SAC Rural Policy Centre

The report concludes that greening the CAP will substantially slow down the decline in farmland biodiversity, most notably in intensive farming areas. It also suggests that extensively farmed areas would be better served by such a change.

So far so good. However, at no point do the authors of the report indicate what type of management conditions they assumed would be put on the permanent grassland condition or what type of habitats would be included in the (in their case) 5% ecological ‘set-aside’. In reality, whether real environmental benefits do arise from any greening of the CAP will depend on how these measures are implemented in practice. For example:

• it is possible to ‘maintain’ permanent pasture without it necessarily having any biodiversity or climate change benefits – it is the way it is ‘maintained’ that counts;
• increasing the diversity of crops grown at any one time has the potential to reduce landscape simplification (one of the major drivers of farmland biodiversity decline) but this depends on how ‘different crops’ are defined – wheat, barley and oats are all different crops, but growing these three would still result in a largely homogenous cereal landscape;
• maintaining an ecological focus on 7% of each farm also has the potential to increase landscape heterogeneity, but currently the areas under consideration appear to be largely, if not exclusively, farmland edge habitats – including some elements that occur within fields would reduce landscape simplification even more, but until the ‘biotopes’ that are mentioned in the draft CAP reform text are defined in more detail then it is difficult to judge how useful this measure will be in practice;

With regard to the latter bullet-point, it is also a sweeping assumption that creating ecological priority areas will always result in land being taken out of production – it doesn’t in Switzerland so why should it in the way the EU implements greening? In many situations, applying the ecological priority area approach would not necessarily have to involve removing land completely from production, but rather biodiversity benefits could be achieved by simply changing the intensity of management of those areas of the farm. For example, while it would not be feasible (or desirable) to plough or apply nutrients in the buffers established next to watercourses or hedgerows, such buffers would still be open and available for grazing by livestock.

Hence there is no evidence that many of the assumptions that must have been made in the report will actually happen in practice – the devil will be in the detail. We have no information on the latter from the Commission as yet, and hence no way to form a judgement of how good, bad or indifferent the results will be for biodiversity. Indeed, if the current uproar over the greening proposals continues unabated, we may end up with greening that is so watered down as to be meaningless.