EVALUATION of the impact of the Common Agricultural ......land use change (i.e. from the management of grassland and cropland) created 12% of total EU-28 GHG emissions in 2018 2 , - [PDF Document] (2024)

EN EN

EUROPEAN COMMISSION

Brussels, 21.5.2021

SWD(2021) 115 final

COMMISSION STAFF WORKING DOCUMENT

EVALUATION

of the impact of the Common Agricultural Policy on climate change and greenhouse gas

emissions

{SWD(2021) 116 final}

EN EN

1

Table of Contents

1. INTRODUCTION ............................................................................................. 3

2. BACKGROUND TO THE INTERVENTION ............................................... 5

3. IMPLEMENTATION/STATE OF PLAY .................................................... 13

3.1. Relevant Pillar I measures .................................................................. 13

3.2. Relevant Pillar II measures ................................................................ 16

4. METHOD ......................................................................................................... 18

4.1. Short description of methodology, tools and definitions.................. 18

4.2. Limitations and robustness of findings ............................................. 20

5. ANALYSIS ....................................................................................................... 22

5.1. Effectiveness ......................................................................................... 22

5.2. Efficiency .............................................................................................. 38

5.3. Coherence of CAP measures .............................................................. 42

5.4. Relevance to needs ............................................................................... 46

5.5. EU added value .................................................................................... 50

6. CONCLUSIONS ............................................................................................. 52

ANNEX 1: PROCEDURAL INFORMATION .................................................... 57

ANNEX 2: SYNOPSIS REPORT ON THE STAKEHOLDER

CONSULTATION .......................................................................................... 60

ANNEX 3: METHODOLOGY .............................................................................. 68

ANNEX 4: CAP CLIMATE MEASURES - COHERENCE AND ADDED

VALUE ............................................................................................................. 71

2

Glossary

AECM Agri-Environment-Climate Measure

ANC Areas facing Natural Constraints

CAP Common Agricultural Policy

CH4 Methane

CO2 Carbon dioxide

CO2eq CO2 equivalent

EAFRD European Agricultural Fund for Rural Development

EAGF European Agriculture Guarantee Fund

ECA European Court of Auditors

EEA European Environment Agency

EFA Ecological Focus Areas

EIP European Innovation Partnership

ESPG Environmentally Sensitive Permanent Grassland

EU European Union

EUR Euro, Eurozone currency

FA Focus Area

FADN Farm Accountancy Data Network

FAS Farm Advisory System

GAEC Good Agricultural and Environmental Condition

GHG Greenhouse Gas

Ha Hectare

ILUC Indirect Land Use Change

IPCC Intergovernmental Panel on Climate Change

LU Livestock Unit

LUC Land Use Change

LULUCF Land Use, Land Use Change and Forestry

M Measure

MFF Multiannual Financial Framework

N2O Nitrous oxide

NGO Non-Governmental Organisation

NH3 Ammonia

R&D Research and Development

SAPS Single Area Payment Scheme

SFS Small Farmers Scheme

SMR Statutory Management Requirement

UNFCCC United Nations Framework Convention on Climate Change

VCS Voluntary Coupled Support

WFD Water Framework Directive

WTO World Trade Organisation

3

1. INTRODUCTION

Most climate change scenarios1 predict a minimum increase in average global temperatures of

2°C above pre-industrial levels by 2050. Such a rise is expected to alter ecosystems, changing

long-term trends in localised temperatures and rainfall patterns, and increasing the frequency

and intensity of extreme weather events such as storms, droughts and intense precipitation,

with far-reaching socio-economic implications. Climate change is therefore a threat to the

wellbeing of our society and the functioning of our economy, affecting our ecosystems and

our natural and socio-economic environment.

The agricultural and forestry sectors are among the most vulnerable to the effects of climate

change, as they directly depend on climatic conditions and healthy ecosystems. Although

agriculture contributes to climate change through the release of greenhouse gases (GHG) into

the atmosphere, the sustainable management of land results in removals of carbon from the

atmosphere. EU agricultural activities, including emissions and removals from land use and

land use change (i.e. from the management of grassland and cropland) created 12% of total

EU-28 GHG emissions in 20182, making it the fifth biggest contributor to GHG emissions in

the EU, after the energy, transport, residential and commercial sectors.

The EU is addressing climate change through ambitious policies3 and in close cooperation

with international partners. The EU is on track to meet its GHG emissions reduction target for

20204, with estimates showing that, in 2018, EU GHG emissions were 23% below the 1990

level, exceeding the 20%. However, in view of the climate emergency, the Commission is

aiming to boost efforts and ambition through the European Green Deal5 to make Europe the

first climate-neutral continent by 20506. One result is the Commission’s proposal for a higher

emission reduction target by 2030 (-55% compared to 19907).

1 Climate scenarios of the United Nations Framework Convention on Climate Change (UNFCCC); European

Environment Agency (EEA) scenarios: https://www.eea.europa.eu/data-and-maps/figures/climate-change-

scenarios-data

2 https://agridata.ec.europa.eu/extensions/DashboardIndicators/Climate.html?select=EU28_FLAG,1

3 For an overview of EU policy, legislation and action to address climate change, see

https://ec.europa.eu/info/energy-climate-change-environment/topics/climate-change_en

As part of the European Green Deal, on 4 March 2020 the Commission proposed the first European Climate

Law to enshrine the 2050 climate-neutrality target into law: https://ec.europa.eu/clima/policies/eu-climate-

action/law_en

4 The EU 2020 climate and energy package (https://ec.europa.eu/clima/policies/strategies/2020_en) introduced

a clear approach to achieving a 20% reduction in total GHG emissions from 1990, which is equivalent to a

14% reduction from 2005. This objective is to be achieved through a 21% reduction from 2005 for emissions

covered by the emissions trading scheme, and a 9% reduction for sectors covered by the Effort Sharing

Decision (No 406/2009/EC of the European Parliament and of the Council of 23 April 2009).

5 The European Green Deal provides an action plan to boost the efficient use of resources by moving to a

clean, circular economy and to restore biodiversity and cut pollution. For more information, see

https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en

6 The climate neutrality objective has been endorsed by the European Council (European Council

conclusions, 12 December 2019) and Parliament (European Parliament resolution of 14 March 2019 on

climate change and resolution of 28 November 2019 on the 2019 UN Climate Change Conference in

Madrid, Spain (COP 25)) and is laid down in a legally binding manner in the proposed European Climate

Law.

7 In September 2020, the Commission proposed to increase the 2030 EU target to -55% of net GHG emissions

compared to 1990 levels. On 21 April 202 the Council and the European Parliament reached a provisional

political agreement setting into law the objective of a climate-neutral EU by 2050, and a collective, net,

greenhouse gas emissions reduction target. For more information, see https://ec.europa.eu/clima/policies/eu-

climate-action/2030_ctp_en

4

While EU non CO2 GHG emissions from agriculture have fallen by more than 20% since

1990, they have stagnated since 2010, highlighting the need for agriculture to accelerate its

transition to more climate-friendly practices.

The 2013 reform of the common agricultural policy (CAP) aimed to improve the targeting,

efficiency and coherence of policy instruments to address the long-term objectives of

sustainable management of natural resources and climate action, along with viable food

production and balanced territorial development. This was laid down in Article 110(2) of

Regulation (EU) No 1306/2013 (‘Horizontal Regulation’)8.

The legal context of the evaluation is set out in Article 110(5) of the Horizontal Regulation

that requires the Commission to present a report on the performance of the CAP to the

European Parliament and the Council by 31 December 2021. The findings and lessons learned

from this evaluation will feed into that report.

Accordingly, the purpose of this evaluation is to assess, notably through counterfactual

analysis, the net impact of the relevant policy instruments of the CAP 2014-2020 on

adaptation to climate change and GHG emissions, regardless of whether or not the measures

were specifically designed to address climate action.

The measures covered by the evaluation are the relevant ones set out in the basic regulations

of the CAP 2014-2020 regarding Direct Payments9, Rural Development

10, and the Horizontal

Regulation.

Besides helping to meet the legal reporting obligation, the evaluation has contributed to

other performance reporting requirements, including the Commission’s annual budget

discharge exercise. Its preliminary results, particularly on effectiveness and efficiency, were

available for the preparation of the impact assessment11

accompanying the 2018 legislative

proposals on the ‘CAP beyond 2020’, presented by the Commission on 1 June 201812

. The

evaluation is also particularly relevant to the objectives of the European Green Deal.

The geographical scope of the evaluation is the European Union of 28 Member States,

including the UK. In-depth empirical analysis was carried out through case studies in

10 Member States.

The evaluation covers the period following the implementation of the 2013 CAP reform,

notably the period after 1 January 2015 for direct payments and after 1 January 2014 for other

measures.

The evaluation covers all the evaluation criteria, assessing the effectiveness of the relevant

measures, with respect to their climate impact, as well as their efficiency, relevance,

coherence and EU added value. This staff working document is primarily based on the

corresponding external evaluation support study13 and draws from additional analysis and 8 Regulation (EU) No 1306/2013 of the European Parliament and of the Council of 17 December 2013 on the

financing, management and monitoring of the common agricultural policy, OJ L 347, 20.12.2013, p. 549-

607.

9 Regulation (EU) No 1307/2013 of the European Parliament and of the Council of 17 December 2013

establishing rules for direct payments to farmers under support schemes within the framework of the

common agricultural policy, OJ L 347, 20.12.2013, p. 608-670.

10 Regulation (EU) No 1305/2013 of the European Parliament and of the Council of 17 December 2013 on

support for rural development by the European Agricultural Fund for Rural Development (EAFRD), OJ L

347, 20.12.2013, p. 487-548

11 https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/future-cap_en

12 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2018%3A392%3AFIN

13 https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-

policy/cmef/sustainability/evaluation-cap-climate-change-and-greenhouse-gas-emissions_en

5

data from internal Commission and external sources. In the subsequent chapters, any

reference to analyses, interviews, findings, etc. should be interpreted as coming from the

evaluation support study, unless otherwise indicated and referenced.

2. BACKGROUND TO THE INTERVENTION

Agriculture is one of the sectors that contributes most to global GHG emissions. There are

three powerful greenhouse gases that are the by-products of agricultural activity, but the non-

CO2 greenhouse gases have a much bigger global warming potential than CO2:

methane (CH4) from livestock digestion processes (enteric fermentation), manure

management and rice cultivation;

nitrous oxide (N2O) from the use of organic and mineral nitrogen fertilisers and from

manure management;

carbon dioxide (CO2) from agricultural soil and biomass, as a result of land

management activities, ploughing, conversion of land uses, e.g. from grassland to

cropland, resulting in a mineralisation of the soil organic carbon to CO2 emitted in the

atmosphere, and from fossil energy consumption14.

Agriculture can mitigate climate change not only by reducing GHG emissions but also by

avoiding further carbon losses, increasing removals through the sequestration of carbon in

vegetation (e.g. hedges) and soils and increasing the contribution towards renewable energy

production.

Agricultural activities in the EU-28 generated 486 million tonnes of CO2 equivalents (CO2eq)

in 201315 (at the time of developing the CAP 2014-2020), corresponding to about 10% of total

GHG emissions. Emissions from agriculture decreased consistently for two decades between

1990 and 2010, notably due to declines in herds. However, emissions have stagnated under

the CAP 2014-2020. Due to the parallel decrease in emissions in other sectors of the

economy, the share of total EU emissions that can be attributed to the agricultural sector has

increased.

In 2018, the agricultural sector emitted 487 million tonnes of CO2eq in the EU-28,

corresponding to 12% of total EU GHG emissions. At the same time, agricultural production

increased by 9% in volume, highlighting a significant increase in production efficiency (i.e. a

reduction of emissions per unit produced).

14

Fossil energy is used in the form of fuels for agricultural machinery, as an energy source for heating

greenhouses and livestock buildings, or for operating tools and other devices on the farm.

15 Unless explicitly mentioned, figures on GHG emissions from agriculture include emissions from reporting

category 3, subject to the Effort Sharing Decision (ESD) targets, as well as category 4 on emissions from

agriculturally managed land under Land Use, Land Use Change and Forestry (LULUCF):

enteric fermentation (3A) (CH4);

manure management (3B) (CH4 and N2O);

rice (3C) (CH4);

managed agricultural soils (3D) (N2O);

cropland (including land converted to cropland) (LULUCF) (4B) (CO2);

grassland (LULUCF) (4C) (CO2).

6

Figure 1: Development of GHG emissions and agricultural production (Index, 2005 = 100)

Source: DG Agriculture and Rural Development

Moreover, agriculture is highly vulnerable to the impacts of climate change (e.g. crop failures

and tree dieback from droughts, storms, floods, or pest and disease outbreaks) and is facing

increasing climate-related risks. The farming sector needs to adapt to climate change (by, for

example, improving soil quality and water management, establishing hedge rows, planting

more resilient crop varieties, and adopting more diverse crop rotation practices) to secure

future yields16.

Therefore, the CAP has considerable potential to support climate mitigation and adaptation by

guiding and requiring how individual farmers choose to manage their land, crops and

livestock and how they use inputs, including energy, fertilisers and water, and their by-

products, wastes, residues and other non-food raw materials. In the 2017 public consultation

on ‘modernising and simplifying the CAP’17, 37% of respondents (other than farmers and

organisations) replied that the most relevant Commission priority18 for the future CAP was

‘mitigating and adapting to the impact of climate change and providing renewable energy’.

At the time of developing the CAP 2014-2020, EU climate policy was mainly defined by the

‘EU 2020 climate and energy framework’, which introduced three key targets for 2020: to

reduce GHG emissions by 20% from 1990 levels, to increase the share of renewable energy to

20% and to improve energy efficiency by 20%. These targets became legally binding through

the ‘EU climate and energy package’ in 200919.

Agriculture is one of the sectors covered under the Effort Sharing Decision, by which EU

countries have taken on binding annual targets until 2020 to reduce GHG emissions compared

to 200520

. This Decision does not set a sector-specific emission reduction target for

agriculture, but rather requires Member States to achieve a target that covers several sectors.

16

Communication COM(2021) 82 final – Forging a climate-resilient Europe - the new EU Strategy on Adaptation to

Climate Change

17 Running from 2 February 2017 to 2 May 2017 (see: https://ec.europa.eu/info/consultations/modernising-and-

simplifying-common-agricultural-policy_en).

18 https://ec.europa.eu/commission/publications/factsheets-commissions-10-priorities_en

19 See footnote 4.

20 The Effort Sharing Decision No 406/2009/EC establishes annual GHG targets for Member States for 2013-

2020. These targets concern emissions from most sectors not included in the EU emissions trading scheme,

such as transport, buildings, agriculture and waste.

The Effort Sharing Regulation (EU) 2018/842 sets binding annual GHG emission reductions for each

Member State from 2021 to 2030, helping to meet commitments under the COP21 Paris Agreement.

85

90

95

100

105

110

115

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

GHG emissions from agriculture Agricultural production volume index

7

Emissions and removals from land use and land use change, including in cropland and

grassland, are not part of the 2020 climate framework. However, the Land Use, Land Use

Change and Forestry (LULUCF) Decision21 requires Member States to provide information on

emissions and removals through cropland and grassland management and to provide national

reports on mitigation actions in these sectors.

EU climate policy in the 2014-2020 period was also shaped by the EU strategy on

adaptation to climate change. It encouraged Member States to adopt comprehensive

adaptation strategies, to build up their adaptation capacities and to take adaptation action in

key vulnerable sectors, including agriculture (through insurance against natural and man-

made disasters, for instance). Furthermore, it helped address the existing knowledge gaps on

adaptation in the agricultural sector. On 24 February 2021 the Commission announced a new,

even more ambitious EU Strategy on Adaptation to Climate Change, which commits the EU

and Member States to make continuous progress to boost adaptive capacity, strengthen

resilience and reduce vulnerability to climate change22.

Climate action is an integral part of the CAP 2014-2020 general objectives, notably the

objective on ‘sustainable management of natural resources and climate action’, with a focus

on GHG emissions, climate adaptation, biodiversity, soil and water. The 2013 CAP reform

also sought to align the CAP with the goals of the Europe 2020 strategy on smart, sustainable

and inclusive growth23

.

The Commission’s proposal for the 2014-2020 Multiannual Financial Framework (MFF)

introduced climate mainstreaming of the EU budget, with a general target of at least 20% to

be spent on climate-related measures. In addition, a specific target of a minimum of 30% of

the European Agricultural Fund for Rural Development (EAFRD) has been reserved for

measures relevant to climate change mitigation and adaptation and the environment24

.

Furthermore, with the introduction of the ‘greening payment’, a 30% share of the budget for

direct payments is provided to farmers adopting or maintaining mandatory climate and

environment-friendly practices. Farmers who do not comply with greening receive reduced

direct payments.

Beyond the general objective of the CAP 2014-2020 on climate action, the two pillars of the

CAP contain specific objectives and a broad range of instruments and measures to address

climate mitigation and adaptation.

The Pillar I specific objective on climate action refers to providing public goods (mainly

environmental) and pursuing climate change mitigation and adaptation. This objective is

pursued mainly through the ‘greening payment’ and the cross-compliance standards for Good

Agricultural and Environmental Conditions (GAECs) linked to CAP payments (see below).

Cross-compliance rules supplemented by greening help to provide a foundational level of

action on the environment and climate (as well as other concerns of EU citizens). Other direct

payments25 could also have indirect effects on mitigation and adaptation, as described in the

next chapters.

21

Decision No 529/2013/EU of the European Parliament and of the Council of 21 May 2013

22 https://ec.europa.eu/clima/sites/clima/files/adaptation/what/docs/eu_strategy_2021.pdf

23 https://ec.europa.eu/eu2020/pdf/COMPLET%20EN%20BARROSO%20%20%20007%20-

%20Europe%202020%20-%20EN%20version.pdf 24

Article 59(6) of the EAFRD Regulation (EU) No 1305/2013

25 Basic payment scheme, single area payment scheme, voluntary redistributive payments, payments for

farmers in areas with natural constraints, voluntary coupled support, small farmers scheme.

8

The greening measures have already been the object of a separate evaluation26

and comprise:

maintenance of permanent grassland, particularly for carbon sequestration, with two

components: (i) maintaining the ratio of permanent grassland to agricultural area – the

ratio of permanent grassland compared to the total agricultural area is set and

monitored by Member States at national or regional level with a 5% margin of

flexibility (i.e. no decrease above 5%); (ii) protecting the most environmentally

sensitive permanent grasslands (ESPG) from ploughing-up and converting in order to

support carbon sequestration, biodiversity and soil protection;

crop diversification, to improve soil quality: this covers farms with 10 to 30 hectares,

or more than 30 hectares, of arable land, which have to grow at least two or three types

of crops respectively. The main crop may not cover more than 75% of the land,

although there are exemptions to the rules, e.g. farmers with a large proportion of

grassland, which is in itself environmentally beneficial;

ecological focus areas (EFA): primarily in order to safeguard and improve biodiversity

on farms and entailing an obligation to dedicate at least 5% of the arable land

exceeding 15 hectares as an EFA, comprising a combination of areas or landscape

features as set out in the relevant regulation27

and selected by Member States as a

menu of choices for farmers.

