Maintain alpine diversity - Demands of the Alliance for Agriculture and Nature Conservation in the Alps for viable and sustainable mountain ...
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Maintain alpine diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for viable and sustainable mountain farming Proposed amendments to the legislative proposals for the reform of the Common Agricultural Policy (CAP) for 2014-2020 as presented by the EU Commission on 12 Oct. 2011
The Alliance for Agriculture and Nature Conservation in the Alps (in short: “Alliance”) is an alliance of farmers’ associations and conservation associations which aims to maintain and support mountain farming and maintain and restore biodiversity in the Alps and in other European mountain regions. The Alliance’s overall concern is multifunctional, environmentally sustainable family farming. This paper will however focus on the impacts on the Alpine region of the legislative proposals for the reform of the EU Common Agricultural Policy (CAP) as presented by the EU Commission on 12 October 2011. Signatories Arbeitsgemeinschaft bäuerliche Landwirtschaft Landesverband Baden-Württemberg (D) Arbeitsgemeinschaft bäuerliche Landwirtschaft Landesverband Bayern (D) International Commission for the Protection of the Alps CIPRA Germany (D) Bayerischer Landesverband der Landwirte im Nebenberuf (D) Bund Naturschutz in Bayern (D) Bundesverband der Regionalbewegung (D) Deutscher Alpenverein (D) Deutscher Verband für Landschaftspflege – DVL (D) EuroNatur, European Nature Heritage Fund (D) Forum Pro Schwarzwaldbauern e.V. (D) Friends of the Earth Europe (INT) Landesbund für Vogelschutz – LBV (D) Landesvereinigung Ökologischer Landbau - LVÖ(D) NaturFreunde Deutschlands (D) Friends of Nature – NFI (INT) Naturfreunde Österreich (A) Naturschutzbund Österreich (A) ÖBV-Via Campesina Austria (A) Schweisfurth Foundation (D) Umweltdachverband (A) Verein zum Schutz der Bergwelt (D) With technical assistance provided by: ProNatura (CH) Abbreviations: A = Austria, D = Germany, CH = Switzerland, INT = International
Deutscher Verband für Landschaftspflege
picture: Marie Kohler Haymaking in Bonneval-sur-Arc, France.
Imprint: This position paper was jointly drawn up by the signatory associations. The drafting process was coordinated by EuroNatur, the European Nature Heritage Fund. Radolfzell, July 2012. This paper is an outcome of the project entitled „Greening the EU Agricultural Policy after 2013 - Towards sustainable agriculture in the Alps („Ökologisierung der EU-Agrarpolitik nach 2013 für eine nachhaltige Landwirtschaft im Alpen- bogen“) as supported by the MAVA Foundation for Nature Conservation (MAVA Stiftung für Naturschutz). Additional support was provided by the Ludwig Raue Memorial Foundation (Ludwig-Raue-Gedächtnisstiftung). Published by: EuroNatur Foundation Konstanzer Str. 22 D - 78315 Radolfzell am Bodensee Tel.: + 49-7732-92720 info@euronatur.org www.euronatur.org Recommended citation: EuroNatur Foundation (Hrsg.) (2012): Maintain alpine diversity. Demands of the Alliance for Agriculture and Nature Conservation in the Alps for viable and sustainable mountain farming. Proposed amendments to the legislative proposals for the reform of the Common Agricultural Policy (CAP) for 2014-2020 as presented by the EU Commission on 12 Oct. 2011 Layout: Kerstin Sauer, EuroNatur Service GmbH Print: digitalcentrum by Working Hands GbR 100% Recyclingpapier Cyclus Print Cover picture - Naturpark Weißbach – Christine Klenovec: Haymaking on the Alpine pasture of the Kallbrunnalm in the Austrian Weißbach Nature Park involves a lot of manual labour.
picture: Yann Kohler Alpine landscape in the French Bauges Nature Park.
Contents
8 1. EU agricultural policy and the future of mountain farming
9 Introduction
14 Aims of the Alliance for Agriculture and Nature Conservation in the Alps
16 2. Overview of the demands of the Alliance for Agriculture and
Nature Conservation
16 Evaluation and discussion of the Commission proposals
22 Summary of the demands of the Alliance for Agriculture and Nature Conservation in the Alps
26 3. Proposed amendments to the EU Commission’s legislative proposals
26 Regulation on direct payments
26 Article 4 – Definitions
28 Article 9 – Active farmer
29 Article 11 – Progressive reduction and capping of the payment
30 Article 14 – Flexibility between pillars
32 Article 20 – Regional allocation of the national ceilings
34 Article 22 – Value of payment entitlements and convergence
36 Article 23 – Establishment and use of the national reserve
38 Article 25 – Activation of payment entitlements (Regional model - standardised required labour usage)
39 Article 25 – Activation of payment entitlements (Definition with respect to the activation of payment entitlements)
40 Article 29 – General rules (for payment for agricultural practices beneficial for the climate and the environment)
44 Article 30 – Crop diversification
45 Article 31 – Permanent grassland
46 Article 32 – Ecological focus area
48 Article 34 & 35 – General rules and financial provisions (for Payment for areas with natural constraints)
50 Support for rural development
50 Article 18 – Investments in physical assets
52 New Article to be inserted between Articles 21 and 22 – Conservation and upgrading of the rural heritage
54 Article 29 – Agri-environment- climate
58 Article 30 – Organic farming
59 Article 31 – Natura 2000 and Water Framework Directive payments
60 Article 32 – Payments to areas facing natural or other specific constraints
62 Article 37 – Risk management
64 Common organisation of the markets in agricultural products
64 Article 24 – Supply of milk products to children (School milk scheme)
66 4. References
1.
