Soil Assocation response to the CAP consultation

Question 1: Why do we need a European Common Agricultural Policy?

The CAP needs EU governance to ensure a coherent response to competing national priorities. The EU has the governance structure to pursue collective action at the required scale to meet its own and international commitments related to climate change, public health, water and biodiversity.

Public goods like environment, wildlife, health and climate do not have an adequate price in the market, so their provision depends on state intervention. Public payments can help tackle this market failure, at least in the short term.

Agriculture accounts for about half of the European land area and farming is a key activity for addressing some of this century’s greatest challenges. Stemming the collapse of biodiversity, mitigating and adapting to climate change, providing an affordable healthy diet and maintaining plentiful, clean water resources require profound changes to the ways in which land is managed. Europe’s biodiversity has co-evolved with traditional farming activities and many species currently depend on specific agricultural management. This, as well as the sensitivity of food production, makes farming inherently different from other economic sectors.

Question 2: What do citizens expect from agriculture?

Citizens expect:

• Agriculture that produces healthy, safe and high quality food, reasonably priced, with no hidden costs.
• Agriculture that respects the investment made by taxpayers: rewarding jobs and a contribution to the economic and social well-being of rural areas, wise use of resources and no waste.
• Agriculture that supports other EU strategies (e.g. EU Strategy on Sustainable Development), policy objectives (such as halting the loss of biodiversity) and international commitments (such as the UN Climate Convention).

Citizens expect agriculture that uses natural resources in a rational way:

• Water: sustainable water use, clean rivers and maintenance of watersheds
• Soil: conservation and improvement, not degradation
• Biodiversity: conservation and enhancement, not decline.
• Landscape: conservation and positive management, not disappearance and pollution
• Fire and flooding: prevention and improved resilience
• Climate: Carbon storage and production of renewable fertility and energy, not net greenhouse gas emissions.
• No use of any persistent, bio-accumulative, hormone disrupting pesticides.
• High standards of farm animal welfare.

Question 3: Why reform the CAP?

Only a small share of the Eu53billion CAP budget is currently targeted at clear policy objectives. CAP should help achieve the two crucial policy goals identified in the UK Cabinet Office’s 2008 report: dramatically reduced GHG emissions and a healthier diet (meaning more seasonal fruit and vegetables, less highly processed food and less meat overall, with proportionately more grass-fed dairy and red meat).

The policy does not currently sufficiently encourage farmers to shift towards genuinely sustainable food production without reliance on fossil fuels, pesticides, imported animal feed and phosphorus, or to adopt land management practice that meet the real challenges of the future: climate change, improving water resources, recovering biodiversity and guaranteeing long-term capacity for healthy, secure food production.

Current direct payments fail to support farmers or land managers who specifically require financial help, or those who are delivering most for society by providing environmental goods and services.

Reform is needed to bring the CAP in line with the Budget Heading under which it falls: “Preservation and management of natural resources”.

Question 4: What tools do we need for the CAP of tomorrow?

The CAP should recognise the efficiency of supporting organic farming systems over a policy of individual interventions seeking to achieve environmental and social objectives separately.

Organic farms deliver the public goods that citizens expect as part of the farm business, so will do so regardless of the economic situation of the farm, short of bankruptcy. Organic is currently the only legally defined systems approach to sustainable farming and needs a holistic policy in which public money is used to support the farming system as a whole, such as with flat-rate area payments decoupled from production.

In contrast to a systems solution, reactionary interventions have serious flaws:

• Specific interventions can work against each other (eg. increasing output of milk per cow to reduce GHGs will reduce animal welfare); increasing costs and causing confusion.
• Piecemeal approaches increase administration and compliance costs (and thus reduce money to farmers);
• Specific interventions work additionally to the economic driver of the business (producing food to sell) and are at risk of abandonment when economic conditions decline.

CAP should:

• Move money from Pillar 1 to Pillar 2;
• Increase OELS by £30 per hectare by including 30 additional points to recognise increased soil carbon storage of organic farms.