The requirement to maintain permanent grassland is very important for protecting existing

carbon stocks and sequestering carbon from the atmosphere. The possibility for greater crop

diversity also has positive implications for carbon sequestration and a greater variety of crops

makes soil and ecosystems more resilient. EFA, such as trees, hedges or land left fallow, are

mostly beneficial for biodiversity and habitats, but also have co-benefits for climate

mitigation and adaptation.

Voluntary coupled support (VCS) is intended for certain sectors or regions where specific

types of farming or specific agricultural sectors, that are particularly important for economic,

environmental and/or social reasons, experience certain difficulties. The eligible animal-based

sectors and the protein crops sector are the largest VCS beneficiaries in the EU. It may have a

positive or negative impact on the climate depending on which activity and under which

conditions the support is granted.

The relevant Pillar II climate-specific objectives (also referred to as ‘priorities for rural

development’) include:

promoting resource efficiency and supporting the shift towards a low-carbon and

climate-resilient economy in the agriculture, food and forestry sectors (priority 5); and

restoring, preserving and enhancing ecosystems dependent on agriculture and forestry

(priority 4).

On top of this, three cross-cutting objectives were defined for rural development, namely

innovation, environment, and climate change mitigation and adaptation. These three

objectives should be integrated/reflected in Member States’ strategies and choices of

instruments.

26

https://ec.europa.eu/agriculture/evaluation/market-and-income-reports/greening-of-direct-payments_en. The

greening measures were also the subject of a special report by the European Court of Auditors

(https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=%7BD7000953-AF55-4CF5-9EB5-

D88635FCD332%7D). The special report concluded that, of the three greening measures, only the

maintenance of permanent grassland could be considered as relevant for the climate.

27 Regulation (EU) No 1307/2013, EU delegated regulation 639/2014, EU implementing regulation 641/2014

9

All the rural development priorities are broken down into specific areas of intervention,

known as ‘focus areas’. The rural development programmes set quantified targets under the

focus areas and outline the programme measures and their allocated funding that will be used

to reach the targets. The most climate-relevant focus areas under priorities 4 and 5 aim to:

increase efficiency in water use by agriculture (focus area 5A – addressing both

mitigation and adaptation);

increase efficiency in energy use in agriculture and food processing (focus area 5B);

facilitate the supply and use of renewable sources of energy (focus area 5C);

reduce GHG and ammonia emissions from agriculture (focus area 5D);

foster carbon conservation and sequestration in agriculture and forestry (focus area

5E);

prevent soil erosion and improve soil management (focus area 4C);

improve water management, including management of fertilisers (focus area 4B –

addressing both mitigation and adaptation).

Some of the CAP Pillar II measures have an ‘explicit intervention logic’ towards climate

change mitigation or adaptation, i.e. the EAFRD Regulation refers to climate-relevant

objectives for these measures. These include agri-environment-climate commitments, forest-

environment-climate commitments, cooperation, forest investments, investments in physical

assets, advisory farm management and relief services and disaster risk reduction (see Table 1).

One of the highest profile climate-relevant rural development measures is the agri-

environment-climate measure (AECM, measure 10). This voluntary measure for farmers

promotes a potentially wide range of practices (designed by Member States/regions within

their rural development programmes) which go beyond the baseline of mandatory

requirements, including those of cross-compliance28

. The beneficiaries are compensated for

additional costs and income foregone due to implementing the commitment. AECMs can

cover all the key issues of climate change, water, soil, air, biodiversity and landscapes (sub-

measure 10.1), as well as genetic diversity (sub-measure 10.2). Measure 10 is mandatory and

thus included in all rural development programmes.

Support for investments in physical assets (measure 4) explicitly addresses not only

economic but also environmental improvements, mainly in the farming and food sectors.

Relevant interventions offer considerable mitigation potential – in relation to manure

management, support for renewable energies and energy efficiency improvements, and

improvements to the natural value of a given area. Measure 4.4 provides support for non-

productive investments linked to the achievement of agri-environment-climate objectives.

This can include, for instance, the planting of hedges or the restoration of wetlands or

peatland.

Looking beyond farming, forestry is covered specifically by two measures which, between

them, have area-based and investment-based components – investments in forest area

development (measure 8)29

and forest-environmental and climate services and forest

conservation (measure 15). These serve both to establish new forests (agroforestry systems

as well) and to improve the environmental and economic value of existing forests, including

better protection against fires and other disasters, and thus contribute to climate change

mitigation and adaptation.

28

While the AECM has to go beyond the cross-compliance rules, its relationship with greening payments is

subject to the EU rule of ‘no double funding’, i.e. greening is not part of the regulatory baseline for the

AECM. Thus, the AECM cannot fund practices which are remunerated by greening payments.

29 Support for afforestation/creation of woodland; establishment and maintenance of agroforestry systems,

prevention and restoration of damage to forests from forest fires, natural disasters and catastrophic events;

improving the resilience and environmental value of forest eco-systems; investments in forestry technologies.

10

Rural development policy supports the development of physical as well as human capital – in

ways that can be linked to the environment and climate. Support for more individually

tailored advice and other services can come through the measure on ‘advisory services, farm

management and farm relief services’ (measure 2), which can also be used to set up the

farm advisory system (FAS) (see section 2.2.). The cooperation measure (measure 16) has a

very broad scope and is an important vehicle for funding innovation through the European

Innovation Partnership for Agricultural Productivity and Sustainability (EIP-AGRI). The EIP

is based on the ‘interactive innovation model’ and seeks to involve farmers actively in the co-

creation of innovative solutions to practical problems. Various parties with complementary

knowledge – farmers, advisers, researchers, businesses, NGOs and others – work together on

projects in ‘operational groups’ to develop such solutions and communicate their results

widely.

Another climate-relevant rural development measure is measure 5, which aims to support

agricultural holdings’ resilience to climate change through better risk reduction. Measure 5

supports preventive actions through sub-measure 5.1, as well as restoration after damage

through sub-measure 5.2.

Some measures were not designed with explicit climate-relevant objectives, but can

contribute significantly towards more environmentally friendly practices that help meet

climate objectives, such as:

The organic farming measure (measure 11), which supports farmers in converting to

and maintaining organic agriculture30

. The measure can contribute to carbon

sequestration in particular, thanks to the specific methods and land management

practices of organic farming, such as organic fertilisation and crop rotation. Moreover,

greenhouse gas emissions from the production of artificial fertiliser are avoided in

organic farming

Natura 2000 and Water Framework Directive payments (measure 12), which

support farmers and foresters in areas subject to disadvantages and restrictions

resulting from implementing relevant directives31

. Such payments can support the

conservation of wetland and peatland, or conversion from arable land to grassland

(e.g. in floodplains), thus contributing to carbon sequestration and climate change

adaptation.

Measure 17 supports risk management and improves farms’ economic resilience to shocks

linked to the effects of climate change (increased incidence of climatic hazards, price

volatility, etc.). The measure can support crop, animal and plant insurance premiums (sub-

measure 17.1), the creation of mutual funds for adverse climatic events, animal and plant

diseases, pest infestations and environmental incidents (sub-measure 17.2) and the

introduction of an income stabilisation tool (sub-measure 17.3). These aim to compensate

farmers for revenue losses due to extreme events; however, unless there are specific

conditions attached to the underwriting of these tools to help farmers adapt their production

systems to climate change (e.g. diversification of production), they do not guarantee the long-

term resilience of production systems.

Payments to areas facing natural or other specific constraints (measure 13) compensate

farmers for difficulties arising from the inherent biophysical constraints in mountain areas and

other areas facing natural or other specific constraints (related to altitude, climate, soil and 30

As set out in Regulation (EC) No 834/2007 on organic production and labelling of organic products.

31 Birds Directive: Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009

on the conservation of wild birds. Habitats Directive: Council Directive 92/43/EEC of 21 May 1992 on the

conservation of natural habitats and of wild fauna and flora. Water Framework Directive: Directive

2000/60/EC.

11

steep slopes as designated in Article 32 of Regulation (EU) 1305/2013). However, the

measure does not require any change in land management practices beyond mandatory

requirements and its contribution to climate objectives is not certain.

Other rural development measures which can be relevant for climate objectives, depending on

how they are designed and targeted, include knowledge transfer and information actions

(measure 1), quality schemes (measure 3), support for farm and business development

(measure 6), basic services in rural areas (measure 7) and LEADER (M19).

In addition to the interventions covered by the two pillars, a number of cross-cutting

measures help to address climate targets.

Cross-compliance is a mechanism that links elements of both pillars of the CAP to farmers’

compliance with various basic standards and their application of fundamental good practice. It

aims to help agriculture develop sustainably and to link the CAP better to other EU policies,

including environmental and climate policies. It includes two types of obligations:

Statutory management requirements (SMRs), which are 13 packages of requirements

arising from non-CAP EU legislation on the environment, food safety, animal and

plant health and animal welfare (e.g. nitrates, birds and habitats), and which are

applicable to all farmers whether or not they receive CAP income support.

Standards for GAECs, which have their legal basis within the CAP. The seven EU

standards relate to management of water, soil and carbon stocks, and landscape

features. Member States must translate these EU standards into national standards,

taking into account local needs and situations. GAEC 6 (maintenance of soil organic

matter, including the ban on burning arable stubble) contributes to climate mitigation

by preventing the direct release of CO2 into the atmosphere. GAEC 4 (minimum soil

cover) and GAEC 5 (site-specific conditions limiting erosion) may have an impact on

climate change adaptation and mitigation by limiting soil erosion, protecting water

courses, improving resilience against floods and improving water retention.

Through the provisions of cross-compliance, when farmers who receive Pillar I direct

payments (with the exception of payments under the small farmers scheme) or Pillar II area-

based payments do not respect the standards concerned, their payments under these schemes

can be reduced.

Another set of cross-cutting provisions concerns the Farm Advisory System (FAS), which all

Member States are required to set up/designate (this can be done with the support of a rural

development measure). In general terms, the FAS should help CAP beneficiaries become

more aware of the relationship between farm practice and management, and of various

standards32.

Regarding climate-relevant CAP measures, it is important to point out that only some of the

interventions that are covered by this evaluation have been specifically designed to include

intended environmental and climate impact objectives. However, several measures that lack

an explicit intervention logic towards climate action may still have relevant climate effects,

for example the management of EFA.

32

Among the topics on which the FAS must offer advice to farmers, the following are directly linked to the

environment and climate: the rules of cross-compliance; the requirements of greening payments; the basic

requirements of maintaining agricultural area with regard to eligibility for direct payments; the Water

Framework Directive and the Sustainable Use of Pesticides Directive.

12

Table 1: The main climate-relevant CAP measures

Measure (M)/instrument Objective in the Regulation Measures targeting

Mitigation Adaptation

Pillar I -

1 Greening measure (permanent

grassland ratio)

Environmental benefits (carbon

sequestration) Yes No

2 Greening measure

(environmentally sensitive

permanent grassland)

Environmental benefits (carbon

sequestration) Yes No

Horizontal measures/standards

3 GAEC 4 (minimum soil cover) Limit soil erosion, protect water courses and

improve resilience against floods and water

retention

Yes Yes

4 GAEC 5 (site-specific

conditions limiting erosion) Yes Yes

5 GAEC 6 (maintenance of soil

organic matter)

Prevent the direct release of CO2 into the

atmosphere Yes Yes

6 Farm advisory system Awareness raising about farm practices and

environmental and other standards Yes Yes

Pillar II – Rural development

7 M1: Knowledge transfer and

information actions

Spread knowledge and improve access to

information Yes Yes

8 M2: Advisory farm

management and relief

services

Improve access to advice Yes Yes

9 M4: Investments in physical

assets

Support provision of physical infrastructure Yes Yes

10 M5: Disaster risk reduction Support to reduce probable consequences of

natural disasters; investments to restore land

and production potential

No Yes

11 M7: Basic services and village

renewal

Investments in small-scale infrastructure,

(also renewable energy and energy saving) Yes No

12 M8: Forest investments Extend and improve forest resources

(including agroforestry) as climate-friendly

land use; support investment and

management (resilience and fire prevention)

Yes Yes

13 M10: Agri-environment-

climate commitments

Support agricultural practices beneficial for

the environment and climate (going beyond

the baseline of legal requirements)

Yes Yes

14 M11: Organic farming Support organic farming practices relevant

to carbon sequestration Yes Yes

15 M12: Natura 2000 and Water

Framework Directive

Support, notably, conservation of wetland

and peatland Yes Yes

16 M15: Forest-environment-

climate commitments

Support for forest land and thus carbon

stocks Yes Yes

17 M16: Cooperation Support joint actions to secure greater

environmental and climate benefits Yes Yes

Source: DG Agriculture and Rural Development

13

3. IMPLEMENTATION/STATE OF PLAY

Under the Multiannual Financial Framework 2014-2020, a total of EUR 408.3 billion is

earmarked for the CAP, of which EUR 308.7 billion is allocated to Pillar I via the European

Agriculture Guarantee Fund (EAGF); the remaining EUR 99.6 billion is allocated to Pillar II via

the European Agricultural Fund for Rural Development (EAFRD). The rural development

policy of the CAP is implemented over a seven-year period, through rural development

programmes designed by national or regional managing authorities. Overall, 118 rural

development programmes have been implemented in the 28 Member States over the 2014-2020

period. Adding the co-funding by national, regional and private resources, the total amount of

funding for the CAP’s rural development policy is EUR 161 billion.

Based on the climate tracking methodology defined for the current programming period33, in line

with the OECD’s ‘Rio markers’34, the CAP’s contribution to climate actions is estimated at 26%,

or EUR 102.8 billion, i.e. well above the 20% commitments.

3.1. Relevant Pillar I measures

In 2018, 154 million hectares (86%) of all EU agricultural land was supported under the direct

payment scheme and therefore subject to compliance with the relevant practices that Member

States have established under good agricultural and environmental conditions (GAECs) and

statutory management requirements (SMRs).

Member States have translated the core obligations of the three GAECs aimed at protecting

soil and carbon stocks in different ways that fit their own circ*mstances. Under GAEC 4

(minimum soil cover), all Member States must have minimum soil cover, with a particular

focus on areas with a high risk of erosion and on setting time-specific rules; Member States have

differed in the way they identify land under this obligation.

Under GAEC 5 (minimum land management reflecting site specific conditions to limit

erosion), the main measures set by Member States tackled land with high slopes, usually

defined as more than 10% slope. More than half (15) of Member States have cultivation

requirements (transversal to the contour of the slope and minimal tillage), a third (8) limit the

crops to be planted (crops with a small canopy, e.g. potato), and a few (3) ban ploughing during

a certain period (generally winter). Three Member States add additional requirements related to

improving/maintaining drainage systems, soil vegetation cover, banning tillage on waterlogged

and flooded soils, promoting preservation of terraces, stonewalls and ditches, banning

overgrazing or requiring inter-row green cover for permanent crops.

All Member States implement the main measure of the ban on stubble burning under GAEC 6

(maintenance of soil organic matter level through appropriate practices, including a ban

on burning arable stubble, except for plant health reasons). A few Member States go beyond

this core requirement by requiring a soil analysis with possible corrective actions, soil coverage

with nitrogen-fixing crops, incorporation of crop residues, crop rotation, and a ban on

cultivation in species-rich and semi-natural habitats.

In 2019, 142 million hectares of agricultural areas, corresponding to 80% of EU agricultural

land, was subject to one or more greening obligations. Around 3.8 million hectares, covered

33

The methodology for climate tracking for the EAFRD is set out in Annex II of Commission Implementing

Regulation (EU) No 215/2014 of 7 March 2014. This includes a list of coefficients for calculating the amount

of support for climate change objectives under the EAFRD.

34 Since 1998, the Development Assistance Committee (DAC) of the Organisation for Economic Cooperation and

Development (OECD) has set up the ‘Rio markers’ system. This consists of policy markers to monitor and

statistically report on development finance flows targeting the themes of the Rio Conventions, namely

biodiversity, desertification, climate change mitigation (i.e. reductions in or absorption of GHG emissions) and

climate change adaptation (including climate risk mitigation and vulnerability reduction).

14

by Small Farmer Scheme (SFS) and 9.6 million hectares of organic areas were exempted from

greening. Compared to 2015, the area under the SFS exemption halved and organic areas

increased by two thirds.

In 2015, the area of declared permanent grassland amounted to 48.5 million hectares,

compared to 44.3 million hectares in 2012, which served as a reference year for establishing

greening obligations (excluding Croatia, which has 2013 as a reference). The change between

2012 and 2015 was due to several factors: the effects of the 2013 admission of Croatia as an EU

Member State; expansion of the areas eligible as permanent grassland in the current period to

include, for example, shrubs and trees that can be grazed; creation and conversion of permanent

grassland; and changes in the population benefiting from direct payments. The situation differed

between Member States; while some saw little or no change in additional permanent grassland

areas, others registered a substantial increase (by more than half in Spain, Italy, Lithuania,

Croatia and Bulgaria, and ten times more in Finland). The new definition of permanent

grassland influenced especially the southern Member States characterised by agro-pastoralism.

Some of the amendments introduced in the ‘Omnibus Regulation’ in 201835 allowed for a

narrower definition of ‘permanent grassland’. For example, nine Member States (Bulgaria,

Croatia, Cyprus, Germany, Greece, Italy, Lithuania, Slovakia and Spain) decided to apply the

newly introduced criterion, according to which grassland is not classified as permanent

grassland if it has been ploughed within a period of 5 years. Other Omnibus amendments to the

definition allowed for its scope to be expanded. For example, Member States could expand areas

with shrubs and/or trees which produce animal feed, provided that the grasses and other

herbaceous forage remain predominant. In 2019, overall, 51.7 million hectares of permanent

grassland was declared under the direct payment scheme, reflecting the changes to land use in

Member States but also the effects of the above-mentioned amendments. It represents 85% of

the total EU permanent grassland reported in the annual land use survey36.

In accordance with greening rules, almost all Member States decided to manage the ratio of

permanent grassland at national level. Only four (Belgium, France, Germany and the UK) opted

to calculate the ratio at regional level.

