Written Statement - Welsh Government response to the European Commission’s consultation on CAP Greening

The Common Agricultural Policy provides support worth around 300 million euros per annum from Europe to the agricultural sector in Wales. This support is vitally important at a time when the Welsh Government and the industry are working side by side through our Strategic Framework for Agriculture to help deliver a prosperous and resilient future for farming. 

During the last round of CAP reform the European Commission expressed its determination to increase the environmental outcomes achieved via farm subsidy payments – the so called Greening of CAP. The Welsh Government is fully supportive of the principle – as are many within the agriculture industry - that farmers should play their full part in protecting the natural environment as a condition of receipt of   significant amounts of public funding. 

It is clear from my discussions with both farming bodies and environmental stakeholders, however, that the greening measures currently in place have  resulted in unwanted complexity for both farmers and government without delivering the substantive environmental benefits that had been hoped for. I am therefore pleased that Commissioner Hogan has included a fresh look at the Greening measures as part of his agenda to simplify the CAP. This is further evidence that the European Commission is listening and reacting to Member State representations and  is willing to engage in a positive manner  to ensure that policies reflect our concerns and the important environmental outcomes that we are seeking. 

The Welsh Government was given the opportunity to comment individually, rather than as part of a broader Member State response, to the European Commission’s consultation on CAP Greening. This is important given the differences in farming systems across  the UK. 

Our response was submitted on 8 March and in it we re-iterated the importance of  all elements of CAP being able to demonstrate that they offer good value for public money. Pillar 1 represents the overwhelming bulk of the spend  and as such must deliver environmental goods and services alongside those to be achieved through the smaller Pillar 2. The Welsh Government believes that cross-compliance under Pillar 1 is an important tool for achieving environmental outcomes and offers more potential benefit than the administratively complex greening measures applied to the Basic Payment Scheme.  

It is also clear that there are differing interpretations of the Greening rules across Europe and even within Member States demonstrating that the current rules are not as clear as they need to be. This situation brings with it a real risk of farmers from different areas within the EU being placed at relative competitive disadvantage – something CAP is specifically designed to prevent.  To avoid these risks, the Welsh Government believes that Pillar 2, taken together with transposition of EC directives into domestic regulations, continues to offer the best opportunity to deliver environmental goods and services in an administratively efficient and targeted manner; a manner that importantly can be clearly understood by farmers.  This will see Pillar 1  retaining its position  as the pre-eminent  policy through which we sustain and increase food production and provide additional value and environmental protection through the less complex and more easily understood  framework of cross compliance. 

We have also, for completeness, outlined our more specific concerns about how Greening has been applied in practice in the event that the European Commission should decide to retain some elements of Greening within Pillar 1.  Specifically, the Welsh Government response highlighted the following key areas for improvement:

• Crop diversification: The impact of Greening, in the Welsh context, is most challenging for the arable sector.  Farms with 10ha – 15 ha of arable area are usually small family farms, predominantly grassland livestock units, growing arable crops for home feed and possibly selling some surpluses. The Welsh Government has highlighted that these farms are being penalised for offering some diversification over a complete pasture system and have  the unhelpful and unwanted expense of growing a different arable crop.  

• Ecological Focus Area (EFA): The rules surrounding Ecological Focus Area (EFA) have also caused concern. To be eligible as an EFA currently, landscape features such as hedges and wooded strips are required to be adjacent to arable land.  If the farm is not wholly arable this may be difficult to achieve.   
• Impact on agri-environment and climate measures: Greening also has consequential impacts on the Welsh Government’s ability to implement effectively its principal agri-environment and climate scheme (Glastir).  Incorporating arable options is a hugely desirable requirement of these schemes, particularly to arrest the decline in rare farmland bird species. However, crop diversification can be a problem for farmers in Glastir, particular those that produce small areas of arable of between 10ha and 15ha.  The farmers involved often struggle to find additional arable areas for crop diversification (to avoid dual funding with Glastir) and this may prevent them joining the scheme altogether at the expense of the much wider environmental outcomes they might have delivered.  

• Administration:  The administration of Greening is  complicated for the farmer and has significant  administrative overheads. The reduction calculations for greening payments are also difficult to explain and therefore not fully understood by farmers when applied, increasing the likelihood of appeals and additional costs and time on the part of both government and farm businesses. 

The European Commission is due to release the results of its consultation in early summer and I look forward to seeing early progress being made towards a simpler and more effective delivery mechanism that will still guarantee the delivery of positive environmental outcomes from CAP.