1. EU agricultural policy and the future of mountain farming
In the view of the Alliance for Agriculture and Nature Conservation in the Alps (in short: Alliance) the
future EU Common Agricultural Policy (CAP) after 2013 should support mountain farming that restores,
fosters and maintains in the long-term the outstanding biodiversity and resource quality of the Alps and
of other mountain regions in Europe. Mountain farming that is future-proof in this sense, i.e. viable and
sustainable, will require that amendments be made to the legislative proposals for the Common Agricultural
Policy as presented by the EU Commission on 12 Oct. 20111.
A general assessment of the CAP and its importance for mountain farming as well as the Alliance’s objectives
are presented in Chapter 1. Chapter 2 (p. 16) provides a brief explanation of the main demands of the Alliance
directly referenced to the EU Commission’s legislative proposals. The demands are further listed in form of a
structured catalogue. Chapter 3 (p. 26) gives a detailed description and rationale of the Alliance’s recommen-
dations for the adaptation of the Commission proposals with reference to the relevant individual Articles.
picture: Parc national de la Vanoise - Christophe Gotti
The protection of cultural and natural heritage is the primary objective in the buffer zone of the Vanoise National Park in France.
1
Proposal for a Regulation on direct payments; Proposal for a Regulation on support for rural development (EAFRD Reg.); Proposal for a
Regulation on a common organisation of the markets (Single CMO)
8 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020
.1
Introduction
A whole lot of money – for what?
Every year the EU spends more than EUR 50 billion to support agriculture. This high expenditure can only be justified
if the distribution of subsidies is both transparent and comprehensible. Society asks what this money is spent on
and rightly demands that each item of expenditure must be matched by the delivery of public goods going beyond
compliance with existing legislation (“public goods for public money”). In other words, if the farming sector – apart
from producing healthy food – engages in the protection of soils and drinking water, works on preserving biodiversity,
if it looks after the landscape, provides jobs, or implements innovative regional strategies for rural development, then
these special contributions should be adequately remunerated. If the funds available were consistently used in this
way, Europe could swiftly move towards the aim of having a multifunctional and sustainable farming sector.
However, the legislative proposals for the Common Agricultural Policy (CAP) as presented by the EU Commission
on 12 Oct. 2011 maintain the old system of area-based direct payments (Pillar 1) and rural development measures
(EARDF, Pillar 2) and can thus not be regarded as a reform and much less a re-orientation. A re-orientation towards a
sustainable, multifunctional farming sector would have necessitated a fundamental alteration of the support system,
or at the very least a substantial shift of funds from Pillar 1 to Pillar 2. Instead, the Commission proposals take the
form of a compromise: Pillar 1 is now to contain so-called “greening” components, but the bulk of funding will con-
tinue to be distributed in a non-selective manner (i.e. purely on an area-basis) while with respect to measures under
Pillar 2 (rural development, climate protection, nature conservation, animal welfare etc.) the current status quo will,
at best, be maintained. Support for family farming and resource protection continues to be underrepresented. This
will not be sufficient to effect the change towards an ecologically compatible farming sector stated as a target by
the EU elsewhere 2, 3.
2
The Europa 2020 strategy passed by the EU Commission in March 2010 lists “a more resource efficient, greener and more competitive
economy” as one of its three priority objectives.
3
The headline target of the EU biodiversity strategy of May 2011, entitled Our life insurance, our natural capital: an EU biodiversity
strategy to 2020, is to“ [halt] the loss of biodiversity and the degradation of ecosystem services in the EU by 2020, and restoring them in so
far as feasible, while stepping up the EU contribution to averting global biodiversity loss.”
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 9
1.
Mountain farming is fading away
Mountain farmers not only produce food, they also preserve and maintain mountain pastures and meadows and thus
one of our most valuable cultural landscapes with their unique diversity of rare plant and animal species and their
particularly high touristic value. Farming in the mountain regions is generally more work-intensive while delivering
lower yields. Moreover, the current distribution of EU agricultural subsidies, which is rooted in historic developments,
disadvantages mountain farmers in many respects: For example, in most Member States the direct payments for
grasslands continue to be lower than those for arable lands. The fact that there will a move away from the historic
basis of direct payments from 2014 onwards is laudable. Despite special European and domestic supports, mountain
farms on average have significantly lower incomes than their colleagues outside of the mountain regions 4. The
current support system has not been able to halt either the continuing loss of farms (in the Alpine region the number of
farms declined by 36 % or 160,000 holdings between 1980 and 2000 5, 6) or the ongoing rapid loss of biodiversity 7, 8.
Especially in the Alpine region fewer farms are often associated with the abandonment of farming in disadvantaged
areas and thus lead to the loss of important cultural landscapes including their high biodiversity, especially that of
low-input semi-natural grasslands 9. Mountain farming is the backbone of the mountain regions. In order to maintain
it, a differentiated support system is required based on the Declaration on Mountain Farming 10 and the Alpine Con-
vention Mountain Farming Protocol 11, both of which list the sustainability and multifunctionality of mountain far-
ming as important objectives.
4
Average annual income from farming: Bavaria: Mountain farmers just under EUR 30,000, holdings in non-disadvantaged areas just under EUR
40,000 (Source: Bayerischer Agrarbericht 2010); Austria: Mountain farmers EUR 22,000, Mountain farmers in particularly disadvantaged
areas (BHK4) EUR 14,000, holdings in non-disadvantaged areas EUR 24,6000 (Source: Grüner Bericht 2011); Switzerland: Mountain farmers
SFR 47,000, valley farmers SFR 72,800 (Source: Agrarbericht 2008 des Bundesamtes für Landwirtschaft).