At EU level, the area of permanent grassland under the greening ratio obligation amounted

to 44.0 million hectares in 2015 and increased by 8% to 46.7 million hectares in 2019. The

figures under the greening ratio do not include exempted areas of the SFS and organic

producers. Between 2015 and 2019, 16 Member States registered an increase in the annual ratio,

while seven Member States and 19 regions (in the case of the four Member States that made

regional calculations) saw reduced annual ratios in 2019 compared to the figures for 2015.

For the comparison of annual ratios to the 2015 reference ratio (‘the comparison ratio’), the

mechanism of reconversion was activated four times in two Member States (Cyprus, in 2015

and 2016, and Estonia, in 2016 and 2018) to reverse the more than 5% drop in the annual ratio.

As of 2019, the comparison ratio registered negative values in nine Member States and

10 regions of the four Member States that made regional calculations, but none exceeded the 5%

threshold.

However, in most cases the changes in national/regional annual ratios under greening and in

the ‘comparison ratio’ resulted from a reallocation of permanent grassland areas within the

terms of the ratio rather than their actual decrease. Between 2015 and 2019, permanent

grassland increased in 17 Member States, with a relative +/- 1% stabilisation in eight Member

States and a decrease of more than 1% in two Member States (Estonia and the UK). Instead, the

35

Regulation (EU) 2017/2393 (the so-called ‘Omnibus Regulation’), https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX%3A32017R2393

36 The statistical definition of permanent grassland is narrower, as permanent grassland is not normally included in

the crop rotation on the holding for 5 years or more, i.e. it is not ploughed. For greening, ploughing of grassland

may not change its classification.

15

figures reflected the combined effects of a substantial increase of/conversion to organic

permanent grassland and, to a lesser extent, of decreasing permanent grassland under the SFS. It

was also affected by changes to agricultural areas. While seven Member States deemed such

situations sufficient to adapt the reference ratio, others did not do so, resulting in lower or

negative figures for the ‘comparison ratio’.

In 2019, of 16.6 million hectares of permanent grassland in Natura 2000 areas,

9.3 million hectares (56%) were designated as ESPG and 5.7 million hectares (34%) were

declared by farmers. Compared to 2015, while the area of Natura 2000 permanent grasslands

remained stable (16.5 million hectares in 2015), the designated and declared ESPG areas rose by

more than 1 million hectares (8.2 million hectares of designated and 4.4 million hectares of

declared ESPG in 2015). This translates to 18% of all permanent grassland declared under the

direct payments scheme being designated as ESPG (ranging from 0.2% in Portugal to just above

57% in Cyprus), and thus protected from ploughing.

These figures reflect differences in delineating/selecting Natura 2000 areas when implementing

the underlying Nature and Birds Directives and Member States’ decisions to designate

permanent grassland within Natura areas. Eight Member States37 designated all permanent

grasslands within Natura 2000 as ESPG, while others designated only a proportion. The lowest

proportions of permanent grassland in Natura areas designated as ESPG in 2019 were in

Portugal (1.3%) and Ireland (4.0%). In terms of ESPG declared by farmers, these ranged from

0.1% of permanent grasslands in Natura 2000 in Portugal and 2% in Austria to 100% in Greece

and in Sweden.

Four Member States (Belgium, Czechia, Italy and Latvia) also designated permanent grasslands

outside Natura 2000 areas as ESPG, protecting an additional 0.6% of all EU permanent

grasslands under the CAP.

In 2019, 69% of EU arable land fell under the EFA obligation (72.4 million hectares). This

reflected the exemptions from the EFA obligation (Small Farmers’ Scheme, organic farmers and

farmers with less than 15 hectares of arable land) and the additional specific exemptions38 added

by the Omnibus Regulation for certain types of farms. The selection of EFA areas and

features differed between Member States, with some opening the whole range of EFA types and

others only a narrow range. Between 2015 and 2019, Member States’ choices remained

relatively stable. The major change from 2018 onwards came from the Omnibus Regulation,

which added three EFA types and increased weighting factors for nitrogen-fixing crops and

short rotation coppice, and from the delegated legislation that restructured some types of

landscape features and banned the use of plant protection products on fallow land and

productive EFA types (such as protein crops).

In absolute terms, 9.5 million hectares were declared as EFA in 2019, representing 13.7% of

arable land under obligation. In terms of uptake by farmers, the most frequently declared

EFA types in 2019 were those linked to land lying fallow (21%) and to productive EFA: catch

crops (55%) and nitrogen-fixing crops (22%). However, the composition of EFA areas

changed compared to 2015: in 2015, areas under catch crops and nitrogen-fixing crops both

represented about a third of all EFA areas, and the share of fallow land was higher,

corresponding to a quarter of all EFA areas. In contrast, EFA areas under landscape features

increased in this period, both in physical terms and, as a share of the total, to 2%.

In 2019, 74% of EU arable land fell under the crop diversification obligation

(77.7 million hectares), compared to 75% in 2015 (80.5 million hectares). This reflected changes

to the areas benefiting from direct payments, changes to areas exempted from the obligation

(SFS, organic farms and exemptions specific to crop diversification) and the additional

37

Bulgaria, Czechia, Greece, Italy, Hungary, Netherlands, Slovakia, Finland and Sweden.

38 Article 46 of Regulation (EU) No 1307/2013.

16

exemptions specific to crop diversification that were added by the Omnibus Regulation for

certain types of farms.

Of the farms applying crop diversification, 87% of arable land was under the obligation to have

at least three crops and the remaining 13% under the obligation to have at least two crops,

though the figures differ between Member States depending on the average size of the arable

land of farms. While six Member States (Bulgaria, Estonia, France, Latvia, Slovakia and the

UK) have 95% or more of arable land under the three-crop obligation, three Member States have

a more balanced distribution, with around half (Slovenia and Finland) or more (Greece) of

arable land under two crops. In Malta, all farms follow the two crops rule only.

Member States can allocate up to 8% or, in the case of some Member States, up to 13% of their

national ceiling for direct payments to voluntary coupled support (VCS). Funding can be

increased by a further 2% to support protein crops. In 2018, the most supported sectors in the

EU-28 were: (i) beef and veal (23 Member States, 41% of all payments effected under VCS);

(ii) milk and dairy products (19 Member States, 20%); (iii) sheep and goat meat (21 Member

States, 12%); (iv) protein crops (15 Member States, 11%); (v) sugar beet (11 Member States,

4%); (vi) fruit and vegetables (19 Member States, 4%). Germany is the only Member State not

applying VCS.

3.2. Relevant Pillar II measures

For the period 2014-2020, EUR 68.6 billion and EUR 6 billion were programmed under

priorities 4 and 5 respectively, which corresponds to 45.6% and 6.4% of the total planned public

expenditure on rural development39 (EUR 151 billion). At the end of September 2020, the EU-28

had executed 76% (under Priority 4) and 46% (under Priority 5) of the planned public

expenditure. It is worth pointing out that many environment/climate measures programmed

under Priority 4 also contribute to climate action, but the budget can be allocated to one priority

only. It explains in part the low budget allocated to Priority 5, which has the most climate-

relevant focus areas (5D and 5E).

The main measures programmed under Priority 4 are the support for areas facing natural

constraints and agri-environment-climate commitments. Under Priority 5, three quarters of the

budget is programmed under investments, included in forestry under focus area 5E. Several

climate-relevant measures were entirely or close to 100% programmed under these two

priorities: agri-environment-climate commitments, Natura 2000 payments, support for organic

farming, ANC payments and support for forests. By contrast, less than 50% of the planned

advice budget, around 30% of knowledge transfers and 20% of investments aimed to address

climate change and protect natural resources.

39

Not taking into account additional national financing (i.e. ‘top-ups’ to national co-financing).

17

Table 2: Measures programmed (total public) under priorities 4 and 5

Priority 4 Priority 5 Share of the

measure

programmed

under

priorities

4 and 5

Measures EUR

million

% EUR

million

%

M01 Knowledge transfer/information 363 1% 125 1% 34%

M02 Advisory services 305 0.4% 62 0.6% 46%

M04 Investments in physical assets 2 119 3% 4 767 50% 20%

M06 Farm business and development 0% 146 2% 2%

M07 Basic services and village renewal 1 398 2% 258 3% 16%

M08 Forest investments 3 055 4% 2 487 26% 92%

M10 Agri-environment-climate 24 021 35% 1 193 12% 100%

M11 Organic farming 11 549 17% 131 1% 100%

M12 Natura 2000 808 1% 7 0% 100%

M13 Areas facing natural constraints 24 226 35% 221 2% 97%

M15 Forest-environment-climate 286 0.4% 3 0% 100%

M16 Cooperation 427 1% 208 2% 25%

Total 68 558 100% 9 608 100% 52% Source: DG Agriculture and Rural Development

At the beginning of the programming period, Member States fixed targets for a series of

common result indicators, so their progress in implementing their rural development

programmes can be followed. The achievements of the EU-28 in implementing measures

planned under priorities 4 and 5 up to the end of 2018 can be summarised as follows:

focus area 5A - increasing efficiency in water use by agriculture: by the end of 2018,

5% of irrigated land had been switched to more efficient irrigation systems, achieving

40% of the target;

focus area 5B - increasing efficiency in energy use in agriculture and food

processing: 18% of the target planned for 2023 (EUR 1.04 billion) was achieved in

terms of total investment in energy efficiency;

focus area 5C - increasing the supply and use of renewable sources of energy, and of

by-products, wastes and residues, for the purpose of bio-economy: 17% of the target

planned for 2023 (EUR 1.19 billion) was achieved in terms of total investment in

renewable energy production;

focus area 5D - reducing GHG and/or ammonia emissions: in 2018, around 2% of

agricultural land was under management commitments that aimed to reduce GHG and/or

ammonia emissions, and more than 80% of the target was achieved. Less than 1% of EU

livestock units were concerned by investments to reduce emissions, achieving 61% of

the target;

focus area 5E - carbon sequestration and conservation: less than 1% of EU

agricultural and forest land was under management that contributed to carbon

sequestration and conservation, achieving close to 90% of the target;

focus area 4B - water quality (covering fertiliser management): 12% of agricultural

land and 0.1% of forest land were under contracts to improve water management by the

end of 2018. While 84% of the target was achieved for agricultural land, only 14% was

achieved for forest land;

focus area 4C - prevention of soil erosion and improvement of soil management:

11% of agricultural land and 0.22% of forest land were under management contracts to

help prevent soil erosion and improve soil management in 2018. While 85.9% of the

target was achieved for agricultural land, only 16.9% was achieved for forest land;

18

focus area 3B - farm risk prevention and management: the share of farms

participating in risk management schemes was close to 6% in 2018, achieving 28.3% of

the target.

Member States went far beyond the regulatory obligation to reserve at least 30% of the Pillar II

budget for measures addressing climate and environmental objectives, achieving almost 55% on

average. However, it is worth noting that payments for areas facing natural or other specific

constraints, whose actual contribution to the climate objectives is weak, are the largest

contributor to this target (20%). They are followed by the agri-environment-climate measures

(17%) and organic farming (10%).

4. METHOD

The evaluation builds on the external support study conducted in 2015-2017, complementing it

with internal (DG Agriculture and Rural Development) analysis based on more recent data and

information, and including relevant findings from available external analyses and assessments.

Considering the wide range of topics under evaluation, the methodological approach of the

evaluation support study combines theoretical and empirical approaches and includes a variety

of methods, both quantitative and qualitative. Due to the complexity, the robustness of the

evaluation faces a number of limitations.

4.1. Short description of methodology, tools and definitions

The starting point for the evaluation was the development of the intervention logic (see Annex

4). This was the basis for assessing the potential impact of each measure on climate action and

for analysing budget allocations for climate action across the CAP.

The impact of CAP measures was quantified where appropriate and feasible, given the

suitability and reliability of data available to the study. This is based in part on measure uptake

data submitted by Member States in their annual implementation reports for the EAFRD (the

reports for 2015 and 2016 for the support study, complemented with figures for 2017-2019).

However, given the low implementation level at the beginning of the programming period, an

accompanying qualitative review of CAP measures addresses gaps in the analysis where

quantification of GHG impacts was not possible. This strengthens the understanding of causality

between the use of measures and the impact in terms of climate mitigation, and provides

information relating to potential emission leakage effects. The qualitative assessment is also

used to understand better the combined impact of CAP measures.

The evaluation support study used a simulated quantification of GHG emissions and removals.

For the GHG simulation, the ‘GAINS’ (Greenhouse gas – Air Quality Interaction and

Synergies) quantitative model40 was used to establish the baseline for simulating emission 40

The GAINS model contains information about the expected evolution of GHG emissions and activity variables

for a number of scenarios. In GAINS, activity drivers for emission projections enter calculations externally

using projections from different internationally-recognised sources. In the specific case of agricultural scenarios

for Europe, these come from the CAPRI model, in line with the macroeconomic scenarios developed for the EU

by DG ECFIN. CAPRI is a modelling system for the EU agricultural sector and uses a unified, complete and

consistent data base, which is derived from various sources such as national statistics and regional statistics.

This model also allows the effects of different policy initiatives on activity variables to be considered. With

these activities, GAINS estimates GHG emissions by applying a consistent methodology across all countries.

The use of GAINS emissions projections is useful for contextualising the estimated mitigation of GHG from

CAP reporting data in terms of the expected evolution of such emissions until 2020. For example, the estimated

mitigation of GHG produced by a measure using a specific uptake value, used in conjunction with the trend of

the projections, may indicate whether its presence can bring about reductions, stabilisations or even increases in

the tendency depicted by the GAINS emissions.

19

reductions and removals associated with the individual CAP measures according to their

mitigation potential. This was based on uptake data reported by Member States (for 2015-2017)

with relevant emission pathways and factors from literature.

A variety of tools and techniques were used to develop the evaluation support study, such as:

Stakeholder consultations, including: a public consultation on modernising and

simplifying the CAP41

; consultation of the relevant Civil Dialogue Groups; interviews

with stakeholders and operators in the agri-food supply chain; consultation with relevant

academics. The synopsis report of the stakeholder consultation is provided in Annex 2.

A survey of farmers and farm advisers about their experience of climate pressures and

relevant CAP instruments. This was also used to gain information from farm advisers on

the extent of uptake of different types of innovation.

Documentary research, literature review, statistical data analysis (measure uptake data

reported by Member States in their annual implementation reports). This also included

data from the Farm Accountancy Data Network (FADN) and expenditure data derived

from the EU out-turn budget and Member States’ financing plans.

Case studies were carried out to gather detailed information about CAP implementation

and climate action in 10 Member States42 that represent a range of farming systems,

biogeographical conditions and climate challenges.

Cost-effectiveness analysis of budget allocations for climate action across the CAP. The

EU’s climate tracking methodology was used to track climate spending in the EAGF and

European Structural and Investment Funds, including the EAFRD. The calculation used

to estimate the contribution of the CAP to climate funding is based on allocating one of

three possible climate markers (0%, 40% or 100%) to each item of expenditure43.

Coherence matrix and scoring: to analyse coherence between regulations and/or

intervention logics and assess the internal and external coherence of the CAP measures.

Emissions leakage

The occurrence of GHG emissions outside the boundary of the local agricultural production

system, as a result of local change (e.g. implementation of an agricultural measure to modify

environmental impact), may be referred to as ‘leakage’. The term is used to describe net

emission change, including emissions, mitigation of emissions, and removals (removals from

the atmosphere of GHGs, also called ‘sequestration’) outside the system boundary. Hence, to

fully account for GHG emissions and removals which result from changes to agricultural

systems within the EU caused by the CAP, there is a need to consider any resultant GHG

emissions elsewhere. Many CAP measures change or influence production at a local level,

which will have an economic and market influence beyond the agricultural system concerned.

The main pathway for leakage considered in the evaluation support study is the net change in

GHG emissions outside of the Member State implementing the measure that is induced by a

change in production. Production changes include:

changes in crop production for food, livestock feed, energy and fibre;

changes in production from livestock farming, predominantly production of food.

41

https://ec.europa.eu/agriculture/consultations/cap-modernising/2017_en

42 Croatia, Czechia, France, Germany, Hungary, Ireland, Lithuania, the Netherlands, Romania and Spain. The case

studies were carried out at national level, but with a particular focus on a single administrative region in the

federal Member States (Aquitaine in France, Saxony-Anhalt in Germany and Andalucía in Spain).

43 For the EAFRD, the method applies different coefficients to different EAFRD priorities and focus areas (no

matter which measures are programmed under these priorities/focus areas).

20

The net change in emissions elsewhere (the leakage) is a mix of emissions from production

systems and from land use change.

For further details on the methodology and estimation of leakage, see Annex 3.

4.2. Limitations and robustness of findings

The limitations of the analysis affect the robustness of findings due to the limited availability of

accurate, detailed and hom*ogenous data, the very limited observation period when the support

study was carried out and the limited evidence to establish the link between CAP measures and

climate mitigation. The first year of implementing the direct payments scheme was 2015 and the

rural development programmes for 2014-2020 were approved by the Commission between

December 2014 and November 2015. Consequently, the evaluation support study could only

rely on 2 years (2015-2016) of data from Eurostat and 1 year (2015) of data from the FADN and

the Clearance of Audit Trail System (CATS).

A key limitation has been the impossibility to quantify the overall net impact of all the CAP

measures on emissions. It is also difficult to deliver an overall assessment of the individual CAP

2014-2020 measures against their desired climate objectives, particularly at EU level, because of

the wide range of implementation choices by individual Member States.

The limitations implied that the emission effects of some measures could not be assessed

quantitatively. The quantitative method used in the evaluation support study to estimate the

impact of CAP measures on emissions is limited. It is questionable whether the impact of a

measure on emissions is suitable for quantification at all. Even when uptake figures are available

for a certain measure, sometimes there is not a direct enough link between the use of the

measure and the impact it has, if any, on climate change mitigation or adaptation. For example,

there is not a direct enough link between the provision of advice to farmers and any changes

they may make in their land management practices to assess the impact of advice measures on

the reduction of emissions to be quantified.

The main limitations of the method, due to lack of data (short period of implementation) and the

impossibility to construct counterfactual situations for all measures44

, can be summarised as

follows:

the impossibility of quantifying the overall net impact of direct payments on emissions.

Direct payments, including coupled support to extensive livestock systems, prevent land

abandonment and contribute to the maintenance of permanent grasslands. When the land

is abandoned, the mitigation impact depends on the alternative use of this land: on one

hand it is negative if the land is ploughed, kept bare-fallow or constructed (soil sealing),

on the other hand it is positive if the land is afforested or left for spontaneous

revegetation;

the difficulty of establishing the extent to which the CAP measures support mitigation

actions, due to the lack of a counterfactual situation45, the level of detail in some uptake

data, the wide range of potential biogenic emissions and the difficulties aggregating

GHG emissions reported at project level;

the lack of specific indicators for the individual measures with respect to their impact on

mitigation and adaptation, and the fact that complementary result indicators (see Chapter

3) were not available in time for the evaluation support study;

44

A key limitation has been the absence of data to show whether permanent grassland has been kept unploughed,

ploughed then reseeded, or converted and ploughed.

