strips (5.9%) are of minor importance.
Other sources from Brussels also report, that there is substantial ‚overbooking‘ on EFA: EFA has a share of 16% of the arable land subject to EFA before applying the weighting factors (WF) and 10% after WF. However, the obligation is just 5% (after weighting factors), so farmers registered far more than necessary in order to avoid problems with controls. This also suggests, that the main debate should not be about the questions whether 5% or 7% of the arable land are necessary. It should be more about which options are useful and effective to target biodiversity problems.
The preliminary land-shares of the different EFA-options are shown in figure 3:
The ‚productive options‘ catch crops and nitrogen fixing crops together take the largest part (53%). Landscape elements and buffer strips, as very effective measures to protect species and link structures within the landscape, have only 11% of arable land (after applying WF). Note that the real shares are given by the figures before applying weighting factors (WF), so the proportion of landscape elements and buffer strips are around 5% alltogether. Countries with the largest shares of landscape elements are Ireland (by far!), United Kingdom, Malta, (surprisingly) Germany and Sweden. Buffer strips are of the registered in Denmark, United Kingdom and Ireland. Also interesting is the fact, that many of the two forest-options don’t play a role: There is a bit of short rotation coppice in Finland and Denmark and a bit afforested area in Portugal, Poland, Hungary and Spain. But on the EU-levels, these options play with 1% a minor role.
If we take a look into the main reform document, EU-Regulation No. 1307/2013 of the European Parliament and of the Council of 17 December 2013, into argument (44), we find the main motivation for the Ecological Focus Area (EFA): „Ecological focus areas should be established, in particular, in order to safeguard and improve biodiversity on farms„. So EFA is about Biodiversity! Ecologists tell us, that mainly buffer strips, landscape element and land lying fallow only show a significant impact on biodiversity. The other elements might be in one or the other way beneficial for the environment in general, however their effect on biodiversity is probably rather limited.
Conclusions: A substantial reform of Greening or beyond is necessary
The preliminary data show that only about 45% of the EFA-area (after WF) useful options are chosen. If we take real area, the share is just about 26%, which is disappointing. There is a lot of water in this system, especially if we take into account the administrative costs to implement Greening. Note that the figures vary substantially between the member states. So I am already looking forward to analyze the full published data-set. Note also that some national experts evaluate the EFA-effects a bit differently across the countries.
The figures clearly show: Greening and the EFA is not the best instrument to perform targeted support of biodiversity and especially endangered species! EFA might contribute for a more broad extensification of arable land – if we take this as an objective for EFA. So from an environmental point it might be worth to think about a pragmatic improvement of EFA. But we need other more effective instruments for a targeted support of biodiversity and endangered species. Greening and EFA are not the solution to this problem.
It is still to early to give a final comment on the figures, since we don’t have more precise and detailed data. And 2015 is just the first year, so given the low commodity prices for agricultural goods, I would expect e.g. the fallow land to be chosen more often in 2016. Also the buffer strips might gain a bit, since the regulations are more clear this year and farmers know how to implement buffer strips.
On the other hand, my two main argument would still be the low efficiency of EFA and Greening and missing effectiveness for endangered species. And remember: The endangered species are the main objective of EFA. This still highlights the potential but also the necessity to substantially adjust the EFA-measures and to financially increase the share of Pillar II and also to reform Pillar II-programs. I will comeback to this in a few months, when more data are available.
Did I miss something or is something unclear? Just write or comment, I am happy about feedback!
Thanks to Dr. Jürgen Wilhelm from the Ministry for Agriculture in Lower Saxony for presenting some of the data in Loccum and for fruitful discussion. Also note that not all data stem from Dr. Wilhelm and I won’t take any guarantee on the data, which are still preliminary.