5
Streifeneder, T. (2009): Die Agrarstrukturen in den Alpen und ihre Entwicklung unter Berücksichtigung ihrer Bestimmungsgründe, Dissertation
LMU München, 230 pp., Data from the Annex, Table 3, p. 199.
6
There are significant regional differences in this respect, especially between the German-speaking and the Romance and Slovenian Alpine
regions respectively.
7
According to a study carried out by the British botanist Jonathan Storkey and his expert colleagues in 29 European countries, Germany,
Austria and Switzerland have the highest rates of decline of arable weeds in Europe. Storkey, J. et al. (2012): The impact of agricultural
intensification and land use change on the European arable flora. Proceedings of Royal Society B.
8
48% decline (in overall numbers) of 36 farmland bird species in 25 European countries between 1980 and 2009. Source: European Bird Census
Council - EBCC, URL: http://www.ebcc.info/index.php?ID=470.
9
“With this agricultural structural change the type and intensity of land use has changed considerably, especially in grassland management,
resulting in a polarization: extensive management in less-favoured areas or, in extreme cases, land abandonment, and intensification in
favoured areas by way of more frequent cutting regimes, fertilizers, reseeding, more productive grass cultivars etc. In both cases negative
impacts on biodiversity are evident.” (Streifeneder, T. (2009), p.9).
10
Declaration on Mountain Farming, Resolution adopted by the 47. Permanent Committee of the Alpine Convention in October 2011.
11
The Alpine Convention Mountain Farming Protocol was signed by the EU on 20.12.1994, ratified by the EU on 27.6.2006, and came into
force in the EU on 6.10.2006.
10 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.1
Alpine Convention Mountain Farming Protocol, (Article 1, Paragraph 1)
This Protocol lays down international measures to preserve and promote mountain farming which
suits local conditions and is environmentally compatible; it aims at recognising and securing the
continuity of its essential contribution to maintaining the population and safeguarding sustainable
economic activities, particularly by means of producing typical high-quality produce, safeguarding
the natural environment, preventing natural risks and conserving the beauty and recreational value
of nature and the countryside and of cultural life in the Alpine region.
picture: Joachim Eigenthaler
Mountain farming characterises the Massif du Mont Thabor region in the south of France.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 111.
Member States carry a great responsibility
This paper focuses on the design of the EU CAP for 2014-2020. The CAP provides the framework for agricultural sub-
sidies. It should be emphasized, however, that there is much scope for Member States and regional level administrati-
ons (e.g. the federal states in Austria and Germany) when it comes to implementing the specifications from Brussels.
It is one of the Alliance’s key demands that the Member States’ policies fully utilize this scope for the purpose of
meeting the objectives set out above.
Mountain farming programmes tailored by the Member States for their respective mountain regions will be indispen-
sable 12. Additionally, Member States may redistribute up to 10 % of their annual national ceilings for direct payments
from Pillar 1 to Pillar 2 13– this is additional to the funds resulting from the reduction and capping of direct payments.
This scope is urgently needed in order to strengthen measures under Pillar 2, as more and more old and new chal-
lenges need to be addressed (i.a. climate protection, Natura 2000, Alpine Convention and its protocols 14) while at
the same time there are no plans to increase total appropriations. “Coupled support” and the “national reserve” offer
further options to Member States for supporting mountain farming under Pillar 1.
In addition to EU funding, Member States have other instruments at their disposal, such as in the areas of research,
education, qualified employment, support for regional economic circuits and decentralized utilities, support for
civil society rural initiatives and innovations. In short: The Member State governments also have a responsibility to
live up to the promises they made for example in the Alpine Convention or in the “Oberammergau Declaration” 15.
To use the words of German Federal Minister Ilse Aigner: “Mountain farming is indispensable for culture and nature
in the Alpine region. […] We must not abandon the mountain farmers!” 16
12
The Commission explicitly mentions this option when it sets out the grounds for the proposal of the EAFRD Regulation. In Section 3,
following the list of EAFRD priorities, the Commission states that: “The regulation includes rules on the preparation, approval and revision
of programmes that largely follow current rules, and opens up the possibility for sub-programmes (e.g. young farmers, small farmers, mountain
areas, short supply chains) that benefit from higher aid intensities.“
13
cf. Article 14 of the legislative proposal for a Regulation on direct payments.
14
incl. the Alpine Convention Protocol on Conservation of Nature and Countryside as signed by the EU on 20.12.1994.
15
“Erklärung von Oberammergau” of April 11, 2011 entitled “Berglandwirtschaft gemeinsam erhalten und gestalten!“ (Maintaining and
designing mountain farming together!), signed by government represents from Slovenia, Austria, Germany, Italy, France and Switzerland.
16
Quote (translated) from a speech given by the German Federal Minister of Food, Agriculture and Consumer Protection, Mrs. Ilse Aigner, at
the occasion of a conference in Krün, Upper Bavaria, on July 10, 2009.
12 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020picture: Naturpark Weißbach – Christine Klenovec
.1
A Pinzgau-style fence is a traditional feature of the cultural landscape on the alpine pastures of the Litzlalm in the Austrian Weißbach Nature Park.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 131.
Aims of the Alliance for Agriculture and Nature Conservation
EU agricultural policy plays a critical role in fostering viable and sustainable mountain farming in the Alps.