45 The CAP applies for a long time and covers a very large area.

21

the difficulty of assessing the effectiveness of the permanent grassland ratio and

measures to protect environmentally sensitive permanent grassland , isolating this from

the effectiveness of other measures such as Natura 2000;

the difficulty of constructing the counterfactual situation in case of no support and

analysing what would happen to fallow land;

the scarcity of available data with which to assess the effect of innovations on climate

action, meaning it was not possible to assess the overall impact of innovations on climate

objectives;

the lack of evidence with which to assess the impact of ‘soft’ measures, such as advisory

measures, or training and advice.

With these caveats, the contractor nevertheless has developed a GHG simulation according to

the mitigation potential of CAP measures.

As regards adaptation, the assessment of the measures’ impact was particularly difficult, as there

are no legally binding or concrete, quantified objectives for adaptation, apart from the budget

requirements mentioned in Chapter 2. The requirement to allocate 30% of EAFRD funds in each

rural development programme to measures addressing environment and climate objectives has

not been an effective driver since, in most cases, most of this support went to measure 13 - areas

facing natural constraints, which could have little relevance to adaptation.

Furthermore, it was also difficult to derive a robust general picture from the opinions presented

in the case studies, given the very different situations and particularly the implementation

choices in the Member States covered by the case studies.

Despite the lack of some data, the solid methodology, particularly the modelling analysis and

the in-depth case studies, ensured the validity of the main findings of the evaluation.

22

5. ANALYSIS

5.1. Effectiveness

This chapter aims to assess the extent to which the relevant CAP 2014-2020 measures are

effective in contributing to climate change mitigation and adaptation.

Trend of GHG emissions and the evidence base for assessing the CAP’s impact

In 2018, the agricultural sector emitted 486 million tonnes of CO2eq in the EU-28 (of which

435 million tonnes were non-CO2 GHG), corresponding to 12% of total GHG emissions46.

Emissions decreased significantly between 1990 and 2010 and have stagnated under the CAP

2014-2020. In view of the EU climate targets, the agricultural sector will need to step up its

efforts to contribute to the EU’s climate ambition. In 2018, 44% of EU-28 agricultural non-CO2

emissions were related to enteric fermentation of ruminant livestock (methane - CH4), 37% to

fertilisation of agricultural soils (nitrous oxide - N2O and, to a lesser extent, CO2), 14% to the

management of manure (CH4 and, to a lesser extent, N2O); the management of cropland and

grassland together resulted in net emissions of 64 million tonnes of CO2eq.

Overall, within the agricultural sector CH4 represents 55% and N2O 43% of GHG emissions.

The agricultural sector is responsible for 54% of total EU CH4 emissions (6% of the total EU

GHG emissions) and for 79% of total EU N2O emissions (4% of the total EU GHG emissions).

These data show that reduction efforts must focus as much on N2O as on CH4. Furthermore, the

role of agriculture in protecting carbon stocks and providing carbon sequestration should also be

enhanced.

5.1.1. CAP measures’ effectiveness in contributing to climate change mitigation

Results of the simulation on GHG emission reductions

Only some CAP measures are expected to have a direct quantifiable impact on GHG emissions

and only certain CAP measures had suitable uptake indicators available for the purpose of the

simulation. Therefore, only a selection of CAP measures could be included in the simulation.

Notable omissions include fallow land (EFA), for which the simulation cannot calculate a single

year’s impact on emissions, the permanent grassland ratio and most direct payments.

In the evaluation support study, three simulations were carried out, reflecting the impact of a

low, medium and high scenario in terms of emission factors, i.e. the potential of measures to

reduce emissions. In addition, for Pillar II, the simulation was based on 2016 uptake; however,

to take into account the fact that uptake is increasing over time, an additional 2020 simulation

was run, simulating an uptake at target level47.

At best, based on 2016 uptake, the reduction in emissions reaches 8.8% compared to the

simulated baseline without the CAP, with a medium scenario at 4.7% and a low at 0.3%. Pillar I

contributes most to this reduction, via greening and, more specifically, protection of

environmentally sensitive permanent grasslands (ESPG) and the ecological focus areas (EFA).

In the medium scenario, in the absence of these two measures, emissions from agriculture would

have been 3.5% higher (19.8 million tonnes CO2eq).

46

See footnote 15. 47

For example, the measures targeting GHG and ammonia emission reductions applied on 1.5% of agricultural

land in 2016 and 2.4% in 2018. The target is set at close to 3% for 2023.

23

Table 3: Simulated impact on EU-28 GHG emissions (simulated Pillar I CAP measures, compared

to the baseline of 1 000 t CO2eq/ year)

CAP measure Scenario Emitted as CO2 Emitted as N2O % reduction compared to the baseline (net CO2eq)

EFA (except fallow land)

Low 19 152 0.0%

Medium 20 4 005 0.7%

High 21 7 858 1.4%

ESPG

Low 1 466 0 0.3%

Medium 15 764 0 2.8%

High 30 061 0 5.3%

EFA + ESPG

Low 1 486 152 0.3%

Medium 15 784 4 005 3.5%

High 30 082 7 858 6.7%

Source: Evaluation support study

Table 4: Simulated impact on EU-28 GHG emissions (selected Pillar II CAP measures, medium

scenario, 2016 uptake, compared to the baseline of 1 000 t CO2eq/year)

CAP measure (ranked by percentage reduction)

CH4 CO2 N2O % reduction compared to the baseline (net CO2eq.)

Baseline 287 394 38 677 240 201

Natura 2000 (measure 12.1)

0 3 881 0 0.7%

Agri-environment-climate commitments (measure 10.1)

0.13 170 1 125 0.2%

Organic (measure 11) 0 0 874 0.2%

Forestry (measure 8) 0 367 0 0.1%

Investments (measure 4) 13 0 0 0.0%

Total Pillar II Low 6 812 432 0.2%

Total Pillar II Medium 13 4 418 1 999 1.1%

Total Pillar II High 20 8 024 3 566 2.1%

Source: Evaluation support study

The quantified results need to be treated with caution, because they may overestimate the

emission reduction from some of the measures analysed. This is particularly the case for the

environmentally sensitive permanent grassland (ESPG) measure, which assumes that all the

benefit of protecting ESPG can be attributed to the greening measure (while 96% of the ESPG is

in Natura 2000). It also uses an emission factor, established from literature, which relates to the

GHG removal benefits arising from restoring wetlands and peatlands. The literature makes clear

that such large removals are achievable in a limited range of circ*mstances, so that the

‘medium’ simulation result is very likely to be an overestimate. Where the Natura 2000

management plans already ban ploughing, the reductions in emissions cannot be attributed fully

to the greening measure; however, greening enhances implementation of the ploughing ban, all

the more in those Member States which translated the Habitat Directive into voluntary

commitments in Natura 2000 areas (e.g. France).

Pillar II measures for which the impact was quantifiable (i.e. investments in physical assets -

measure 4, investments in forest area development - measure 8, agri-environment-climate -

measure 10.1, organic farming - measure 11 and Natura 2000 payments – measure 12.1) have

helped to reduce GHG emissions by ~6.4 million tonnes CO2eq/year. This corresponds to 1.1%

of total emissions from agriculture based on the 2016 uptake of measures.

Most of the reduction is associated with carbon sequestration due to Natura 2000 payments.

Although the simulation result exaggerates the impact of this measure, which compensates

24

farmers for the cost of complying with restrictions which are already in place, it is reasonable to

associate some mitigation impact with the payment. In its absence, protection might have been

more difficult to put in place due to farmers’ opposition, and management plans might have

been less well complied with once they were in place. As the simulation could not account for

such factors, the whole impact on GHGs associated with Natura 2000 protection has been

attributed to Natura 2000 payments - measure 12.1. In addition, under the CAP, areas under

greening cannot be compensated with Natura 2000 payments for the same restriction48

;

however, the simulation modelled each measure separately, implying some double counting

with the modelling of the ESPG under greening.

Under the medium scenario, full uptake (at target level) of the measures that Member States

have programmed would yield reductions equivalent to 1.5% (compared to 1.1% based on 2016

uptake). The extent of success should be considered alongside wider sectoral aspects, notably:

Livestock production: CH4 emission reductions may be achieved by certain operations

under the agri-environment-climate measure (10.1) with respect to manure management

and feed, and investments in physical assets (measure 4) with respect to manure storage

and livestock housing.

Fertiliser use: N2O and CO2 emission reductions are only reported for agri-environment-

climate commitments (measure 10.1) with respect to management of inputs.

Preserving carbon sinks and enhancing carbon sequestration: CO2 reductions and

removals may arise from practices that are supported by CAP measures included in the

simulation but which are small in relation to wider reductions and removals in the

sector.

Figure 2: Simulated emissions impact of CAP measures by source, medium scenario (1 000 t

CO2eq/year), 2016 uptake, compared to baseline

Source: Evaluation support study

As shown in Figure 2, the mitigation impact is dominated by the effects of CAP measures on

change in soil carbon stocks (the balance of emissions mitigation and increased removal of

carbon from the atmosphere) and change in N2O emissions from soil and manure. It is estimated

that 15.8 million tonnes of the 19.8 million tonnes reduction in emissions of CO2eq in the

medium scenario for Pillar I measures come from changes in soil and biomass carbon stocks; the

48

Regulation (EU) No 1306/2013 requires Member States to deduct from the measure 12.1 payments any amount

associated with restrictions that a farmer is already required to comply with as a result of the greening measure.

25

corresponding figure for the simulated Pillar II measures is 4.4 million tonnes CO2eq out of a

total emission reduction of 6.4 million tonnes (2016 uptake).

N2O emissions from soil and manures across the EU-28 would have been 4 million tonnes

CO2eq per year greater without the relevant Pillar I measures (0.71% of baseline emissions) and

2 million tonnes CO2eq per year higher without the Pillar II measures (0.35%) per year (2016

uptake). The agri-environmental commitments accounted fully for this result.

Reductions in CH4 emissions - from enteric fermentation and manure management - do not

feature highly in the simulation results. Other work49 has shown that livestock mitigation

measures have low potential, due to the technical difficulty in reducing emissions in the

livestock sector. As highlighted in the Farm to Fork Strategy and in the Methane Strategy,

changes in consumption patterns towards more sustainable diets would also be an effective way

to decrease livestock emissions, while avoiding any reduction in herds leading to increased

GHG emissions outside the EU (leakage).

CO2 emissions associated with energy consumption are higher in some sectors (especially

horticultural farms and specialised dairy farms, poultry and pig meat farms), but the relevant

mitigation actions are site-specific and could not be simulated.

The effect of CAP measures on CO2 removals

CO2 is of great importance in the agricultural sector’s GHG balance, because of the very large

stock of carbon in soils. Soils in Europe are accumulating carbon: grassland and forest soils are,

on average, a carbon sink that is estimated to grow by 80 million tonnes every year50, and around

90% of this carbon sequestration takes place in forests. This amounts to approximately 0.1% of

all EU soil stocks (75 billion tonnes), so a small increase relative to existing stocks would have a

large effect on net GHG emissions from the agricultural sector.

Agricultural soils in Europe are a carbon sink, but they are losing carbon. Looking at

agricultural land across the EU, the combination of grassland and cropland had a net emission of

68 million tonnes CO2eq in 2018 according to GHG inventory reporting51. These emissions have

significantly decreased since 1990, when they were at around 90 million tonnes. However, it soil

carbon is currently the ‘blind spot’ in the land/climate nexus, as its monitoring needs significant

improvement and investment. Soils can be a net source or sink for atmospheric carbon,

depending on land use and management. Decreases in soil organic carbon through cultivation

can be mitigated by minimising soil disturbance and tillage, permanent soil organic cover, crop

rotation practices, or with special practices on cultivated peatlands (carbon-rich soils). Removal

of CO2 into soils, without changing land use, depends on the balance between carbon additions

(crop residues and organic matter additions) and carbon losses, mainly through organic matter

decomposition. The most effective means of removing CO2 is changing land use from annual

crop production to perennial grassland and/or woodland. In the simulation, the main mitigating

impact of the CAP is realised through CO2 removals. According to the simulation, CAP

measures result in removals between 3.6% (with Pillar II 2016 uptake) and 4% (at target level)

of net agricultural GHG emissions.

Soils rich in organic matter and, consequently, in carbon are better suited to withstanding the

impact of climate change because they are more resistant to erosion and retain water better,

especially during extreme events such as droughts.

49

Martineau et al (2016), Effective performance of tools for climate action policy - meta-review of Common

Agricultural Policy (CAP) mainstreaming.

50 Frelih-Larsen et al (2016), Updated inventory and assessment of soil protection policy instruments in EU

Member States.

51 EEA Data viewer https://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer

26

An important initiative on soil carbon is the ‘4 per 1 000’ initiative52, which aims to increase soil

organic matter and carbon sequestration through agricultural practices adapted to local

environmental, social and economic conditions, such as agro-ecology, agroforestry,

conservation agriculture and landscape management. The initiative commits stakeholders to a

transition towards productive and highly resilient agriculture, based on appropriate management

of lands and soils, creating jobs and income and consequently promoting sustainable

development. This project highlights the fact that the carbon stock in permanent grassland is

close to its maximum (hence, the importance of maintaining it), but that there is significant

potential to increase carbon stocks in arable land.

Emission mitigation impacts across Member States

There is no clear regional pattern to the pathways leading to net changes in GHG emissions;

however, there are differences between Member States depending on their geography, farming

systems and policy implementation choices. The majority of Member States’ CAP measures

have had a similar mitigating effect on climate change to that for the EU-28 as a whole. Member

States with little opportunity to establish or protect permanent grassland (e.g. Malta, Cyprus)

have the lowest potential to decrease emissions, while Member States with a large area of

permanent grassland (e.g. Spain, Italy, Romania, Czechia and Greece) have the highest potential

to have an impact on GHG emissions. Lower emissions are attributable to the large areas of land

designated as ESPG within certain Member States and the potentially high benefit resulting

from protecting these carbon stocks.

It can be concluded that mitigation will mainly be achieved by maintaining permanent grassland

and thus carbon stocks. The main contribution from arable systems comes through EFA

(nitrogen-fixing crops and, to a lesser extent, from catch and cover crops).

Measures whose impact could not be simulated

The permanent grassland ratio may potentially have significant effects on carbon emissions or

removals. Compared to the counterfactual scenario in which there are no CAP measures, the

ratio could theoretically prevent up to 95% of the 36.1 million hectares of permanent grassland

from being ploughed without reseeding as grassland.

However, its impact could not be simulated due to the significant uncertainty relating to the

management of permanent grassland, the soil types concerned and the age of the grassland.

Unlike ESPG, where ploughing is banned and designation (should) guarantee that soil carbon is

locked in and sequestration can continue, various types of management with very different

consequences for mitigation are possible in the case of land which is not ESPG and which is

only protected through the permanent grassland ratio53. The European Court of Justice in 201354

made clear that land classed as permanent grassland can be ploughed and re-seeded without it

losing its ‘permanent grassland’ status.

Alternative scenarios are presented in the evaluation support study on the impact of converting

soils to arable, ploughing them then reseeding as grassland, or not ploughing at all. These

scenarios show that, for each percentage point of declared permanent grassland that remains

52

This initiative is part of the Global Climate Action Plan (GCAA), adopted by the UNFCCC at COP 22 as a

follow-up to the COP 21 Lima-Paris Plan of Action, and contributes to the goal of reaching a land-degradation

neutral world.

53 Appropriate management of grassland may facilitate CO2 removal, such as: reducing nitrogen fertiliser inputs in

highly intensive grass covers; increasing the duration of grass covers; converting grass covers to grass-legume

mixtures or to permanent grasslands; and moderately intensifying nutrient-poor permanent grassland. However,

intensifying nutrient-poor grasslands on organic soils may lead to large carbon losses.

54 The Court judgment of 2 October 2014 in the case C-47/13 clarified the definition of permanent pasture.

‘Permanent grassland’ must be interpreted as agricultural land which has been, for 5 years or more, used to

grow grass and other herbaceous forage, even though that land has been ploughed up and seeded with another

variety of herbaceous forage other than the one previously grown on it during that period.

27

unploughed, there will be an estimated avoidance of net CO2 emissions from soil of between

0.7 and 1.8 million tonnes CO2eq (depending on soil type and climate), compared to a situation

where the soil would otherwise have been ploughed then reseeded. A greater avoidance of

emissions (1.2 to 4.5 million tonnes CO2eq) is achieved if grassland would otherwise be

converted to arable use.

The above-described model could not simulate the GHG impact of most direct payments either

(single payment scheme or single area payment scheme, the redistributive payment, the small

famers’ scheme and payments to areas facing natural constraints). However, the results of

another modelling study55 on the impact of direct payments on production using the CAPRI

model show that, overall, direct payments are helping to keep land in agricultural production.

While land abandonment occurs in practice, the modelled results suggest that more land would

have been abandoned if direct payments had not been in place, and thus production and

associated emissions would have been lower.

Maintaining extensively managed farmland, particularly semi‐ natural pastures, is key for

conserving biodiversity and preserving the cultural landscape. Therefore, direct payments

contribute to the provision of these public goods, but principally in marginal areas, since

relatively productive land would be farmed in any case (i.e. even without the CAP). The higher

agricultural output in marginal areas brought about by direct payments also causes higher levels

of GHG emissions. These higher GHG emissions for the EU are, to some extent, moderated by

lower emissions in the rest of the world. Nevertheless, the net effect of direct payments is

slightly higher global GHG emissions.

Determining the potential impact of the small farmers’ scheme in particular is further hindered

by the fact that agricultural holdings under this scheme are exempt from greening obligations

and from cross-compliance penalties. Therefore, the simulated reduction in emissions from the

greening measure could have been larger without this exemption. In addition, since the impact

of cross-compliance itself cannot be quantified, neither can the impact of not applying its

sanctions to certain farms. Thus, depending on the effectiveness of these obligations, there is a

risk of a missed opportunity to mitigate GHG emissions (this is also discussed in relation to the

evaluation criteria for ‘coherence’).

The evaluation support study concluded that the impact of measures supporting areas facing

natural constraints on livestock production, the most usual type of farming in these areas, is

difficult to establish. Since this payment is not coupled, the impact on production and thus GHG

emissions is unlikely to be significant. As direct payments, the measure is intended to enable

farming to continue in areas where it otherwise might not.

