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Linking payments to environmental standards

The 2003 CAP reform established a series of “cross-compliance” rules on environmental protection, food safety, animal and plant health and animal welfare, which farmers must comply with across Europe. Statutory Management Requirements (SMR) apply to all European farmers, and relate to existing environmental legislation. Good Agricultural and Environmental Conditions (GAEC) are additional requirements attached to most direct and rural development payments, and therefore only apply to farmers involved in these CAP support schemes.

In the CAP period 2014-2020, two SMRs (i.e. SMRs 1 and 10) integrated the requirements of the Nitrates Directive and the Sustainable Use of Pesticide Directive, as well as several GAECs are also relevant to water targets, directly and indirectly, including those requiring the establishment of buffer strips along watercourses, groundwater protection measures, soil and land management practices to limit erosion and maintain soil organic matter, and retention of landscape features such as hedgerows. One GAEC required compliance with authorization procedures for abstraction for irrigation purposes.

It is generally acknowledged that cross-compliance offered large potential for tackling pressures on the water environment because they reinforce the widespread enforcement of minimum environmental standards in agriculture. However, evaluations of cross-compliance has regularly highlighted some pertaining weaknesses, which can hinder their environmental effectiveness (ECA, 2009, 2016; Devot et al., 2020).

One common reported issue relates to the generic nature of crops-compliance requirements and their lack of spatial targeting. Under the current system, CAP management authorities set out standards following an approach that can be applied across a region or a country uniformly, so as to minimise administrative burden in compliance-checking. Two notable exceptions include the SMR related to the Nitrates Directive, which accounts for nitrate vulnerable zones, and the GAEC on land management to limit erosion, which integrates the need to account for site-specific conditions. Both support a reduction in nutrient pollution pressures.

There are issues relating to varying level of ambition. For instance:

• The specification of GAEC on buffer strips vary widely across Europe, including minimum width, obligations and restrictions regarding the use of fertilizer and pesticide input, and the type of vegetation cover that can constitute a buffer strip. The most ambitious buffer strip requirements more closely follow scientific recommendations regarding adequate consideration of factors, such as slope of the upstream land, vegetative cover type and maintenance operations, to enhance their effectiveness in tackling nutrient and pesticide pollution (Hickey and Doran, 2004).
• Cross-compliance relating to the use of pesticides was so far been limited to respecting procedures regarding the buying of products, their handling and application (ECA, 2020). Reducing pesticide pressure will require going beyond and implementing an integrated approach to managing pest and diseases, that considers alternative methods and reducing the application rate and frequency, as set out under the Directive on the Sustainable Use of Pesticides.
• Abstraction pressures were tackled by GAEC 2, which requires that the farmer comply with authorisation procedures. Considering the large number of unreported abstraction points, this GAEC has large potential to improve monitoring of water use. A requirement to install a water meter and report water use could improve further the GAEC. Potential additional measures could include the uptake of water saving measures and efficient irrigation systems.

Finally, cross-compliance requirements did not apply to sectoral market interventions and not all direct payments. This exempted certain polluting sectors such as cotton production, wine and vegetables, from meeting these standards when receiving these payments. In the current proposals for the CAP post-2021, some of these payments will remain under different environmental requirements as direct and rural development payments.

The new CAP green architecture proposes to integrate cross-compliance requirements and greening measures (see below) into a set of “conditionalities” on all Pillar I payments. In addition to integrating pre-existing cross-compliance and greening requirements (leaving some flexibility to member states on setting exact levels of ambition), new proposed standards include controls on diffuse phosphate pollution, new Farm Sustainability Tool for Nutrients, and the protection of wetland and peatland would contribute to tackle pressures from agriculture on water.

No conditionality requirement has yet been proposed regarding the mitigation of the impact of hydromorphological changes from drainage schemes and irrigation infrastructure, or measures tackling emerging chemical pollution such as pharmaceutical and cleaning products used in livestock rearing.