It is the view of the Alliance for Agriculture and Nature Conservation in the Alps that the CAP after 2013
should:
support sustainable family farming and foster the natural diversity and structure of the Alpine landscape in order
to preserve the Alps’ natural and cultural heritage;
(Articles 29, 30 and 32 DP Regulation, Articles 21 and 22 EAFRD Regulation)
remunerate the higher labour input required to manage the Alpine cultural landscape and differentiate support
payments accordingly;
(Articles 11 and 25 DP Regulation, Article 32 EAFRD Regulation)
provide more funds for environmental objectives with a view to maintaining the Alpine region’s biodiversity as a
basis for the economy, culture, and recreation;
(Articles 14 and 31 DP Regulation)
maintain and support low-input semi-natural grasslands as typical elements of the Alpine cultural landscape,
and provide incentives for the re-establishment and maintenance of unique and typical alpine land use types,
such as seasonal alpine pastures (Almen);
(Articles 4, 9, 23, 25 and 31 DP Regulation)
ensure the fair and targeted distribution of EU funds;
(Articles 20 and 22 DP Regulation)
The Yellow Alpine pasqueflower (Pulsatilla alpina apiifolia) prefers nutrient-poor pastures and stony natural grasslands as its habitat in the upper
regions of the western Alps.
14 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.1
make the provision of public funds conditional on the delivery of special public goods in the areas of climate
protection and nature conservation and on achieving the EU’s sustainability objectives, and support precautionary,
resource conserving management;
(Articles 18, 29, 31 and 37-41 EAFRD Regulation)
contribute to regional and environmentally-friendly production of healthy, GM-free foods and thus to sustainable
development in rural areas;
(Single CMO Regulation)
support enhanced added value of mountain farming in the Alps by targeted marketing of products of mountain
farm origin (trademark);
(Single CMO Regulation)
establish a fair and sustainable dairy market that is focussed on the EU internal market and respectful of natural
resources and the labour force.
(Single CMO Regulation)
picture: Gunther Willinger - www.guntherwillinger.com
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 152.
2. Overview of the Alliance’s demands
Evaluation and discussion of the Commission proposals
The associations forming the Alliance for Agriculture and Nature Conservation in the Alps had hoped for a
fundamental re-orientation of the CAP. However, since it is unlikely that any profound changes can be made
to the foundations of the “middle ground” legislative proposals the Commission has tabled, a constructive
criticism of the proposals will be given below. The main points of criticism and demands will briefly be listed
in this Chapter.
Greener and fairer?
At his presentation of the Commission proposals, Agriculture Commissioner Ciolos pleaded for a “greener and fairer”
CAP. Hence the cross-compliance between direct payments and the “greening”, and the more even distribution of
direct payments. The Alliance for Agriculture and Nature Conservation in the Alps welcomes these approaches but
misses, for the most part, their stringent implementation in the form of instruments and measures. A true greening of
the CAP could primarily be achieved by way of strengthening Pillar 2. Sustainability indicators (e.g. High Nature Value
Farmland) and targets (e.g. as part of the biodiversity strategy) developed by the EU itself have not found their way
into the text of the proposals, even though many measures (e.g. investment aid, support for young farmers, advisory
services, design of the regional model) ought to be made conditional on sustainability criteria as a matter of urgency.
Research and education projects in the area of multifunctional agriculture should also receive more CAP funding.
In general, the allocation of funding for research and education must be underpinned by sustainability criteria (e.g.
biodiversity protection, no genetic engineering). Important measures would be, for example, advice on sustainability
issues at the level of individual farm holdings as well as research projects on organic farming.
The more equitable distribution of direct support entails the abolition of the link to historical references the Commission
is seeking as well as the introduction of a uniform single payment scheme. The Association concurs with these
objectives and with degression and capping of area payments. Member States should be given the option to distribute
up to 50 % of the basic payment based on standardized labour input. Upper limits to stocking rates and nitrogen net
balance surpluses should be introduced as additional qualitative cross-compliance requirements for the receipt of
the basic payment.
The legislative proposals include a number of different support options for low-input semi-natural grassland (agri-envi-
ronmental programmes, compensatory allowance, coupled payments, national reserve) – however, we are of the opinion
that there is a need to revise and improve some sections of the definitions and targets in this regard. We welcome the
provisions on the maintenance of permanent grassland in principle. However, the reference date applied is disastrous
and likely to lead to large-scale ploughing up of areas of permanent grassland prior to this date. Further, the Commission
should also provide incentives for the restoration of permanent grassland. The Association welcomes the requirement of
7 % ecological focus areas but emphasizes the need to ensure that these areas perform a habitat network function.
16 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.2
How green is the “greening”?!
The greening component of Pillar 1 can merely set new minimum standards to bring about additio-
nal activities in intensive agricultural regions. Only additional remuneration for the delivery of en-
vironmental public goods and the provision of incentives to go beyond these minimum standards,
especially in areas that are in particularly great need of protection and action such as the mountain
regions, will allow for the European environmental and sustainability objectives to be achieved.
The Alliance for Agriculture and Nature Conservation in the Alps calls for a minimum appropriation of EAFRD funds
in accordance with the priorities set out in Article 5, EAFRD Reg. Fifty percent of EAFRD funds should be reserved for
Priorities 4 and 5 (ecosystems, resource efficiency, climate protection). This would include measures under EAFRD
Reg. Articles 29-35 (agri-environment, organic farming, Natura 2000, Water Framework Directive, compensatory
allowance, animal welfare, forest protection). Priority 6 (social inclusion, poverty reduction, rural development) and
the LEADER programmes are also of particular relevance for mountain farming and should be given increased consi-
deration in terms of the allocation of funds.