There is potential for reducing GHG emissions if the abandonment of previously farmed land is

followed by vegetation (herbaceous, shrub and wood) and forest. However, erosion effects with

subsequent loss of soil carbon are also possible, and these can take a number of forms. For

instance, in Scotland there have been instances where the replacement of sheep farming by

uncontrolled grazing by wild deer has increased erosion. Elsewhere, in regions where soil is

held in place on steeply sloping ground through terrace systems, the abandonment of such

systems may result in the loss of significant soil carbon.

For horizontal measures, the simulation could not quantify the impact of cross-compliance on

GHG emissions due to the difficulty in determining the specific areas of land to which the often

widely different rules set by Member States apply in practice. Member States have tended to set

rules based on existing good practices and not beyond. Ensuring the ‘status quo’ is nevertheless

important: by ensuring that there are no reversal trends, the carbon stock is protected.

Although no simulation could be made, it is understood that ‘soft measures’ to support climate

mitigation actions will indirectly contribute to GHG reductions by changing behaviour and

55

Brady et al (2017), Impacts of Direct Payments: lessons for CAP post-2020 from a quantitative analysis.

28

improving capacity. The most common CAP measures used to improve capacity and uptake are

the Farm Advisory System as a horizontal measure and the measures supporting knowledge

transfer (measure 1) and advisory services (measure 2) under Pillar II.

The CAP measure supporting knowledge sharing networks by establishing and running

operational groups of the EIP for agricultural productivity and sustainability (measure 16) has

led to a number of initiatives to support capacity for climate mitigation at farm level and helps

research results to be translated in practice on the ground. Additional soft measures are

identified in the literature review as having the potential to contribute to GHG reductions. These

measures include: the use of business plans to support energy efficiency on farms and in rural

businesses (via the farm and business development measure, measure 6); and support for

operations (including local renewable energy production, community energy efficiency,

localised food chains, sustainable mobility, etc.) under the community-led local development

strategies (LEADER, measure 19).

The impact of voluntary coupled support

VCS is intended to aid certain production activities which experience difficulties and which are

important for economic, social and/or environmental reasons. Its potential impact on GHG

emissions varies according to the type of production supported and any eligibility requirements.

Support to maintain ruminants contributes to keeping enteric emission levels, while helping to

maintain permanent grassland and thus carbon stock. Support for protein crops could reduce

emissions of N2O and increase sequestration compared to a counterfactual scenario in which

other crops were grown.

Academic and other literature does not present a clear picture of the impact of coupled support

on production or GHG emissions. Using the CAPRI model, Jansson et al56 show that removing

coupled support for ruminants would reduce beef production by 1% and total agricultural GHG

emissions in the EU by 0.5%. However, about three quarters of this reduction would be

cancelled out by emissions leakage (i.e. increased emissions outside the EU) due to an increase

in imports from countries with relatively higher emissions per unit of product (emission

intensities), like Brazil57. This emissions leakage would significantly limit the positive impact on

global warming that could come from removing coupled support in the EU.

A reduction in direct emissions from livestock might also be accompanied by changes in land

use whose impact is difficult to predict. Land previously used for grazing or for the production

of feed could be abandoned, set aside or brought into another form of production (e.g. grassland

could be converted into arable land or vice versa). If abandoned, the effect can be positive for

climate (e.g. afforestation, conversion to grassland) or negative (e.g. conversion to settlements

or increased soil erosion). The benefit of stopping livestock production therefore depends on

how land is managed.

With regard to production effects, in certain cases coupled payments support the continuation of

agricultural activity on carbon-rich soils, which is less GHG-intensive than alternative uses for

the land58. An extensively grazed pasture which is no longer supported by coupled support might

be ploughed and converted to arable production, releasing soil carbon and also emissions from

the use of fertilisers. However, the extent to which such changes can occur is constrained by

56

Jansson et al (2020), Coupled Agricultural Subsidies in the EU Undermine Climate Efforts.

57 In a no-coupled support scenario, beef production in the EU would decrease by 89 000 tonnes, while

consumption would decrease by only 50 000 tonnes despite higher prices. The market balance would be

maintained by a reduction in EU exports (-22 000 tonnes) and by increased imports to the EU (+17 000 tonnes).

58 In the EU-28, most suckler cows, ewes and she-goats are raised extensively. 68% of suckler cows, 41% of dairy

cows, 62% of sheep and 50% of goats are held on farms with a livestock density below 1.4 LSU/ha. These

numbers are calculated on the basis of the Eurostat Farm Structural Survey of 2013. In this respect, DG

Agriculture and Rural Development estimated that the share of VCS spending granted to extensive systems is

around 30%.

29

other policy instruments, notably by the permanent grassland ratio and the designation of

environmentally sensitive permanent grassland, in addition to the physical characteristics of the

land which may make it unsuitable for arable farming. Therefore, the evaluation support study

could not conclude that reduced emissions from a reduction in livestock numbers would

automatically be offset by increased emissions from ploughing.

A smaller proportion (10%) of Member States’ coupled support budget has been set aside for

protein crops, which can reduce GHG emissions. The EU protein crop area increased by close

to 60% between 2013 and 2019, to 2.16 million hectares59. Beside coupled support, market

factors, the eligibility of protein crops for EFA and the crop diversification measure also

contributed to this increase. The evaluation support study reports that reductions in direct GHG

emissions from improved nitrogen efficiency of between 0.033 and 0.159 tonnes/hectare/year

are achievable via nitrogen management measures, including the planting of protein crops.

The overall net impact of coupled support on GHG emissions within the EU is difficult to judge.

Additional enteric emissions and emissions from manure management associated with livestock

numbers that are higher than would be expected in a counterfactual scenario must be balanced

against the risk of emission leakage and any positive impacts from protecting sensitive soils,

while also depending on its use and management. The small positive impact of additional

protein crop production must also be taken into account. The scale of support for the livestock

sector qualitatively suggests that negative impacts (i.e. increase in GHG emissions) are likely to

outweigh positive impacts (i.e. climate change mitigation). However, model results also show

that, due to leakage (increase of emissions outside the EU), the net-negative impact of VCS

might be very small.

The assessment of the impact of voluntary coupled support, decoupled direct payments and

support for areas facing natural constraints highlights that the debate on livestock emissions

cannot be simply narrowed down to reducing livestock numbers to a more sustainable level, but

should also make a distinction between intensive and extensive livestock systems. This was

highlighted in the Commission’s report on the ‘Future of EU livestock’60: besides the risk of

emissions leakage, it is important to consider that ruminants in extensive livestock systems

maintain marginal land whose biomass is not mechanically harvestable (humid and dry

mountain areas, humid zones, etc.), with positive effects on biodiversity and landscape

management, such as on fire risk prevention, depending on site-specific conditions. In addition,

to produce meat and milk ruminants use cellulose, which is not digestible for human beings.

A holistic approach to livestock systems when assessing their impact is necessary, by also

looking at relation with impact of feed production and unsustainable consumption patterns.

5.1.2. CAP measures’ contribution to climate adaptation and climate

resilience of the agricultural sector and society

With close to 800 natural catastrophes worldwide in 201861, the number of extreme events

affecting agriculture is rising. Climate adaptation was an overarching objective of the five

European Structural and Investment Funds for 2014-2020, including the EAFRD, and a cross-

cutting objective of the CAP 2014-2020. However, there are no legally binding or concrete,

quantified objectives for adaptation, apart from the budget requirements. The requirement to

allocate 30% of EAFRD funds in each rural development programme to measures addressing

environment and climate objectives has not been an effective driver, since much of this

59

Short-term outlook for EU agricultural markets, Statistical Annex, https://ec.europa.eu/info/sites/info/files/food-

farming-fisheries/farming/documents/short-term-outlook-statistical-annex_en.pdf

60 Dr Jean-Louis Peyraud (INRAE) and Dr Michael MacLeod (SRUC), European Commission, Future of EU

livestock: how to contribute to a sustainable agricultural sector.

61 Meteorological events: tropical storm, extra-tropical storm, convective storm, local storm. Hydrological events:

flood, mass water movements. Climatological events: extreme temperature, drought, forest fire.

30

percentage was made up of measure 13 (support for areas facing natural constraints). This

measure has little relevance for environment and climate objectives, including adaptation.

Figure 3: Number of natural catastrophes worldwide

Source: Münchener Rückversicherungs-Gesellschaft, Geo Risks Research, NatCatService

Note: The graph refers to the natural catastrophes occurred in general and not only in agriculture.

Member States’ national strategies include plans to adapt the agricultural and forestry sectors.

The planning process for rural development programmes required Member States to integrate

adaptation into their policies. Unfortunately, however, there were no such requirements under

the Direct Payments and Horizontal Regulations. In Pillar II, very little reference is made in the

programmes to risk assessments and even less to adaptation strategies and plans. Despite

adaptation being considered as a relevant challenge in almost all rural development

programmes, only eight addressed climate adaptation explicitly. Nevertheless, although overall

the CAP measures were not primarily designed to address climate-related objectives and very

few CAP measures make explicit reference to climate adaptation, several measures had some

indirect effects on adaptation (see Table 1).

Tracking expenditure on adaptation is very difficult, as there is no focus area dedicated

specifically to adaptation. In addition, some measures which can address adaptation relate to

several focus areas (investments in physical assets, agri-environment-climate commitments,

organic farming). At EU level, EUR 7.8 billion have been allocated to support actions explicitly

dedicated to preventing or minimising the damage that climate change can cause, corresponding

to 5% of the total climate change allocation under the EAFRD. The main contributions are

detailed below.

Effects of the Horizontal Regulations on adaptation

Cross-compliance GAEC standards can have unintended positive effects on adaptation and can

also help to avoid cases of maladaptation, but the extent to which this happens depends on how

Member States choose to define the standards. Interviewees in the case study countries pointed

out that climate change adaptation had not been a significant driver of GAEC choices (Germany,

Spain, except for GAEC soil in 2018, and Romania). In most case study countries, GAEC

standards did not change significantly between the CAP 2007-2013 and the CAP 2014-2020,

showing no strong commitment to furthering climate change adaptation. Overall, Member States

have not directly tailored GAECs for adaptation purposes, so their potential is not fully used.

31

As regards the standards most likely to benefit adaptation, for GAEC 6 (maintenance of soil

organic matter62), most Member States (15) did not go beyond the EU minimum requirement,

a ban on stubble burning. Furthermore, compared to the CAP 2007-2013, the number of

Member States which defined additional requirements for the maintenance of soil organic

matter decreased. These requirements include: restrictions on entering land when it is

waterlogged or frozen; use of crop rotations; not growing successive crops with a high soil

carbon demand; application and/or monitoring of organic matter; soil testing; and stubble

management63. Part of these requirements, previously under GAEC 6, are reflected in the CAP

2014-2020 in the crop diversification obligation under greening.

GAEC 2, which concerns compliance with authorisation procedures for irrigation water, is

mostly defined by Member States as a requirement to hold a permit for irrigation and, in some

Member States, to have a water meter. The EU framework does not include any requirement to

link the quantity of water used to the quantitative state of the water resource in the area, which

would have been beneficial to avoid cases of poor adaptation.

With regard to the Farm Advisory System (FAS), the advisers interviewed also reported on the

high complexity in advising on adaptation given: 1) the uncertainty of climate change impacts;

2) the fact that knowledge of adaptation issues is still developing; and 3) the fact that the

vulnerability of a given farming system is very dependent on its context and location. Although

climate change has been included in the scope of the FAS from 2014, it is difficult to assess

accurately to what extent climate change has been included in advice to farmers. Case study

interviews hint that the situation varies across Member States and that the integration of climate-

related actions has been low. There is thus room to improve how adaptation is incorporated into

the FAS.

Effects of the first pillar’s measures on adaptation

Crop diversification is likely to have positive effects on adaptation by agricultural holdings and

on territorial adaptation. Increased crop diversity and crop rotation promoted by the measure

improve farms’ resilience to climatic events such as droughts and to economic shocks from

price volatility. Crop rotation also helps to improve soil quality and resilience to pests, while

diversifying into less water-demanding crops may lower dependence on water resources in

traditionally irrigated areas.

In 2016, 23% of farms in the EU had three crops or more. The crop diversification measure

required changes of crop on less than 1% of EU arable land, but it encouraged farmers to

maintain diversification. In 2016, 27% of EU farms had one crop only, and mono-cropping

remains a dominant practice in a number of countries and regions in the EU (Italy, Romania,

Spain, Poland, north-western Germany and south-western France). Nevertheless, the impact of

crop diversification under greening was higher locally in areas with high levels of mono-

cropping (e.g. 2.8% of the agricultural area had to be diversified in Spain). According to the

evaluation support study on greening, most farmers that had to diversify mainly planted

leguminous plants instead of cereals, and they mainly did it in rotation; both practices were

identified as being positive for adaptation by favouring resilience to pests and droughts and

improving soil structure.

The permanent grassland ratio can improve adaptation, since permanent grass cover limits

soil erosion and improves resilience to floods. It helps to maintain a level of diversity in farming

systems, which has been identified as crucial for adaptation.

62

There is a growing consensus that soil quality (and especially soil organic carbon) is key for both mitigation and

adaptation.

63 Hart et al (2017), Research for AGRI Committee, The consequences of climate change for EU agriculture.

Follow-up to the COP21 - UN Paris Climate Change Conference.

32

In EFA, planting of catch/cover crops, adopted by many farmers to comply with the obligation,

favours adaptation by improving soil organic carbon content and maintaining soil moisture,

which is good for resilience to droughts, while also limiting the risk of soil erosion. The

maintenance of (non-bare) fallow land and landscape elements is also beneficial for resilience to

floods and protection from soil erosion.

Direct payments can potentially facilitate investments necessary to adapt to new climate

conditions, and hence facilitate a transition towards more resilient systems. They can also lower

farmers’ economic sensitivity to shocks that may be directly or indirectly due to climate

changes, such as climatic events or price volatility, by improving income stability. A fairer

distribution of direct payments through the voluntary redistributive payment could favour

adaptation by supporting farm diversity through support for smaller farms. However, the

measure was implemented only in 10 Member States, which limited the potential benefits. VCS

favours systems that are experiencing difficulties, which might relate to the resilience of a

region (e.g. an important employer in a region already marked by high structural

unemployment), and in doing so it promotes farm diversity64 more broadly. As Scenar 203065

shows, a ‘no CAP’ scenario would lead to more specialised systems, implemented on a smaller

agricultural area, located in the most favourable places, thus reducing diversity.

Direct payments can also have unintended negative effects on adaptation. They may support

the maintenance of vulnerable farms, slowing some structural changes that could be necessary

for adaptation in some cases or supporting risk-prone behaviour. Such cases have been reported

during the case study interviews in Spain, where interviewees pointed out that the basic payment

scheme was still strongly linked to historical payments; for example, farmers working on

irrigated systems located in arid zones continue receiving higher levels of CAP payments.

However, these systems are going to be increasingly vulnerable to the effects of climate change

and they may lead to higher vulnerability of the whole territory through their use of ground

water from aquifers that are already quite depleted.

Also in Spain, coupled support is available for rice and tomatoes, even though these irrigated

crops require high levels of water consumption and are grown in areas facing water scarcity

issues. However, rice is typically produced on areas near to the sea, where the salinity of the soil

is so high that rice production often has no alternative. This highlights trade-offs between the

different pillars of sustainability, in this case environmental versus social sustainability. All

cases are very context-dependent and cannot be generalised, while the screening for

maladaptations means considering socio-economic indicators in conjunction with natural

resource indicators.

Effects of the second pillar’s measures on adaptation

Almost all rural development measures have intended or unintended effects on adaptation.

However, assessing the effects of measures is rather difficult, as they not only support practices

that are beneficial for adaptation but usually also encompass other actions or types of operation

that are not relevant for adaptation. In addition, information on budget allocation and uptake are

not available for different types of operation, so the adaptive effects are probably over-estimates

in most cases.

Soft measures

Training (measure 1) and advisory services (measure 2): even though climate change

adaptation is often mentioned as an objective of these measures, most supported actions focused

primarily on economic or other environmental subjects. Furthermore, the effects of the measures

64

Examples include coupled support for nuts in rain-fed areas in Spain, avoiding abandonment of terraces that

limit erosion in mountainous areas and, in the Netherlands, support for very extensive grazing in natural areas

which do not meet the criteria for the basic payment scheme.

65 M’barek et al (2017), Scenar 2030 - Pathways for the European agriculture and food sector beyond 2020.

33

have been hindered by a low level of programming and delays in implementation, which is

problematic given the fact that, in several Member States or regions, there is no funding

allocated to training activities beyond rural development support (e.g. in Romania).

Cooperation (measure 16) can promote adaptation to climate change thanks to support for the

development and diffusion of innovative practices, better planning of resource management and

support for diversification of agricultural holdings’ activities; the measure has been programmed

by most managing authorities. An example of using this measure for adaptation is the funding of

operational groups, comprised of farmers and other stakeholders, created in the Agro-ecology

project in France. They promote collective experimentation and knowledge exchange,

facilitating a transition toward more sustainable practices.

Measure 19 (LEADER): a review of LEADER projects supported in the previous

programming period (2007-2013) across the EU-28 showed that, overall, climate-relevant

projects mostly focused on capacity building and energy efficiency, with a limited focus on

more explicit adaptation activities66.

Investment measures

Measure 4 (investments in physical assets) has strong potential to support climate change

adaptation, since investment in equipment and infrastructure can enable vulnerable farms and

forest holdings to adapt to climate change through, for instance:

improved resource efficiency for agricultural holdings (water efficiency, reduced soil

tillage);

storage facilities to increase water resource availability in agricultural holdings (including

rain water collection);

modernisation of livestock production units (recycling water or improving ventilation of

buildings).

Non-productive investments linked to the achievement of agri-environment-climate objectives

are also very relevant for climate change adaptation. Support is available, for instance, for the

planting of hedges and trees against erosion, or the restoration of wetlands or peatland.

Interviewees in Spain (Andalusia) pointed out that the modernisation of irrigation systems

improves the capacity of farmers to cope with droughts. However, it may also lead in some

cases, in the long run, to poor adaptation in areas where the water resource is already depleted

(as a result of increasing water demand with increases in irrigated areas, rather than changes in

cropping patterns in these regions). Moreover, water savings that could be achieved by more

efficient irrigation systems can be over-compensated by increasing the irrigated area or by

switching to more water-intensive crops.

Another example of potentially poor adaptation concerns support for high-cost investments

(heavy machinery), which can lead to a high level of specialisation by farms (to achieve

economies of scale) and can lock farmers into specific systems that are more challenging to

adapt to climate change. In addition, farmers who are financially weakened by heavy

investments are also more economically vulnerable to climate shocks.

