VOICE is a member of the European Environmental Bureau. Below is an EEB press release on leaked details of the upcoming Common Agricultural Policy reform. This policy has sigificant implications for the the impact of agriculture on the EU's environment.[12th September, Brussels] Environmental NGOs and farmers condemned plans to greenwash the Common Agricultural Policy (CAP) as revealed in a leaked Commission document. The green groups say that unless the proposals are overhauled to provide real environmental commitments, the policy will remain devoid of any legitimacy.NGOs believe that while the Commission proposal superficially commits to greening the CAP and to rewarding farmers that deliver public goods, a close analysis shows that most of the commitments are fake, empty or seriously underwhelming.No additional support is envisaged for farmers maintaining protected natural habitats in the Natura 2000 network or managing extensive grasslands that are crucial for biodiversity and the climate.All farmers will continue to receive subsidies, even those that practice highly unsustainable farming methods, provoke soil erosion or pollute and over exploit water resources. The leaked draft also reveals funding for targeted and effective schemes to raise the environmental performance of farms could be decreased.Environmental NGOs and farmers are calling on the Commission to radically improve the proposal and put substance behind their green rhetoric.See below reactions from involved NGOs:“The current proposal is a smoke and mirror show”, said Ariel Brunner, Head of EU Policy at BirdLife Europe. “The environmental movement has been supporting a significant budget allocation for a reformed CAP but will not go along with a window dressing exercise that keeps pumping money into Europe’s most environmentally harmful farms”.“It is shocking to discover that under a headline of greening the CAP, the Commission is actually proposing measures that could be a step backwards. If adopted, this would not only mean that the same farmers will be paid to continue farming in the same damaging way, it would also fail to restore this current policy’s lost legitimacy,” commented Faustine Defossez, EEB Agriculture and Bioenergy Policy Officer.Matthias Meissner, WWF Germany, Policy Officer International Agriculture added: “In these times of austerity, the European Commissioners must make it crystal clear what the effects of CAP money will be in the future. It would be outrageous for EU taxpayers’ money to be spent on supporting farming practices which put at risk food supply for future generations, by destroying the ecological and economic basis of our agricultural system.”“Progress in terms of sustainable development of rural economies and farms needs to see the designation of a significant part of the budget to agri-environment and organic farming; something lacking in the current proposals” adds Marco Schlüter, Director of IFOAM EU Group. “Multiple challenges cannot be met with business as usual, but need investments in comprehensively sustainable food systems.”NOTES(1) Analysis of the leaked CAP reform proposal-Farmers will NOT be required to respect the Water Framework Directive, the EU’s key legislation protecting water resources, nor the Sustainable Use of Pesticides Directive. The leaked regulation only envisages the possibility for the Commission to expand cross compliance, the basic rules all farmers receiving public money are supposed to respect, to cover these pieces of legislation once all Member states have fully implemented them, which means that even one non complying Member States could block the introduction of the EU wide compliance.-No incentives are being introduced for farmers managing extensive grasslands, which are crucial both for biodiversity conservation and for as carbon stocks. This means that sustainable extensive grazing will keep being out competed by unsustainable factory farming and other forms of harmful livestock operations. This would be further compounded by the flawed definition of grassland that will shut out of support some of Europe’s most valuable High Nature Value farming systems, and by the offer of new old stile production subsidies for arable crops. The protection regime against ploughing up of grasslands, a potentially crucial improvement is riddled with loopholes and based on unclear processes.- No extra pillar 1 support is foreseen for farmers managing land in the Natura 2000 network, the EU wide system of areas protected for biodiversity, about half of which is managed by farmers. This flies in the face of the claim that income support will be more closely realigned with the provision of public goods.-The so called “greening component” of pillar I (30% of direct payment supposed to be attached to good practice commitment) is extremely weak and likely to go to most farmers just for carrying on unsustainable business as usual practices.No rules to prevent soil erosion and degradation are introducedNo crop rotation obligation is introduced and the “diversification of crops” requirement is made empty by allowing a farm to have 70% of the land covered with one monoculture 25% by a second monoculture with just 5% of a third crop. This means that a farm with 70% maize, 30% oil seed rape and a potato field thrown in, would be considered “sustainable”.One of the very few positive changes would be the introduction of a requirement to keep 7% of farm area as Environmental Focus Areas (i.e. valuable habitats and landscape elements such as hedgerows, field margins and ponds). This figure is still lower than the 10% considered necessary by the scientific community.-The sanction system remains exceedingly weak meaning that farmers not respecting their commitments would get away in most cases with just warnings or irrelevant penalties such as withholding of 1% of their payment.-The reform backtracks on the last 20 years of reform process by reintroducing so called “coupled” production subsidies. Member states will be able to freely subsidise anything from biofuels production to intensive cereals production, without any constraints or link to positive outcomes for society.-The proposal would allow a subset of countries (Bulgaria, Estonia, Finland, Latvia, Lithuania, Poland, Portugal, Romania, Slovakia, Spain, Sweden and the UK) to shift money away from targeted and programmed spending in the rural development policy toward beefing up their untargeted income support and production subsidies. This means that, contrary to the claimed “greening” of the policy we are likely to see money currently spent on environmental schemes moved back to old style subsidies, including for highly polluting forms of farming.-in the new rural development policy, the environment is being clearly de-prioritised. For example several non environmental investments will receive higher levels of EU cofounding than environmental schemes. The guaranteed minimum spending on environmental schemes is also being removed.-The new rural development policy is introducing a raft of new “risk management” subsidies which duplicate pillar I spending and would potentially push farmers not to adapt to climate change, for example by continuing growing water intensive crops in water stressed areas and incentivise risk averse behaviour as low diversification of crops and income.-There is no apparent environmental or climate proofing mandatory for all measures in the rural development regulation. Rural development spending risks funding environmentally damaging measures such as irrigation expansion or clearing protected habitats for greenhouses and other intensive crops. These practices have been documented extensively and criticised by the European Court of auditors and should be avoided.Please be aware that in the Editor’s notes we (EEB) could not raise the totality of our concerns in an exhaustive way; there are indeed some voluntary schemes proposed in the leaked texts that according to us could potentially lead to an easy way of allowing blanket exemptions to damaging practices such as the small farmers scheme which is currently based on a lump sum exempted from cross compliance and from greening. Only by claiming that there are small (no clear definition in the text) Farmers will get a lower payment but will not have to respect any rules, not even basic binding legislation.