The compensatory allowance is designed to compensate for disadvantages faced in areas with natural constraints,
such as for example mountainous regions with their steep slopes, difficult access and short growing season. Funding
should be differentiated by degree of handicap – equitable distribution cannot simply be achieved by defining any
area above a certain altitude (e.g. 700 m a.s.l.) as a mountain region and apply a one-size-fits-all subsidy to all such
areas. Instead, the degree of handicap faced should be determined at the individual farm level, such as in the Austrian
mountain farm land registry. The legislation should be worded in such a way as to enable Member States to imple-
ment such differentiated funding models or call on them to develop such models.
The protection and management of Natura 2000 areas 17 and the implementation of the Water Framework Directive
(WFD) must be greatly improved if the 2020 biodiversity targets 18 are to be met. While all of the financial instruments
of the EU must contribute to achieving these targets, funding aimed at achieving a favourable conservation status
of the Natura 2000 areas, a central European objective, should largely be provided by the CAP. The current legislative
proposals will not allow for adequate funding to be provided for Natura 2000 areas and WFD implementation.
17
While Natura 2000 is the core element of EU biodiversity policy within Europe, only 17 % of species and habitats respectively are at a
favourable conservation status. Source: EU Commission (2009): COM(2009)358 final, p. 7 and 9.
18
EU Commission (2011): Our life insurance, our natural capital: an EU biodiversity strategy to 2020.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 172.
Member States are given the right to opt for a regional allocation for the purposes of distributing basic payments.
The Alliance for Agriculture and Nature Conservation in the Alps proposes that prior to drawing up these regional
models, Member States should be requested to submit impact assessments outlining the impacts of different
scenarios. Otherwise there would be a risk that regional models are drawn up in such a way that the planned
targets will not be met.
Farmers have a legitimate expectation that they can achieve fair incomes from the sales of their products together
with the remuneration for their provision of public goods. Efficient market instruments must be established in
order to stabilize prices and avoid strong price fluctuations. The production and marketing of premium products
which reflect the specific traits of a particular region and the diversity of rural areas must be supported. Moreover,
the Alliance for Agriculture and Nature Conservation in the Alps calls for a ban on misleading advertising and for
greater support of short distribution routes, direct marketing initiatives and regionally based farmers’ markets.
Mountain farming in particular has a need for a trademark for sustainably produced mountain products. The Alli-
ance welcomes the increased support for producer groups and the school milk scheme as envisaged in the legis-
lative proposals. The latter scheme could however have a much greater steering effect if it was underpinned with
strong quality criteria for the school milk (regional organic milk or regional non-silage milk). Overall, farms must
be made more competitive to allow them to contend with the major retail chains’ superior bargaining position.
picture: Gunther Willinger - www.guntherwillinger.com
Alpine ibex (Capra ibex).
18 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.2
Market measures
The Alliance for Agriculture and Nature Conservation in the Alps calls for an EU agricultural policy with an internal
market focus aimed at ensuring that farming can continue throughout the EU and at supplying high-quality food
for the domestic population. The financial crisis since 2008 has drastically demonstrated that largely unregulated
markets are not expedient from a societal point of view. There are many parallels and multiple links between the
financial crisis and the development of the global food crisis.
The Alliance is disappointed that market stabilization, as one of the objectives declared in the European Treaties 19
is scarcely being pursued in the Commission proposals. The EU Parliament recognized this problem, highlighted
numerous shortcoming in its analysis entitled “Fair revenues for farmers: A better functioning food supply chain
in Europe” 20 and called for a range of specific measures to be taken based on this analysis. In this context, the
Alliance for Agriculture and Nature Conservation in the Alps highlights the particular significance of a fairer dairy
market for mountain farming. A number of selected measures which can improve framework conditions in the
dairy market and also in other areas of food production and which can contribute to market stabilization are listed
below:
Milk producers themselves must be able to react to changes in demand and affect the market by way of supply
management measures. With the European Milk Board (EMB) a European monitoring agency has effectively been
created already. However, it must urgently be given market control powers and responsibilities.
The thresholds set for the stabilizing mechanisms intervention and private storage must consider the interrela-
tionships between price development, costs, and profit margins. The current intervention thresholds are set at
prices that are much too low and have already caused enormous losses of added value for dairy farmers.
The voluntary set-aside of milk quota in turn for financial compensation mooted by the EU Commission
19
Lissabon Treaty
20
Official Journal of the European Union C308E of 20.10.2011, p. 22 – 30: Fair revenues for farmers: A better functioning food supply chain
in Europe, European Parliament resolution of 7 September 2010 on fair revenues for farmers: A better functioning food supply chain in Europe
(2009/2237(INI)).
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 192.
In case of a crisis, agreed milk quota increases should temporarily not be allocated at farm level.
Milk producers should be able to collectively negotiate prices in more than one producer association, each with
clearly defined contract volumes, so as to strengthen their bargaining power and spread their risks. This should
also include the option of marketing a proportion of the milk produced through a cooperative and the remainder
through a milk producers’ association or as a sole trader.
The basic criteria for contracts between milk producers and dairy processors as set out in the Commission
proposals should be made compulsory in all Member States so as to be able to influence market balance and
create approximately similar framework conditions throughout the European marketplace.
Introduction of a trademark for products or mountain farm origin. Such a label should reliably inform consumers
about the geographic origin of the products and, in conjunction with quality schemes such as organic farming,
environmental protection, nature conservation, animal welfare and social issues, enhance added value in
alpine farming.
A ban on misleading labelling and advertising: images or indications on packaging suggesting production
methods other than those employed must be prohibited (e.g. a cow out on pasture where the milk is produced
by cows kept indoors year-round). With regard to mountain farming it is important that the use of terms such
as “Berg” (mountain), “Alms” or “Alp” (alpine pasture) and their derivates and equivalent terms in other
languages may only be used for products if these have been produced in a mountain region (with more detailed
criteria to be defined). This also applies to advertising in relation to these products.