Measure 8 (forest management and investment) can also support a wide range of actions that

are beneficial for adaptation of forests, and covers similar potential climate benefits to those of

measure 4 (investment) and measure 5 (risk prevention). Through afforestation, it can: provide

sustainable use of former agricultural land that would become marginal because of the effect of

climate change; support agroforestry, which has multiple climate change adaptation benefits;

improve forest resilience through improved risk mitigation (pest control, fire prevention,

restoration); and improve the resilience of forests to climate change (introduction of adapted

species, mixed stands, etc.). However, in few cases afforestation is done with fire-prone species

66

Frelih-Larsen et al (2014), Mainstreaming climate change into rural development policy post-2013.

34

such as eucalyptus, thus increasing the risk of fires and the potential damage caused by these

fires.

In most case study countries where the measure is implemented (seven out of eight), the

measure is likely to have had some positive effect on farmers’ adaptive capacity. For instance, in

Aquitaine (France) and in Andalusia (Spain) sub-measure 8.3 (promoting fire protection) has

been widely used to build infrastructure to mitigate fire risk; however, it is used much less to

promote preventive actions (planting of resilient species, etc.).

Measure 7 (basic services and village renewal) has no intended effects on adaptation, but it

may support various actions, such as the maintenance of pastoral activities (in Aquitaine), which

are considered resilient to climate change.

Risk management measures

Only a very low share of the EAFRD budget (0.8%) has been attributed to measure 5 - disaster

risk reduction, which aims to support agricultural holdings’ resilience to climate change. This

measure supports preventive actions, e.g. investments in drainage systems in northern regions

where more rain is expected in the coming years, the establishment of flood plains, or the

planting of trees against erosion, as well as restoration after damage to improve the resilience of

farming systems to climate change. According to the case study analysis, measure 5 has

probably helped to reduce the vulnerability of some farmers, foresters and/or territories in

Saxony-Anhalt and Croatia, where some adaptation-relevant projects have been funded.

Measure 17 supports risk management and thus improves economic resilience to shocks linked

to the impact of climate change. However, this type of support may also have adverse effects on

adaptation, by promoting risk-prone behaviour by farmers who feel protected. At least one risk

management tool is available in the rural development programmes of Italy, France, Romania,

Portugal, Hungary, Croatia, the Netherlands, Lithuania, Latvia and Malta, and of two regions:

Castilla y León (Spain) and Flanders (Belgium). However, although CAP support for

agricultural risk management has increased compared to the previous programming period, its

share in the overall CAP budget remains very low (around 2% of Pillar II). The low level of

programming for measure 17 is largely due to the fact that some Member States finance risk

management using national funds (insurance in Spain) and that managing authorities tend to

avoid measures that may lead to under-use of resources.

Part of measure 6 (support for farm and business development) supports the diversification of

activities on agricultural holdings. However, this sub-measure has been opened by only a

minority of managing authorities and represents a limited share of total public expenditure at EU

level. Therefore, the measure is unlikely to have significantly enhanced the diversification of

activities across the EU. However, the measure also includes support for young farmers (sub-

measure 6.1); up to 2018, 109 000 young farmers set up in business with CAP support. Case

study interviews and the literature review have shown that young farmers are more likely to

adopt new practices and technologies, taking into account sustainability issues such as

adaptation to climate change and, more generally, sustainable management of resources.

Land management measures

The agri-environment-climate measure (AECM – measure 10) has diverse potential effects

on adaptation. A number of interventions under this measure help to improve the resilience of

farms and society more generally by establishing areas of semi-natural vegetation and landscape

elements, and by promoting practices that improve soil health and water retention in soils, limit

soil erosion, improve resilience to floods, etc. For instance, cover crops, crop rotation, improved

management of landscape features, zero tillage and increased use of forage crops are some

practices that can be promoted by this measure and which can, in certain circ*mstances, be

beneficial for adaptation. Furthermore, the measure may also improve resilience thanks to the

conservation, use and development of varieties more resilient to droughts.

35

In most case study countries and regions, most commitments have been designed to address

environmental objectives related to biodiversity, landscape and natural resources, particularly

soil and water, but in all these Member States at least one scheme promotes adaptive practices.

Assessing the effects of the measure on climate change adaptation is challenging, as most

Member States have offered a wide range of measures pursuing several objectives, among

which climate change adaptation is just one. To be more effective for adaptation, measures

should tackle specifically the main climate challenges, which are most often location-specific.

Organic farming (measure 11) has the potential to build resilient food systems, mainly through

crop diversification and improved soil quality. 8.0% of EU agricultural area is farmed

organically and close to 65% of this area is covered by EU organic support.

Natura 2000 and Water Framework Directive payments (measure 12) can contribute to

territorial adaptation through the protection of biodiversity and wetlands, as highlighted in case

studies in Germany (Saxony-Anhalt), Czechia, France (Aquitaine), Ireland and Lithuania.

Areas facing natural or specific constraints (ANC – measure 13) supports the maintenance

of farms in remote areas, thus limiting land abandonment and preventing higher fire risk.

Importantly, it maintains a diversity of products, farming systems and habitats (including

grassland) that is deemed important for adaptation at a higher level (by regions and EU society).

However, in most case study countries, interviewees pointed out that the measure is seldom

tailored to ensure that it supports systems resilient to climate change or adaptive activities.

In conclusion, several CAP measures have the potential to contribute to climate adaptation,

mostly by maintaining or enhancing the diversity of crops and farming systems, protecting

against soil erosion and floods, protecting against shocks and supporting necessary investments

to adapt to new climate conditions. In addition, some GAECs can address climate adaptation,

but generally Member States have not tailored GAECs sufficiently for this purpose, so their

potential is not fully used. Case study interviews indicate that advising farmers on how to

improve climate performance has been a low priority. In addition, some measures might have

some unintended negative effects for adaptation depending on specific conditions, slowing some

structural changes that could be necessary for adaptation. Obviously, the biggest contributions

come from measures specifically designed to contribute to adaptation.

5.1.3. The contribution of technological and social innovation to achieving the

CAP’s goals on climate change

Innovation is identified as a key element of the Europe 2020 strategy to manage the multiple

climate change challenges facing the agricultural and forest sectors. In the agricultural sector,

both technological and social innovations have strong potential to contribute to the CAP’s

climate action goals by helping to limit GHG emissions and adapt to climate change in the

livestock and crop sectors.

Based on the literature and interviews in case study countries, the evaluation support study

compiled a non-exhaustive list of social and technological innovations, with potential effects on

climate objectives. Technological innovations can be divided into different categories, such as:

- genetic improvement: e.g. increasing crops’ resistance to heat/drought; better adapting

crops’ agro phenology (e.g. early variety selection); increasing crops’ resistance to pests;

increasing feed efficiency; improving animals’ resistance to heat and disease; gender-

selected (i.e. sexed) sem*n;

- biological innovations: e.g. on-farm anaerobic digesters (i.e. methanisation), which

implies the digestion of organic material (e.g. manure, slurries and crop residues) by

bacteria in sealed tanks to yield biogas and digestate; feed additives to reduce methane

emissions (e.g. linseed, nitrate, or propionate precursors); low nitrogen feed to reduce

ammonia emissions; nitrification inhibitors in soil (suppressing the microbial conversion

36

of NH4 to N2O); bio-control agents for plant protection (e.g. with auxiliary insects or

bacteria);

- mechanical innovations: optimised irrigation equipment (e.g. drip irrigation, micro-

sprinklers); optimised soil management equipment (e.g. direct seeding or shallow tillage

equipment);

- knowledge based-innovations: assisting fertilisation with digital technologies (e.g. with

GIS or field sensors); assisting irrigation with digital technologies (e.g. field sensors to

map irrigation needs); information systems providing timely information to steer farm

management mobile applications to recognise in-field diseases;

- climate-controlled environment: climate-controlled buildings for livestock, climate-

controlled greenhouses.

Social innovations can vary, since they rely on stakeholders who decide to organise themselves

to answer local needs. They can be related to:

- sharing knowledge: e.g. collaborative online tools, groups of farmers and stakeholders

meeting in workshops or field visits, financing through crowdfunding and sponsorship;

- sharing resources on water management, sharing equipment;

- financing and insurance: through crowdfunding and sponsorship, mutual funds, forward

contracts, insurance products;

- land conservation and management;

- breeding: organisation, conserving, selling seeds of ancient or local varieties;

- labelling: climate labels, participatory guarantee systems;

- organisation of food production systems: local food systems.

Climate objectives are rarely the sole or main objective pursued by stakeholders through these

social innovations. However, many of them can significantly impact climate objectives directly

(e.g. water management groups) or indirectly (e.g. organisations for conserving, exchanging or

selling seeds of ancient and local varieties).

Data on the proportion of farmers using innovations at EU level is scarce. Therefore, a survey of

farmers’ advisers and representatives was carried out for the evaluation support study, gathering

the results on adoption rates for the 10 case study countries. The results show that adoption of

innovations is, on average, higher for technological innovations (24%) than for social

innovations (11%), while the cost-effectiveness of mitigation technologies is strongly related to

the regional specificities of the farming sector. For technological innovations, the use of

genetically improved seeds or animals is quite common at EU level, as is the use of sexed sem*n

and climate-controlled greenhouses and livestock buildings. For example, EU average milk

yield has increased by 67% since 1990, allowing for a production increase of 5%, while the

number of dairy cows has decreased by close to 40%, contributing significantly to the GHG

emission reductions in Europe since 1990.

In this context, it is important to mention that, as highlighted by Peyraud et al67, designing

climate-friendly, innovative livestock systems (to e.g. reduce emissions per unit of output)

cannot be pursued at the expense of other dimensions, such as animal welfare and reducing the

risk of developing antibiotic resistance.

Social innovations are less frequently implemented by farmers, except for those participating in

water management groups (and, to a lesser extent, in other stakeholder and farmer groups) and

in local farming systems. The adoption rate also differs greatly between Member States: some,

such as the Netherlands, Germany and France, seem to rely extensively on both technological

and social innovations, as confirmed by the survey results; others, such as Lithuania, Ireland,

Croatia and Hungary, rely less on innovations.

67

European Commission, Peyraud and MacLeod (2020), Future of EU livestock: how to contribute to a

sustainable agricultural sector.

37

Figure 4: Innovation adoption rate per technological (red) and social (green) innovation (%)*

Note: * For innovation related to livestock (and crop) production, the figure shows the percentage of livestock (and crop)

producers who were judged to have adopted the innovations.

Source: Evaluation support study

Figure 5: Development of dairy herds and milk cow yields in the EU-28 since 1990

Source: DG Agriculture and Rural Development, based on Eurostat

‘Fostering innovation’ is a cross-cutting objective of the CAP. In the EAFRD, innovation is also

specifically targeted as both a cross-cutting priority and as the first of the six priorities

(‘Knowledge transfer and innovation’), so many measures can influence the emergence and

adoption of innovations.

According to case study interviews, the mainstreaming of climate change actions in measures 1

and 2 increased but remained generally low in the current CAP, so the impact of these measures

on climate-related innovations might be limited. For measure 4, only some Member States

specifically target innovations that can have positive effects on climate objectives. For instance,

GPS technology for tractors and for spraying machinery are supported in Ireland, irrigation

modernisation is supported in France and innovations are specifically targeted by a type of

operation in the Netherlands called ‘a guarantee for the introduction onto the market of risky

innovations’.

Under the EAFRD, 98 out of 112 rural development programmes (in 27 Member States) provide

support for more than 3 200 EIP operational groups. Although these groups can work on a wide

10

20

30

40

50

60

gen_milk_yield

gen_feed_efficiency

gen_drought_crop

sexed_sem*n

gen_disease_livestock

clim_greenhouses

biocontrol

gen_heat_crop

farmer_group_water

clim_building_livestock

gen_pest_crop

gen_phenology_crop

local_farming

information_system

irrig_opti_equipment

irrigation_digital

fertilisation_digital

stakeholders_group

farm

er_group_equip…

gen_heat_livestock

insurance

feed_additive

mobile_app_diseases

nitrification_inhibitor

farmer_group

stakeholders_group_…

online_forum

low_N_feed

seed_conservation

land_stewardship

land_conservation

participatory_breeding

urban_farming

mutual_fund

participatory_guarantee

digester

climate_label

crowdfunding

Mean

2.000

3.000

4.000

5.000

6.000

7.000

8.000

10

15

20

25

30

35

40

kg/c

ow

mil

lio

n h

ead

s

Number of dairy cows Milk yield

38

range of topics, climate objectives are included within the EIP-AGRI objectives and the work of

the operational groups should be in line with these objectives.

Several other EU policies and initiatives are promoting innovations in the agriculture and forest

sectors that can have an impact on climate change objectives (e.g. Horizon 2020, the European

Institute of Innovation and Technology (EIT), the LIFE programme, and policies supported by

European Structural and Investment Funds other than the EAFRD).

For example, LIFE BEEF CARBON is a voluntary European initiative that aims to reduce GHG

emissions per unit of beef (carbon footprint) by 15% over a 10-year period on 2 172 farms in

four large beef-producing countries. The outcome shows that mitigation practices are not all

costly to adopt. There are different solutions that can reduce the carbon footprint of a farm, such

as optimising the arrival (births) and departure of animals (slaughterhouse), to reduce the

presence of unproductive animals on the farm. Reviewing the cropping system can be another

solution; for example, feeding the cattle from the meadows and the fodder produced on the farm

reduces emissions linked to feed production and transportation. In addition, using animal

manure avoids the purchase of fertilisers.

Technological and social innovations in the agricultural sector have strong potential to

contribute to the CAP’s climate action goals, but their overall impact depends also on

pedoclimatic conditions, farming systems, location and the way in which the innovative

solutions are implemented. In addition, the uptake of mitigation practices and technologies

depends on their costs and the potential level of incentives. The CAP, or a system of carbon

pricing68, can provide the relevant incentives. According to the JRC’s ‘Economic assessment of

GHG mitigation policy options for EU agriculture’69, mitigation practices and technologies in

the EU have the potential to bring about a decrease in agricultural emissions of between 15 and

35 million tonnes of CO2eq (for a carbon price between EUR 20 and 100 per tonne of CO2eq

respectively), a reduction of up to 9% compared to business as usual. The effect on LULUCF

emissions would represent an additional reduction of 37 to 45 million tonnes of CO2eq.

5.2. Efficiency

The evaluation assesses the efficiency of the CAP’s contribution to achieving the climate action

objectives, particularly the targeting, administrative costs and management related to

implementing the CAP 2014-2020 measures.

This efficiency assessment could only be done to a limited extent. One of the key

methodological difficulties is the absence of quantified information about many of the benefits

of the measures under consideration, due to which it has not been possible to quantify the full

impact of tracked CAP climate spending. Even the quantified results available with regard to

mitigation are subject to significant caveats regarding their accuracy. For adaptation, it has not

been possible to quantify any benefits due to the site-specific and uncertain nature of the

benefits associated with reducing vulnerability to risk. In addition, the analysis of administrative

burdens and costs was impeded by the fact that Member States do not usually record the

administrative costs and burdens associated with individual measures.

68

Carbon pricing is an instrument that captures the external costs of GHG emissions - the costs of emissions that

the public pays for - and ties them to their sources through a price, usually in the form of a price on CO2

emitted. A price on carbon helps shift the burden for the damage from GHG emissions back to those who are

responsible for it and who can avoid it. A carbon price provides an economic signal to emitters, and allows them

to decide to either transform their activities and lower their emissions, or continue emitting and paying for their

emissions (World Bank, https://carbonpricingdashboard.worldbank.org/what-carbon-pricing).

69 European Commission, Perez Dominguez et al (2020), Economic assessment of GHG mitigation policy options

for EU agriculture: A closer look at mitigation options and regional mitigation costs - EcAMPA 3.

39

5.2.1. Efficiency of first pillar measures

The evaluation support study analysed budget allocations for climate action across the CAP. For

that, the EU’s climate tracking methodology was used to track climate spending in the EAGF

and EAFRD. The calculation for Pillar I is based on allocating one of three possible climate

markers70

(0%, 40% and 100%) to each item of expenditure; it does not distinguish between

adaptation and mitigation actions. According to the tracking methodology, the shares of direct

payments contributing to climate change through greening measures are 0%, 4% and 10% for

crop diversification, for EFA and for the permanent pastures measures respectively, for a total of

14% (i.e. EUR 6.1 billion per year). A further EUR 2.5 billion is attributable to direct payments

other than greening.

For mitigation, the evaluation estimated that the environmentally sensitive permanent grassland

measure (ESPG) measure had led to an annual reduction of 15.8 million tonnes of CO2eq (see

Chapter 5.1 on effectiveness); no quantified result could be modelled for the permanent

grassland ratio. If all the climate spending associated with the permanent grassland measure

were to be attributed to ESPG, the simulated reductions in emissions achieved by the ESPG

measure would be obtained at a cost of around EUR 220/t CO2eq. However, ESPG represented

only 16% of permanent grassland subject to greening, with the remaining 84% subject only to

the ratio. Therefore, the evaluation assumed that the mitigation benefits of the ESPG measure

are obtained at a cost of EUR 0.7 billion or EUR 44/t CO2eq.

For the EFA measure, EUR 1.75 billion of attributed spending is associated with mitigation

benefits of 4 million tonnes, at a cost of EUR 437/tonne CO2eq. It is also worth remembering

that climate action is not the primary objective of the EFA measure.

The analysis suggests that, overall, using the tracking methodology and the simulation,

EUR 6.1 billion of expenditure on the greening payment in 2016 secured a simulated

19.8 million tonnes of CO2eq at a cost per tonne of close to EUR 280. This figure is a rough

estimate, to be taken with caution in view of the limits in the modelling exercise explained in

Chapter 5.1.1 and the simplistic approach of the tracking.

According to the evaluation on greening71, compliance costs for farmers were assessed as being

negligible for all except highly specialised arable farmers, for whom the crop diversification

measure entailed costs. On the other hand, according to this evaluation, administrative costs for

farmers are quite high, especially for the EFA measure. In contrast, according to the Ecorys

study on the administrative costs of the CAP72, farmers perceived compliance with the greening

provisions (permanent grassland, EFA) as a higher source of costs than the administrative

burden related to submitting aid applications. The study indicated that most farmers did not

perceive a substantial increase in their administrative burden due to new rules and requirements

(e.g. greening) introduced by the 2013 CAP reform, although the measurement and declaration

of EFAs was mentioned as a main administrative task.

For the other first pillar non-greening payments, the tracking methodology attributes 20% of

those direct payments to climate and assigns it a marker of 40%. On this basis, a further

EUR 2.48 billion is considered to be spent yearly on climate. As for cross-compliance, only

GAEC 4, 5 and 6 are identified as directly addressing soil and carbon stock, while other GAEC

70

Since 1998, the Development Assistance Committee (DAC) of the Organisation for Economic Cooperation and

Development (OECD) has set up the Rio markers system. This system consists of policy markers to monitor and

statistically report on the development of finance flows targeting the themes of the Rio Conventions, namely

biodiversity, desertification, climate change mitigation (i.e. reductions in or absorption of greenhouse gas

emissions) and climate change adaptation (including climate risk mitigation and vulnerability reduction).

