CAP not Matching Europe’s Green Ambitions, say Auditors (again)

 Creative Commons CC0 1.0 photo of ECA building by Procrastineur49 

CAP 2023-2027 is greener than the previous CAP – but plans  “do not match the EU’s ambitions for the climate and the environment”. That’s according to the ECA – the European Court of Auditors – which released it’s special report Monday 30th September. So what’s in it? Oliver Moore delves in for an initial read.

CAP 2023-2027 Strategic Plan Regulation (CAP SPs) may be greener than the previous CAP – but plans “do not match the EU’s ambitions for the climate and the environment“. Moreover, key elements for assessing green performance are missing.  So says the ECA, or European Court of Auditors, which released report 20/2024 on Monday. 

The report, using CAP SPs from Poland, France, Spain and Ireland,  found that CAP’s green architecture enables environmental ambition, but the Commission “does not use measurable criteria for assessing green ambition.” 

The green architecture refers to: “enhanced conditionality” (aka cross-compliance system and the “greening” obligations of the previous CAP) as expressed through the GAECs (good agri-environmental condition rules, plus directives and other rules); “eco-schemes” – farming practices purported to be beneficial to the climate, the environment, and animal welfare, typically about  T 25 % of direct payments, but voluntary;  and the reserving of at least 35 % of EAFRD funding in each Plan for interventions addressing the environment, the climate, and animal welfare, which are also voluntary for farmers.

You can ask…

Member states did respond to Commission  queries on the formulation of their plans – but did so in a partial manner, and did not necessarily adjust their positions based on Commission feedback either. 

Early on, the elephant in the room was named – actual impact on the climate and the environment is affected by the recent measures introduced by the Commission in response to farmers’ requests, and also depends on the level of farmers’ uptake of voluntary schemes.

Indeed the timing of a brand new and rushed CAP arriving in 2024, alongside the requirement to analyse CAP 2023-2027, will mean that more research is needed, to put it mildly.  

Ambition

The CAP plans were not especially aligned with the EU Green Deal – targets were not integrated while measurability was missing. reference is made to the fact that the Green deal targets themselves were also being rolled back – more inevitable awkwardness for auditors tryin got compare things year on year. 

Despite simplification, CAP objectives “lack clarity”  and focus more on outputs than results: “Important result indicators are missing in some CAP Strategic Plans, and the links set by the member states between result indicators and objectives vary” making it “challenging to demonstrate the achievements of the CAP”, as the report euphemistically puts it. 

For example, as the report references, for “the new system of conditionality, all member states made use of exemptions to good agricultural and environmental conditions, and 16 member states postponed the requirement to protect peatlands and wetlands, using the options laid down in the CAP Strategic Plans Regulation. Furthermore, member states sometimes did not exploit the full potential of the good agricultural and environmental conditions. The voluntary eco-schemes and rural development measures often do not result in a change to existing practices. Overall, our analysis shows that the final Plans do not show a substantial increase in green ambition compared to the previous period.”

Indeed this from the conclusion  is somewhat at variance with the title of this report – how is something “greener”  but also not showing “a substantial increase in green ambition compared to the previous period”?

So what to do

The ECA recommends three things: exchanges on good practice in the plans; estimating CAP s contributions to Green Deal Targets while fostering better alignment and integration of said targets; and, relatedly, a stronger monitoring framework.

Recommendation 1 – Promote exchanges of “green” good practice in the Plans

Recommendation 2 – Estimate the CAP’s contribution to the Green Deal’s environmental and climate targets

Recommendation 3 – Strengthen the future CAP monitoring framework for the climate and the environment

Good practice would mean, in practice, that by 2025  “the Commission should promote exchanges of good practice in eco-schemes, and of key practices and approaches to tackle long-term climate and environmental challenges better. ”

Quantified estimates of the CAP SPs contribution to the Green Deal climate and environmental targets should be presented by end of December 2025 – in the Commission’s report to the European Parliament and the Council.

This would mean that phrases such as “increased ambition” would need to be defined, and transparent and measurable criteria should be used. This feeds into the final point on monitoring – while the new monitoring framework is more coherent, it also “lacks the elements needed to track performance effectively.” Important result indicators are “missing in certain Plans” while “links to specific objectives vary greatly”.

Therefor recommendation 3 – Strengthen the future CAP monitoring framework for the climate and the environment –  involves the following steps ,which should  be implemented by 2027. 

  • assess which of the EU’s climate and environment goals could be incorporated into quantified targets for the CAP, and how;
  • clarify how these targets will be used as criteria to assess the member states’ CAP programming documents;
  • define result indicators to monitor progress towards these targets.

This is not the first negative report on CAP by the ECA. See below for more goin gback to 2018. See also selected examples of CAP SPs being queried by the Commission. 

Read/download the report here ECA_CAP_SR-2024-20_EN

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