Support for direct marketing initiatives and regionally-based farmers’ markets: Especially in the alpine region
it is possible for farmers to add value to their products. Such products are popular and valued by consumers.
However, farmers need government support to establish direct marketing structures as the necessary investments
are beyond the farmers’ financial resources.
20 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.2
picture: Kerstin Sauer
Necessity of market rules in the dairy sector
Abolition of milk quotas in 2015. Milk quotas have made a strong contribution to maintaining
mountain farming. The liberalisation of the dairy sector is expected to result in an increased sup-
ply of milk and decreasing prices, with a resultant shift of dairying into agriculturally favoured
regions. This in turn will impact adversely on mountain farming in particular. Market stabilisati-
on measures could at least in part absorb these impacts. Unfortunately, concrete approaches to
addressing this issue are missing from the Commission proposals on CAP reform.
Especially in the dairy sector, farmers must be given the opportunity to achieve and maintain
market balance. This is not a question of fixing producer prices but of having the ability to swiftly
and in a binding manner for all concerned react and adapt supply to demand. Without such a
statutory framework, market volatility will time and again cause significant market distortions,
inevitably leading to export dumping and causing enormous losses of added value for rural areas.
Jobs will be lost and the pressure to intensify farming practices will increase.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 212.
Summary of the Alliance’s demands
With respect to the proposal for a Regulation on direct payments we call for:
a more precise definition of permanent grassland to ensure support for low-input semi-natural grasslands;
(Article 4, see p. 26)
a move away from the purely area-based payment, and an option to have standardised required labour usage
considered as a frame of reference for the purposes of activating payment entitlements;
(Article 11, see p. 29 und Art. 25, see p. 38)
significantly lower thresholds for capping and degression if the purely area-based payment is retained;
(Article 11, see p. 29)
obligatory full convergence of payment entitlements immediately at entry into force of the Regulation if the
purely area-based payment is retained; (Article 22, see p. 34)
the obligation of Member States to carry out an impact assessment of the impacts of different possible regional
models; (Article 20, see p. 32)
Alpine asters (Aster alpinus) thrive in warm dry calcareous soils at altitudes of up to 3100 meters.
22 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.2
the use of the national reserve to support low-input semi-natural grassland areas; (Article 23, see p. 36)
the introduction of two additional criteria for the greening of Pillar 1, i.e. a maximum nitrogen net balance
surplus of ≤ 50 kg N/ha/year hectare and a maximum stocking density of 2,2 DE per hectare (equivalent to 176 kg
N/ha/year from livestock manure); (Article 29, see p.40) DE = Dungeinheit. One “Dungeinheit” corresponds to 80 kg N/ha/year from livestock manure
with respect to crop diversification, a single crop to take up no more than 50 % and legumes to take up at least
20 % of a holding’s arable land per growing season; (Art.30 , see p. 44)
the reference date for the ban on ploughing up of permanent pasture to be brought forward to 12 October 2011
at the latest; (Article 31, see p. 45)
the use of chemical plant protection products and mineral fertilizers to be prohibited on the 7 % ecological focus
areas, and their configuration to ensure that these areas perform the envisaged habitat network function;
(Article 32, see p. 46)
the Member States to be given the opportunity to notify decisions to use up to 5 % of their annual national
ceiling for the support of areas with natural constraints at dates later than 1 August 2013;
(Article 34 und 35, see p. 48) picture: Gunther Willinger - www.guntherwillinger.com
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 232.
With respect to the proposal for a Regulation on support for rural development we call for:
support for farm infrastructure such as access tracks, livestock housing etc. to be conditional upon participation in
agri-environmental measures; (Article 18, see p. 50)
EU co-financing rates for investments into environmental protection, biodiversity, and Natura 2000 to be signifi-
cantly higher than those for investments into processing, marketing, and infrastructure; (Article 18, see p. 50)
EAFRD minimum appropriations for Priorities 4, 5 and 6 (ecosystems, resource efficiency, climate protection,
social component) as well as for the LEADER programme; (Article 29, see p. 54)
higher limits to the maximum amounts payable for participation in agri-environmental and conservation
schemes (Natura 2000 and Water Framework Directive); (Articles 29 and 31, see p. 54 and p. 59)
higher limits to the maximum amounts payable for areas facing constraints, and the distribution of funds to be
differentiated by degree of handicap; (Article 32, see p. 60)
no subsidisation of insurances; (Article 37, see p. 62)
picture: www.agrarfoto.com
Sickle-bar mowers are used on the slopes of the Swiss Alps.
24 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.2
With respect to the proposal for a Regulation on a common organisation of the
markets we call for:
the introduction of mechanisms for and implementation of effective market stabilisation measures;
the school milk scheme to be underpinned with strong quality criteria (regional organic milk or regional
non-silage milk); (Article 24, see p. 64)
picture: Parc national de la Vanoise - Frantz Storck
Traditional wooden buildings with an adjacent vegetable garden in Hameau de Chandon, Vanoise National Park.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 253.