71 https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/cmef#evaluation

72 https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/cmef/regulation-and-

simplification/analysis-administrative-burden-arising-common-agricultural-policy_en

40

standards and statutory mandatory requirements may indirectly also address mitigation.

However, an overall assessment of the cost-benefit of GAECs and statutory mandatory

requirements and, more generally, of the non-greening direct payments in respect of climate

benefits is not possible due to the lack of reliable quantitative evidence for both benefits and

costs.

5.2.2. Efficiency of second pillar (rural development) measures toward climate

action

Ten out of the 19 rural development focus areas are considered to be climate-relevant. For Pillar

II, the tracking methodology73 is different to the minimum of 30% spending on measures

addressing climate and environmental objectives, which is required by Article 59(6) of the Rural

Development Regulation. The tracking methodology allocated coefficients according to how

strongly associated with climate each focus area is considered to be. A coefficient was thus

associated with each focus area (100% in eight cases, 40% in two), which has to be multiplied

by the corresponding budget to calculate the budget dedicated to climate. However, it is

important to note that many rural development measures addressing climate-relevant focus areas

have rather broader environmental objectives, and not specific climate objectives (e.g. organic

farming, Natura 2000 compensation).

A focus area is considered to be beneficial for mitigation when it covers emission limitation,

energy saving, improved soil management, enhanced fertilisation and carbon management. A

focus area is identified as positive for adaptation when it covers risk management, improved soil

management and water management. Based on these criteria, some focus areas have been

identified as beneficial for both adaptation and mitigation objectives and other focus areas for

only one of these objectives. For priority 4 (restoring, preserving and enhancing ecosystems),

expenditure has not been disaggregated between the focus areas. As both focus areas 4B and 4C

are positive for both adaptation and mitigation, all priority 4 spending has been treated as

positive.

The results show that the budgets dedicated to mitigation and adaptation are similar,

EUR 16.5 billion and EUR 16.9 billion respectively in 2015-2016, but they overlap to a

considerable extent. The analysis carried out (see Chapter 5.1 on effectiveness) simulated a

reduction attributable to Pillar II of 6.4 million tonnes CO2eq based on the uptake of measures in

2016. It should be noted that some of the Pillar II measures for which mitigation effects could

not be quantified account for a large part of the tracked climate budget (especially measure 11 –

organic farming). As a result, the calculation for the efficiency of rural development measures

might be an underestimate. The evaluation suggests that, if the unquantifiable benefits are not

included, simulated reductions achieved by rural development measures are achieved at a cost of

EUR 194/tonne.

The vast majority of the budget, EUR 70.7 billion, is programmed under priority 4 (45.8% of

Pillar II). This is mainly because the large budgets dedicated to the AECM, organic farming and

support for ANC have been mostly dedicated to priority 4. However, as described in chapters 2

and 5.1, neither organic farming (measure 11) nor the support for ANC (measure 13) are

measures with a climate-related intervention logic. Indeed, no emission reductions resulting

from measure 13 could be simulated, and for measure 11 only some reductions in emissions

could be simulated. Nevertheless, it is important to note that organic farming contributes to

emission reductions through the limited use of chemicals, the production of which also leads to

emissions. It also contributes to agricultural holdings’ adaptation towards more resilience.

For priority 5, which has climate as its principal objective, only EUR 11.9 billion (7.7% of Pillar

II) has been dedicated to it, and in six rural development programmes priority 5 is not

73

The methodology for climate tracking for the EAFRD is set out in annex II of Commission Implementing

Regulation (EU) No 215/2014 of 7 March 2014.

41

programmed at all74. This is also illustrated by the French case study, which found that some

managing authorities have allocated the greatest budget to a single priority (usually priority 4) to

reduce administrative complexity. According to case study interviews, the Netherlands chose to

address agricultural emissions through its national policies and therefore no measures were

programmed under priority 5. The evaluation support study also revealed that certain Member

States (e.g. Hungary, Romania, Bulgaria, Portugal and Spain) did plan to spend more than the

average on mitigation, while others (Scandinavian Member States, Poland, Austria and Czechia)

planned to spend less. Therefore, the targeting of budgets toward priority 5 is quite low and

varies between Member States.

5.2.3. Efficiency gains

The scope for efficiency gains in respect of the CAP measures addressing climate action is

examined through case study interviews and literature review. They consider how the budget

might have been spent so as to achieve better results for adaptation and mitigation.

Economic (via risk management tools) and agronomic (via e.g. diversification) adaptation

usually benefits private interests more than the public good, and mitigation schemes may have

private co-benefits. The evaluation found that Member States have made little use of measures

such as loans and well-designed risk management tools to leverage private finance and

internalise risk.

The analysis also pointed out the importance of targeted approaches through many cases

where better targeting of support would lead to an increase in efficiency. For example,

protecting carbon-rich soils such as peatland is particularly beneficial to climate mitigation,

compared to protecting other soils. Targeting has been little used in the 2014-2020 CAP, due

either to the way measures are designed or to the choices made by Member States. However,

there are a few examples where targeting has led to an improvement in efficiency. For instance,

under cross-compliance, Germany and Czechia have rules under GAEC 5 (minimum land

management reflecting site-specific conditions to limit erosion) which restrict the crops that can

be grown and how the soil may be cultivated in areas judged to be at risk of erosion by water.

Targeting in this way improves the ratio of benefits to costs.

For the EAFRD, eligibility and selection criteria allow managing authorities to focus on

particular localities, social structures and farm types. However, the targeting is rarely used to

focus on climate action. Interviews in several Member States and regions (Andalucía in Spain,

Czechia, Ireland, Lithuania and Saxony-Anhalt in Germany) pointed out that the targeting of

mitigation hotspots or vulnerable and/or resilient areas in their rural development programmes is

limited and could be significantly improved. An example which illustrates this lack of targeting

is the rural development programme in Saxony-Anhalt, which does not address the protection of

peatland even though the region has a considerable amount of peatland and protecting/restoring

peatland is one of the most carbon-efficient measures available.

As previously described, some measures that do not have explicit climate objectives are

nonetheless relevant for climate. To achieve better results, it is thus important to demonstrate the

climate benefits which can be achieved through the use of such measures. A recent study for the

European Commission calls for a detailed assessment of the climate results and relevance of

measures to improve the targeting and monitoring of climate actions75. A clearer and more

transparent intervention logic for climate could help managing authorities to achieve that.

The evaluation also highlighted the role of screening for maladaptation that could avoid public

expenditure on infrastructure, or on sectors that may increase vulnerability in the medium to

74

In Finland-Aland, France-Lorraine, France-Mayotte, Germany-Hesse, Slovenia and the Netherlands.

75 Forster et al (2017), Climate mainstreaming in the EU budget: preparing for the next MFF.

42

long term, such as irrigation infrastructure in areas with depleted water resources. It could also

avoid promoting excessive specialisation by whole geographical areas, thus improving

efficiency. The rural development programmes examined in the case study countries contained

no evidence that such screening practices are applied.

5.2.4. Administrative burden and simplification

The annual administrative costs for national administrations for both pillars are estimated at

around 3.5% of the budget, which is rather cost-effective76. For beneficiaries, costs related to

rural development measures were estimated in 2011 at 4.7% of total public expenditure

(including national co-financing).

The evaluation could not quantify the administrative burden of individual measures addressing

climate action other than the Pillar I greening measure. The evaluation support study on

greening estimated that, for most Member States, the one-off implementation costs of the

greening measure are between 0.24 EUR and 0.69 EUR per hectare, with running costs of

between 0.12 EUR and 0.60 EUR. They arose mainly from on-farm controls and the obligation

to map landscape features into the Land Parcel Information System (LPIS).

Costs to farmers are estimated between EUR 86 million and EUR 217 million a year (i.e.

roughly between 0.7% and 1.8% of the total public administration costs). The estimated

additional annual administration costs associated with the greening measure account for 3.0 to

8.5% of the total public administration costs associated with the management of direct

payments. The administrative burden of the greening measures is especially associated with

their management and control, although there has been some simplification since 2015.

Although the analysis could not quantify the administrative burden of rural development

measures, some complexities related to the new framework for strategic planning of rural

development programming and implementation were reported during case study interviews and

also in the literature. These include: the difficulty of implementing the requirements for clear

identification of needs, targeting of support and attribution of spending to focus areas and

objectives, due to shortages of suitably trained staff; the obligation to enhance coordination

between the different European Structural and Investment Funds; and the complexity of some

measures (e.g. measures 1 and 2).

Case study interviewees also expressed concern about the additional level of administrative

control and monitoring. The complexities involved have led some Member States to include

fewer measures in their rural development programmes than in previous programming periods

and to fund some actions through national funds instead, to focus measures on a few focus areas

to simplify monitoring, or to avoid tailoring measures to local needs.

5.3. Coherence of CAP measures

The evaluation assesses whether the CAP measures and instruments within the CAP 2014-2020

deliver a coherent contribution to the specific objectives of climate action. It analyses whether

they are consistent and complement each other, or whether there are conflicting objectives

and/or incentives within the CAP (internal coherence) and/or with respect to other EU or

national policies (external coherence) that may compromise the effectiveness and/or efficiency

of the relevant measures under evaluation.

5.3.1. Internal coherence of the CAP in addressing climate action

The evaluation assesses the internal coherence among CAP 2014-2020 measures contributing to

the general objective of climate action. The way CAP measures may be used together is usually

76

DG Agriculture and Rural Development Annual Activity Report (2019).

43

coherent, but does not produce synergies with respect to climate action; apart from a few

exceptions, the combination of CAP measures does not strengthen the impact that the measures

have individually on climate action nor does it worsen it.

In most case study countries, good examples of coherence were identified between the GAEC

requirements, greening and some AECMs in relation to climate action and through the use of

soft measures. These measures together have strong potential to protect and enhance soil carbon

in agricultural soils. Several CAP measures that promote cultivation of leguminous crops can

work in synergy to promote carbon stock increase in soils, including: coupled support for

protein crops; the greening EFA measure (27 Member States have allowed leguminous crops as

EFAs); and the AECM (e.g. in Spain, France, Poland and Germany, but only in some regions).

Also, legumes can give some farmers the option to diversify their cropping pattern under the

greening crop diversification measure. Overall, the association of several measures targeting

cultivation of leguminous crops gives farmers a greater incentive to grow these crops.

Similarly, the implementation (and/or retention) of landscape features, catch and cover crops,

buffer strips and agroforestry were also highlighted as beneficial to carbon stocks and are

promoted under various measures, mostly the greening EFA measure, GAECs, AECMs, forestry

under measure 8 (for the creation of new agroforestry areas) and investment under measure 4

(e.g. when it supports the creation of landscape features). However, their contribution to the

increase of carbon stocks depends on national/regional implementation choices. In particular,

the AECM can be used to complement both cross-compliance and EFA measures.

The permanent grassland measure prevents the reduction of permanent grassland via

ploughing (through the ban of ploughing on ESPG), and thus benefits carbon stocks. In addition,

there are several CAP measures with which the permanent grassland measure (both the ratio and

ESPG) can interact and may provide synergies to protect carbon stocks. For example, the

AECM and the Natura 2000 payment may act in synergy with the ESPG measure, improving

grassland management for better carbon sequestration. According to results from the evaluation

support study, three Member States have offered payments under AECM for the conversion of

arable land to permanent grassland (Germany, Czechia and the UK-England). However, these

measures can also be designed to serve other objectives (particularly biodiversity) and therefore

the potential synergies depend on whether the main objective was to favour carbon sequestration

when designing the measures at national/regional level.

Soft measures can facilitate the implementation of actions which are beneficial for carbon

stocks and are promoted under other CAP measures, e.g. cultivation of legumes, grassland

management, agroforestry, etc.

There are some exceptions where the analysis shows theoretically synergistic or conflicting

relationships between CAP measures, depending on Member States’ implementation choices or

on certain circ*mstances. This is referred to as ‘relationships having mixed impacts’.

The analysis also identified some instances of theoretical incoherence. For example, the CAP

allows Member States a considerable degree of flexibility in implementing CAP measures.

However, the multitude of general and specific CAP objectives and national, regional and local

needs might lead to an inherent degree of incoherence among measures addressing climate

change.

Some Member States have designed eligibility criteria for permanent grassland in a restrictive

way, even where this meets the criteria set out in the Direct Payments Regulation. Doing so

means that the carbon stock in the excluded areas cannot benefit from the protection afforded by

cross-compliance and support through greening. Excluding areas from these protections is

incoherent with climate objectives, although it may serve wider policy objectives important to

the Member State concerned, such as focusing income support where it is most needed.

The exemption of beneficiaries of the small farmers scheme from greening goes against

mitigation. Small farmers account for a large group of beneficiaries and, although the area

44

covered by small farms only accounts for 6.4 million hectares (7% of the total), their exemption

represents a sizeable missed opportunity for climate action.

Voluntary coupled support for livestock gives rise to a number of likely negative

relationships. One common example of incoherence is the choice by most Member States to

significantly support ruminants, due to the benefits associated with coupled support such as

economic and social benefits even though almost half of the agricultural emissions arising

within the EU come from enteric fermentation (mainly ruminants) and the management of

manures of all livestock77.

In addition, in a few countries, there are positive examples of targeted location of support and

the way the support for livestock is implemented, for example:

In Andalucía, the livestock systems receiving coupled support are mainly extensive (in

contrast to the rest of Spain) and located in ANC with steep slopes which are often prone

to water scarcity. This means that the impact of coupled support could be relatively

positive for climate in this specific case, by helping to maintain grassland systems on

steep parcels which may otherwise suffer from soil erosion following abandonment and

for which alternative uses may increase water consumption.

In France, the negative effects of coupled support for livestock on climate could be

limited by the fact that the support decreases with the number of animals.

Coupled support for livestock can have a positive impact on climate, if it supports extensive

livestock farming which would otherwise be replaced by arable farming (to the extent that the

greening permanent grassland ratio obligation and other constraints permit it). This appears to

be happening in, for example, parts of France (Aquitaine) and Spain (Andalucía)78. Nevertheless,

this support is both widely available and often unconstrained by eligibility rules (such as

stocking densities79), which could limit its impact on production and emissions.

Beyond livestock, coupled support in other sectors was found to be potentially incoherent in

relation to climate adaptation. For example, coupled support is also provided to support the fruit

and vegetable, cotton and rice sectors in Andalucía, whose production drives the

overexploitation of water resources in the region but also brings significant social benefits in

terms of employment.

The availability of direct payments to farmers may act as a barrier to afforestation/creation of

woodland, supported under measure 8.1 (forest investment). Similarly, inconsistencies were

found in some case study countries where direct payments are granted to agricultural activities

taking place on peatland/wetland (e.g. the Netherlands and Lithuania) with no conditions to

prevent them from being damaged (which results in high levels of GHG emissions). In Hungary,

agricultural land for which direct payments are granted often has to be drained to be cultivated,

which increases an already high probability of flood risks and flood damage when they occur.

Cases of both coherence and incoherence were found among payments for ANC (measure

13). Although it is not a climate action measure, it has potentially positive climate effects by

maintaining grassland systems (in Aquitaine, Andalucía and Croatia). Most beneficiaries in

Andalucía are located in steep or mountainous regions, which means that this support is

relatively positive in terms of climate action. This is because it is likely to help maintain

agricultural activity that is extensive (this is specific to Andalucía and unlike other regions of

77

https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/cmef/farmers-and-

farming/future-eu-livestock-how-contribute-sustainable-agricultural-sector_en

78 Even in these positive cases, from a strict climate mitigation point of view, the net impact would depend on

whether the benefits of maintaining grassland systems (carbon stocks, avoided N2O emissions) outweigh the

emissions from the livestock themselves.

79 The scheme as it is currently designed does not allow for restricting support to certain types of farming where

the sector in general is undergoing difficulties.

45

Spain), prevent soil erosion and limit fire risks (while providing important biodiversity and

culturally beneficial outcomes).

One example of potential incoherence is the way this measure is implemented in Hungary, as it

helps to retain agricultural production on lower quality land. In some regions, this is likely to

require more inputs to generate the same quantity of output, leading to higher emissions in

relative terms (i.e. per unit of output, because yields are lower for the same amount of input).

Member States have generally chosen to allocate substantial shares of the rural development

budget to measure 13. Although not all Member States have programmed the measure, and there

is a high variation as to its overall share of the budget, in total nearly 17% of the EAFRD budget

is allocated to this measure. The fact that these significant budget amounts count towards the

30% spending requirement for climate action seems incoherent, given that it is not a climate

measure per se and has both positive and negative impacts on climate action objectives.

These examples show that the CAP as a whole could do better in preventing inappropriate land

management with respect to climate action. There appears to be a lack of climate safeguards,

which would be evident if climate considerations were more systematically taken into account in

the implementation decisions.

In conclusion, some incoherence between the CAP measures was identified. This limits the

coherence of their overall contribution towards the CAP’s climate objectives, although CAP

measures generally are not intended to respond to climate objectives. While they can interact in

a way that incidentally has a positive impact on climate action, this interaction is generally not

designed or implemented in a way that seeks to steer their contribution towards more climate

action. There is therefore ample scope to improve the CAP’s internal coherence.

Details on the combined effect of measures (i.e. whether they are expected to be neutral, to

reinforce or to undermine the theoretical impact they are expected to have on climate action) can

be found in Annex 4.

5.3.2. Coherence of the CAP in addressing climate action with other CAP objectives

and broader EU and national policy objectives

Coherence of the CAP climate measures with the other general objectives of the CAP

The evaluation concluded that, overall, the CAP climate measures are considered to be coherent

with the broader aims of the CAP’s three general objectives for the 2014-2020 period, namely

sustainable management of resources, viable food production and balanced territorial

development. The implementation choices are important to avoid conflicts and to secure

synergies between CAP climate measures and wider CAP objectives. In some case studies, key

measures that were flagged as being potentially highly synergistic (e.g. advisory services), are

not always made use of within rural development programmes (in Saxony-Anhalt and Czechia),

and there is a wider question of how to maximise the opportunities offered by these potential

synergies.

As noted in a number of case studies, including the Netherlands, Lithuania and Romania, the

lack of incoherence is passive. It does not necessarily signify active promotion of coherence and

a drive to maximise synergies between climate mitigation and adaptation and wider goals.

Coherence with other EU policies

The CAP climate-focused measures are broadly coherent with other EU policies related to

climate change (see details in Annex 4). However, there are instances where further

opportunities for integration exist, particularly with the EU soil thematic strategy and the Floods

Directive. Therefore, although CAP climate-focused measures and other relevant EU policies do

not conflict in principle, some of the rules in place do not safeguard against conflicts happening

in practice when the measures are implemented.