3. Proposed amendments to the EU Commission’s legislative proposals
Regulation on direct payments
Article 4 – Definitions
COM: (h) „permanent grassland“ means land used to grow grasses or other herbaceous forage na-
turally (self-seeded) or through cultivation (sown) and that has not been included in the crop
rotation of the holding for five years or longer; it may include other species suitable for grazing
provided that the grasses and other herbaceous forage remain predominant;
(i) „grasses or other herbaceous forage“ means all herbaceous plants traditionally found in
natural pastures or normally included in mixtures of seeds for pastures or meadows in the
Member State (whether or not used for grazing animals);
Demand: The proposed definitions of “permanent grassland” and its use exclude important agriculturally used habitat
types from the eligible areas under Pillar 1 (heaths, nutrient-poor grassland). Provided that grazing of these
habitat types is necessary or favourable for their maintenance, this use must generally qualify them as eligible
areas, i.e. not the type of vegetation present but the use to which it is put should determine eligibility.
The definition of permanent grassland in Article 4(h) should therefore be rendered more precisely as follows:
(h) “permanent grassland” means land under grass or other forage plants (naturally self-seeded or
sown) that is used as meadow and/or pasture and that has not been ploughed up and re-seeded
for at least five years. Landscape features to be defined by the Member States may be included
with permanent grassland areas provided such areas are allocated their own parcel use code
“low-input semi-natural grassland” or if the grazed and/or cut area comprises more than 50 %
of the total area;
Without this specification especially those habitat types would be affected that the EU considers as
being in special need of protection as Natura 2000 sites, and which are of major importance for extensi-
ve livestock production as well for landscape-based recreation, not only in the Alps but also in all other
high and low mountain regions of Europe. According to EU conservation legislation Member States are
under obligation to avoid the deterioration of such sites, an obligation that cannot be met in the ab-
sence of agricultural land use. Therefore, the inclusion of these sites into eligible areas for the purposes
of the Pillar 1 payment scheme is indispensable.
For clarification, the following should be added to the definition of „grasses or other herbaceous forage“
in Article 4(i):
These also include dwarf shrubs, reeds, rushes, sedges and other plant species of no or limited
forage value;
26 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.3
Rationale: Traditional pasture landscapes (often located in mountain regions) typically contain dispersed land-
scape features – primarily scrub, hedges, trees and copses. According to both the current legislation
and the Commission proposals on CAP reform these woody plants are not considered forage and may
not exceed a certain proportion of the parcel claimed. In Germany and other Member States these
landscape features must generally be individually assessed and appropriate deductions have to be
made from the eligible area. This practice entails a high administrative burden, is prone to errors, and
involves a high risk of sanctions. Following the “use them or lose them” principle, extensively mana-
ged pastureland should explicitly include landscape features such as hedges, individual or sparsely
dispersed trees as these are beneficial to landscape dynamics and biodiversity. Livestock also does
browse such features and uses them for shelter. The default inclusion of such landscape features
removes the need to individually define and assess them, thus removing a huge administrative burden
for farmers and inspections. This is the only way in which many characteristic cultural landscapes that
are dependent on extensive grazing regimes can remain part of the agricultural system and continue
to be used for primary production.
picture: Gunther Willinger - www.guntherwillinger.com
The Long-spurred Pansy (Viola calcarata) thrives in Alpine natural grasslands and on scree.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 273.
Article 9 - Active farmer
COM: 1. No direct payments shall be granted to natural or legal persons, or to groups of natural
or legal persons, where one of the following applies:
(a) the annual amount of direct payments is less than 5 % of the total receipts they
obtained from non-agricultural activities in the most recent fiscal year; or
(b) their agricultural areas are mainly areas naturally kept in a state suitable for
grazing or cultivation and they do not carry out on those areas the minimum activity
established by Member States in accordance with Article 4(1)(c).
2. Paragraph 1 shall not apply to farmers who received less than EUR 5 000 of direct
payments for the previous year.
Demand: Proposed wording supplementing the provisions of Article 9(2):
Charitable organisations or holdings implementing landscape management or nature conservation
measures are considered “active farmers”.
Rationale: Charitable organisations (such as landscape management associations or conservation organisations)
and landscape conservation farms 21 do not fall within the planned definition of “active farmers”. As
a result they can activate only limited payment entitlements under Pillar 1 for land parcels managed
for conservation purposes, leading to a situation where on many sites of special conservation interest,
it will not be feasible to maintain agricultural land use. However, the European Court of Justice in
its Judgment of 14.10.2010 (C-61/09) 22 confirmed that an area is not precluded from being eligible
for aid where, while it is also used for agricultural purposes, the overriding objective is landscape
management and nature conservation.
21
Landschaftspflegebetriebe, also termed Landschaftspflegehöfe, i.e. farms whose agricultural activity primarily serves landscape management
and nature conservation objectives
22
Official Journal of the European Union C 346 of 18.12.2010: Judgment of the European Court of Justice of 14 October 2010 (Case C-61/09).
28 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020.3
Article 11 - Progressive reduction and capping of the payment
COM: 1. The amount of direct payments to be granted to a farmer under this Regulation in a given
calendar year shall be reduced as follows:
– by 20 % for the tranche of more than EUR 150 000 and up to EUR 200 000;
– by 40 % for the tranche of more than EUR 200 000 and up to EUR 250 000;
– by 70 % for the tranche of more than EUR 250 000 and up to EUR 300 000;
– by 100 % for the tranche of more than EUR 300 000.
2. The amount referred to in paragraph 1 shall be calculated by subtracting the salaries effectively
paid and declared by the farmer in the previous year, including taxes and social contributions
related to employment, from the total amount of direct payments initially due to the farmer
without taking into account the payments to be granted pursuant to Chapter 2 of Title III of this
Regulation.
Demand: The Alliance calls for a move away from the purely area-based payment. Member States should be
given the option to have standardised required labour usage considered as a frame of reference for the
purposes of activating payment entitlements. If the purely area-based payment model is to be retained,
the progressive reduction and capping mechanism should be introduced. It should be made mandatory
that the funds thus released are to be used in the Member States concerned to achieve environmental
objectives under Pillar 2 without national cofinancing. For increased effectiveness of this measure, only
half of the labour costs should be taken into account. Member States should have the option of setting
significantly lower thresholds for capping and degression.
Therefore we propose the following wording as a supplement to the provisions of Article 11(3):
Member States may decide to set lower thresholds for capping and for the different tranches of
direct payments.
Rationale: Given the thresholds as set out in the legislative proposals and the qualifying deduction of 100 % of the
full labour costs, the degressive reduction mechanism would have a negligible effect in many regions.
The mechanism however would increase the bureaucratic burden while the redistribution effect would
be extremely small 23. The fact that the full labour costs could be offset also means that small and me-
dium farms would likely suffer a comparative disadvantage.
23
According to calculations made by the Arbeitsgemeinschaft bäuerliche Landwirtschaft (AbL) significantly fewer than 0.5 % of farm holdings in
Germany would be affected by the reductions. Source: AbL-Positionspapier (2011): Bäuerliche Arbeit bestimmt Qualität der Landwirtschaft.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 293.
Article 14 - Flexibility between pillars
COM: 1. Before 1 August 2013, Member States may decide to make available as additional support
for measures under rural development programming financed under the EAFRD as specified
under Regulation (EU) No […] [RDR], up to 10 % of their annual national ceilings for calendar
years 2014 to 2019 as set out in Annex II to this Regulation. As a result, the corresponding
amount shall no longer be available for granting direct payments.
Demand: The Alliance urgently requests Member States to use this option in order to mitigate the negative
impacts of an insufficient Pillar 2 budget.
The Alliance calls on the Commission to determine
1. that funds thus transferred need not be co-financed, and
2. that 50 % of the funds thus transferred may be used to co-finance Pillar 2 measures.
Rationale: The stagnating Pillar 2 budget (and its increasing remit) jeopardizes the urgently needed achievement
of defined priority EU objectives such as those set out in the EU Biodiversity Strategy or the European
Action Plan for Organic Food and Farming 24. Intact soils, clean drinking water, and biodiversity do not
come for free. Money invested into these resources is an investment into the future, as exemplified by
the issue of drinking water and the Alps: The Alps are one of the European biodiversity hotspots and also
our most important water reservoir. Alpine rivers provide water for 170 million people. Climate change
will significantly reduce available water in the Alps and beyond. It is therefore all the more important
to protect and restore rivers within the meaning of the Water Framework Directive. Today only about 10
% of the rivers and streams of the Alps can be considered ecologically intact 25. Clearly there must not
be any further deterioration resulting from, for example, new hydroelectric power plants or increased
chemical contamination due to the intensification of farming. However, without an increase in the Pillar
2 budget, sufficient funding will not be available to finance important mechanisms for achieving
sustainability objectives, such as Natura 2000 and the Water Framework Directive.
24
EU Commission (2004): COM(2004)415 final.
25
Massaruto, A. (2011): Compact No. 03/2011: Water in Climate Change. CIPRA background report..
30 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020picture: Naturpark Weißbach – Christine Klenovec
.3
The Apollo (Parnassius apollo) is a true mountain species. Its range stretches from the mountains of Iberia across all of the European mountain
regions as far as to the Urals.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 313.
Article 20 - Regional allocation of the national ceilings
COM: 1. Member States may decide, before 1 August 2013, to apply the basic payment scheme at
regional level. In that case they shall define the regions in accordance with objective and non-
discriminatory criteria such as their agronomic and economic characteristics and their regional
agricultural potential, or their institutional or administrative structure.
2. Member States shall divide the national ceiling referred to in Article 19(1) between the re-
gions in accordance with objective and non-discriminatory criteria.
[…]
Demand: The Alliance for Agriculture and Nature Conservation in the Alps calls for the mandatory implementation
of an impact assessment of the impacts of different possible regional models in the Member States.
Rationale: The design of the regional models is extremely complex and a prior assessment should be made of their
impacts with regard to support for sustainable agriculture and a more equitable distribution of funds.
Only then will the process be transparent and different scenarios can be assessed objectively.
32 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020picture: Naturpark Weißbach – Christine Klenovec
.3
The whole family comes out to help make hay on the steeply sloping grasslands in the Austrian Weißbach Nature Park.
Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020 Maintain Alpine Diversity 333.
Article 22 - Value of payment entitlements and convergence
COM: 1. For each relevant year, the unit value of payment entitlements shall be calculated by dividing
the national or regional ceiling established under Articles 19 or 20, after application of the
linear reduction provided for in Article 23(1), by the number of payment entitlements allocated
at national or regional level according to Article 21(2) for 2014.
[…]
5. As of claim year 2019 at the latest, all payment entitlements in a Member State or, in case
of application of Article 20, in a region, shall have a uniform unit value.
6. When applying paragraphs 2 and 3, Member States, acting in compliance with the general
principles of Union law, shall move towards approximating the value of the payment entitle-
ments at national or regional level. […]
Demand: Transitional periods for the application of the new system of direct payments (i.e. the change from the
current historical model to the new model) should be deleted or at least be significantly reduced. The
Commission proposal provides for a possible gradual convergence and transitional periods until the end
of 2018 (see Article 22(5) and (6)).
Rationale: The gradual “approximation” provided for in Article 22 (6) would be burdensome in administrative,
social, and political terms and would unnecessarily prolong the historic model with all its disadvan-
tages and inequities.
34 Maintain Alpine Diversity Demands of the Alliance for Agriculture and Nature Conservation in the Alps for the EU Agricultural Policy 2014 – 2020You can also read