46

Coherence with relevant national policies

The analysis of the case studies has identified multiple approaches to national climate delivery,

within national climate mitigation and adaptation policies, to the requirements placed on the

agricultural sector and to the use of the CAP measures. The CAP and, particularly, the rural

development programmes are noted in all case studies as being an important policy through

which to deliver climate goals at national and regional level.

However, interviews in the case study countries revealed that choices on implementing the CAP

at national level often do not aim to proactively pursue synergies in relation to climate action

and delivery. The Lithuanian case study shows that, although CAP rules do not impede proper

climate action, interviewees felt that the government took a passive role in this and that they did

not seek to actively promote coherence or to maximise synergies. In contrast, France does have

in place a mechanism for reviewing its regions’ rural development programmes and ensuring

that climate goals are taken into account.

In some case studies, interviewees questioned whether the current implementation of CAP

support was coherent with the overarching goal of climate mitigation in the long term. For

example, analysis of Irish and Dutch policies noted that, while use of CAP measures is not

incoherent with climate goals, the approach to the use of CAP measures does not complement

the areas of greatest need. Ireland has yet to define how CAP measures can be used to protect

peatlands; as noted by agricultural experts, although Ireland’s objective is to move towards

carbon neutrality in agriculture, it still has to plan what this will actually entail and the means to

deliver it. In the Netherlands, CAP funding focuses on renewable energy, biodiversity and

manure management without addressing the broader challenges associated with the sector’s

climate footprint.

A number of case studies (i.e. Czechia, Germany, Romania and France) noted that key policies

were not integrated into Pillar I and Pillar II implementation during the 2014-2020 period due to

key climate policies still being under development. Overall, in the case study countries, climate

issues are increasingly seen as important within the agricultural sector and climate goals are

expected to be of increasing importance post-2020 (such as in Germany, where the 2050

national climate protection plan explicitly highlights the future role of the CAP).

5.4. Relevance to needs

Relevance is the extent to which the objectives of an intervention are pertinent to current needs,

problems and issues. The evaluation assesses the relevance of the general CAP objective of

climate action and the relevance of CAP measures targeting this objective in relation to the

actual needs at EU, national and farm level.

5.4.1. Relevance of the CAP objective of climate action to the needs at EU, national

and farm level

Climate-related needs at EU level are expressed in a range of legislative and other commitments

on GHG emission reductions set out in the EU’s climate and energy framework to 202080. The

evaluation found that both the CAP’s general objective of climate action and the more specific

sub-priorities set out in the Rural Development Regulation are broadly framed; as a result, each

corresponds to a range of needs expressed at EU, national and, in most cases, farm level. The

CAP’s objectives of climate mitigation and adaptation are clearly relevant to EU-level needs,

represented by the Kyoto commitment and adaptation strategy respectively, while its sub-

priorities are relevant to a range of EU needs.

80

For further details, see Chapter 2.

47

Relevance to Member States’ needs

Agriculture is a significant source of GHG emissions in all 10 of the case study countries, so the

CAP’s objective of reducing emissions is relevant to all of them. However, only four of them set

a target for the sector81 (Czechia, Germany and France for agriculture as a whole, and the

Netherlands for intensive horticulture under glass). In Croatia and Hungary, there are no

national policies that require agriculture, forestry or other rural sectors to reduce emissions,

while Lithuania and Romania also have no quantified target. Ireland has an aspiration to achieve

carbon neutrality (taking both agricultural emissions and LULUCF into account) by 2050.

Member States report more detailed climate needs in their rural development programmes. The

CAP sub-priorities relevant to the highest number of needs identified in the case study countries

are improved water management (a need explicitly identified in all case study programmes) and

more efficient water use (all but Lithuania), followed by preventing soil erosion or improving

soil management (all except Czechia and Lithuania). In contrast, few Member States explicitly

identified needs to protect and sequester more carbon in agriculture or forests. The Netherlands

identified no need relating to forestry, while Croatia and Hungary highlighted the need to

increase forest areas and Saxony-Anhalt to preserve them (both of which have the potential to

improve carbon conservation and sequestration even if not explicitly done for that purpose).

Relevance to farmers’ needs

Evidence of needs at farm level is shown by the results of the public consultation on the future

of the CAP carried out for the Commission in 2017, during which farmers identified protecting

biodiversity (20%), more sustainable use of pesticides and fertilisers (19%), reducing soil

degradation (17%), preserving genetic diversity (15%) and rationalising the use of water (13%)

as the most important environmental challenges facing agriculture. Only 5% of farmers selected

reducing environmental risks such as fire and floods. 58% of farmers felt that the CAP

addressed these challenges only to some extent, or not at all.

According to the participating farmers, the most important objectives the CAP should pursue in

order to tackle climate change are ‘providing sustainable renewable energy sources’ (20%),

followed by ‘improving climate change adaptation and enhancing the resilience of agricultural

systems’ (16%) and ‘fostering carbon conservation and sequestration in agriculture and forestry’

(15%). A high proportion of farmers felt that afforestation (19%) and improved forest resilience

(18%) should be objectives of the CAP.

The small-scale survey carried out for this evaluation revealed that individual farmers and

foresters do not have explicit mitigation needs. For farms and forests, the sub-priorities of

carbon sequestration (per se), increasing the share of renewable energy and GHG mitigation are

not necessarily shared by farmers themselves, given that they may not always yield private

benefits; unlike failure to adapt, failure to mitigate does not by itself compromise the short-term

viability of an individual farm or forest enterprise. Despite this, the survey showed that those

farmers and foresters who were aware of which actions would reduce emissions were likely to

consider those actions to be relevant to their own farm. The CAP’s climate objectives are

therefore relevant to the needs of farmers and foresters in this context.

5.4.2. Relevance of CAP measures in contributing to climate action and the related

specific objectives

The climate-specific objectives are: pursuing climate change mitigation and adaptation; energy

efficiency; and shifting to a carbon neutral and climate-resilient economy. Certain CAP

interventions that are relevant or partially relevant to the EU’s climate needs are mainly

voluntary for Member States. However, key measures such as cross-compliance, the greening

81

Agriculture is grouped with other sectors under the Effort Sharing Regulation, for which sectoral targets are not

required. Instead, there is an overall target for all sectors.

48

measures, the FAS and the AECM are compulsory for Member States. Cross-compliance and

greening are also compulsory for farmers.

In contrast, the relevance of other CAP measures is constrained by the fact that they are

voluntary for farmers. While voluntary measures give Member States and farmers the flexibility

to target the needs in their territories with the appropriate interventions, there is no requirement

for farmers to take up those measures in areas where the highest needs have been identified.

This is compounded by the farmers’ perceived needs not always corresponding with the climate

needs identified by the managing authority, i.e. farmers often focus on adaptation challenges

rather than mitigation.

This situation is illustrated in the table below.

Table 5: Relevance of CAP measures to EU climate objectives and needs

EU-level objective

Emission reduction

Increasing

removals

Replacing

emissions

Climate

adaptation

Reducing

GHG

emissions

Energy

efficiency

Voluntary redistributive

payment N N N N N

Greening (crop

diversification) P N N N P

Greening (PG ratio) N N R N N

Greening (ESPG) N N R N N

Greening (EFA) P N P N P

Voluntary payment ANC N N P N N

Voluntary coupled

support P N N N N

Small farmers scheme N N N N N

Cross-compliance P N P N P

Farm advisory system P N P N R

M1: Knowledge and

information P P P P P

M2: Advisory services R R R R R

M4: Physical assets R R P R R

M5: Disaster risk

reduction N N P N R

M6: Farm business and

development P P N P P

M7: Basic services P P P R P

M8: Forest investments R R R R R

M10: Agri-env-climate R R R N R

M11: Organic farming P N P N P

M12: N2000 and WFD N N P N P

M13: ANC N N N N P

M15: Forest-env-climate R N R N R

M16: Cooperation P P P P P

M17: Risk management N N P N R

M19: LEADER P P P P P Score Meaning

N Not relevant (N)

P Partially relevant (P)

R Relevant (R) Note: There is a distinction between the column for reducing GHG emissions – which is the process by which emissions from

agricultural practices are reduced as a result of implementing the measure – compared to the column for the increase in removals

49

and maintenance of stocks. This is the process by which emissions do not increase as a result of the measure being implemented,

or where the measure leads to more emissions being removed from the atmosphere.

Source: Evaluation support study

Despite the fact that the two largest sources of GHG emissions from agriculture in the EU are

non-CO2 emissions (N2O and CH4) from livestock and from managed agricultural soils, CAP

measures relevant to reducing these emissions from livestock are all optional, with the

exception of ‘statutory mandatory requirement (SMR)’ 1 (improving compliance with the

Nitrates Directive) in cross-compliance. Optional measures through which Member States may

choose to address livestock management can take the form of advice and training, investment

support for better collection and management of manure, encouragement of lower or more

appropriate stocking density (agri-environment-climate) or the development of innovative

approaches (cooperation). Member States are only required to make available the agri-

environment-climate measures but are not required to offer options relevant to non-CO2

emissions82; nor are they required to put in place other measures that may help to reduce

livestock-related emissions. Furthermore, there are no greening requirements (the only other

compulsory environmental measures) that address livestock-related non-CO2 emissions. The

CAP measures do not specifically address a significant proportion of the EU’s climate

mitigation needs.

Reduction of emissions from managed agricultural soils is better addressed than livestock

emissions by the measures available in the CAP. The compulsory greening requirements relating

to permanent grassland (and ESPG) address conversion and ploughing risks. The framework for

cross-compliance GAECs (4, 5 and 6) aims to prevent erosion and maintain organic matter,

which can help to reduce soil-related emissions. However, Member States set almost all of the

detailed GAEC rules (GAEC 6, under which the Regulation requires a ban on stubble burning,

being the exception) and so determine which of these emissions are addressed in practice.

As described in Chapter 5.1 on effectiveness, the way these criteria are defined can lead to

significant areas being excluded from the requirements, thereby reducing the relevance of the

soil-related GAECs to the EU’s climate needs. The ‘statutory mandatory requirement (SMR)’

which reinforces compliance with the Nitrates Directive is relevant to emissions from arable

land in addition to livestock. There are also a number of rural development measures (forest

investments, organic farming, Natura 2000 and Water Framework Directive payments, payment

for forest-environmental and climate commitments, cooperation) able to address soil-related

emissions. However, their voluntary nature for Member States and beneficiaries can limit the

relevance of some of these measures in practice when their implementation by Member States is

limited. Even the compulsory AECMs’ relevance can be limited, given that Member States can

choose whether to focus on soil-related emissions, but the principle that AECMs address the

needs identified in the rural development programme should limit this risk.

The EU’s objective of minimum spending on climate and environmental objectives83 is

necessary to focus public money towards addressing climate needs. However, as the EAFRD

Regulation does not require addressing climate actions in particular, the 30% ring-fencing

covers both environmental and climate objectives. Moreover, support for ANC represents more

than half of what is required by ring-fencing.

As the measure itself simply provides financial compensation for the additional costs arising

from the fact that farmers operate in mountain areas or areas with other biophysical constraints

(environmental and climate conditions), the support farmers receive does not have to be spent

adapting to climate change or mitigating emissions. For this reason, support for ANC can be

considered at best only partially relevant to the objective of climate action. Thus, only part of

82

As set out in Council Regulation No. 1303/2015 (Article 32).

83 20% of the overall EU budget is to be spent on climate-relevant actions, which is given partial effect by the

requirement that at least 30% of the rural development programme budget must be spent on measures

addressing climate and environmental objectives (see Chapter 2).

50

the allocation to the environment- and climate-relevant measures contributes directly to climate

objectives. While climate and environmental objectives are highly interrelated, articulating

clearly the requirement for climate-relevant expenditure could help to improve implementation

and uptake of CAP measures so that they focus more on climate action needs.

Against the EU’s climate action needs, more measures appear relevant or partially relevant to

adaptation than to mitigation, although these are pursued rather for environmental management

purposes and much more rarely through dedicated adaptation measures (see Chapter 5.1.2).

Despite the great diversity in needs and in approaches to addressing those needs in the EU, the

following general conclusions on CAP measures’ relevance to climate action can be drawn:

Measures relevant for mitigation are not always communicated or articulated as

having mitigation benefits. However, this does not detract from their relevance in

addressing climate mitigation needs.

Mitigating emissions from livestock requires a broader combination of approaches and

activities than that which is available through current CAP measures. Given that

livestock production has the highest contribution to GHG emissions from agriculture,

designing specific CAP measures to directly reduce these emissions could help.

Overall, the evaluation revealed that the actual relevance of CAP measures in addressing the

EU’s climate needs might be influenced by the non-compulsory nature of some of the relevant

measures. However, there are measures that are compulsory for farmers (cross-compliance,

including the ‘statutory mandatory requirement (SMR)’ which reinforces compliance with the

Nitrates Directive and greening) and which are relevant for carbon sequestration (particularly

through the preservation of permanent grassland) and reducing nitrogen fertiliser use.

5.5. EU added value

EU added value is considered to be the value resulting from applying policy measures at EU

level, which is additional to the value that would have resulted from public authorities applying

similar measures at regional or national level. It is widely understood to be a multi-faceted

concept with different meanings and an economic and social or political dimension.

The economic dimension focuses on EU public goods and the efficiency of their delivery

through a collective EU approach, the attainment of economies of scale, and addressing positive

and negative external factors. The political or social dimension includes legal certainty

(objectives and priorities set out under EU policies), better coordination and complementarities

between actions84

.

When assessing the added value of climate action under the CAP, it was not possible to consider

a simple counterfactual scenario in which the identical measure is taken by Member States

acting without the EU. Therefore, the evaluation assumed a hypothetical counterfactual scenario

in which there are no EU-funded direct payments and no EU co-financed rural development

measures. It would also leave Member States free to determine the contribution their agricultural

and forest sectors would make to meeting EU climate and energy targets, and the size of any

financial incentives.

The evidence of Member States’ implementation choices within the revised GAEC framework

and greening requirements does not suggest any strong mitigation ambition on the part of most

Member States to use these measures to improve protection of water resources and soils

generally, or the carbon stores in soils and woody vegetation. Most of their choices have

prioritised farmers’ economic interests over those of the environment, although the prevalence

of nitrogen-fixing crops in EFA implementation has both adaptation and mitigation benefits.

84

Commission staff working paper on ‘The added value of the EU budget’, accompanying the 29 June 2011

Commission Communication on ‘A budget for Europe 2020’, SEC (2011)867.

51

Therefore, GAEC and greening may have raised climate ambition in certain situations,

compared to the counterfactual scenario (where there may be no environmental conditions

attached to direct payments). However, more generally they have had a passive effect in

preventing further deterioration of soil carbon and quality, and removal of woody landscape

features.

The lack of focus among rural development measures on reducing emissions from ruminant

livestock and manure handling/storage also suggests a lack of ambition on the part of Member

States to address methane emissions.

Based on case studies, the introduction in 2013 of specific EAFRD priorities to address climate

actions has provided EU added value by: stimulating a higher level of climate ambition in those

Member States which had not yet developed climate action plans for agriculture and forestry

(Czechia); refocusing debates on the CAP to encompass climate action (Germany-Saxony and

Croatia); or by incentivising governments to do more (Spain, Romania and Ireland), or even

offering more support for adaptation (Saxony). This effect on raising ambition is not EU-wide –

the Netherlands had already chosen to develop and implement climate policies largely without

using CAP funds, and in Lithuania there has so far been limited impact on an agricultural sector

that is focused on other priorities.

EAFRD environmental land management measures (principally agri-environment-climate

commitments) and also some forest measures had the most significant impact on GHG reduction

(mostly CO2, but also other GHG emissions), thus increasing the effectiveness of climate action.

Capital investments contributed little to GHG reduction (and suffered from low uptake),

suggesting that they have not raised Member States’ ambitions.

The evaluation found it more difficult to judge what effect the CAP has had on adaptation

ambitions in the agricultural sector. The process of preparing strategic plans for the European

Structural and Investment Funds and the ex-ante evaluation for the rural development

programme has probably stimulated a number of managing authorities to analyse their climate

risks and adaptation needs as part of their policy planning and programming earlier than they

would have done in the absence of the CAP. This may also have raised the use of the CAP to

support adaptive actions. However, the analysis of Member States’ adaptation plans has shown

that they have seldom budgeted for, and even less often funded, the actions proposed in their

plans. This highlights the potential role of the CAP (and other sectoral policies) to support

adaptation, for example through support for preventive actions.

Overall, the rural development measures seem more efficient in terms of targeted climate action

than direct payments, but there is still scope for improved efficiency in the rural development

programme and, cumulatively, at EU level. The CAP has provided a significant degree of legal

certainty, but only for the duration of each programming period. EU funding rules have also

provided opportunities for synergies between the EAFRD and other funds.

The evaluation suggests, however, that some Member States acting alone could have possibly

devised more efficient and effective means of achieving emission reduction targets. For

example, the more ambitious Member States might: target support at areas or production

systems where the greatest mitigation or adaptation benefits can be achieved; make any income

support payments conditional upon more demanding, targeted requirements for soil

management, particularly for carbon-rich (peaty) and wetland soils and to combat soil erosion

and improve soil functionality; limit investment in projects that meet threshold criteria for GHG

reduction and medium-term adaptation benefits; and support investments in water efficiency in

agriculture only if these implement an adaptation plan for all uses of the resource concerned. On

the other hand, there would be other Member States where, in the absence of the CAP,

particularly the EAFRD, ambition would be low and climate action would be less of a priority.

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6. CONCLUSIONS

Agriculture is both impacted by and has an impact on the climate, and EU agriculture has huge

challenges ahead to address climate change. In addressing those, progress made by the European

agricultural sector in terms of reducing emissions must not be overlooked, especially regarding

carbon sequestration, as it provides valuable lessons both from its successes and its limitations.

Effectiveness for climate mitigation

EU GHG emissions from agriculture have fallen by more than 20% since 1990, exceeding the

target set for 2020. However, emissions have stagnated since 2010, mainly due to agricultural

output increasing by 9%. This highlights gains in economic efficiency and environmental

footprint per unit of output produced, but similar gains in total emissions are needed.

The assessment of effectiveness has been limited by the available data on the implementation of

the measures at the time the support study was carried out, which covered the period 2015-2017.

The lack of information on detailed farming practices, including whether permanent grassland

has been kept unploughed, has also been a key limitation, particularly with regard to the

importance of maintaining the carbon stocks in agricultural soils, especially those of permanent

grassland.

To assess the impact of the CAP measures on GHG emission reductions, a modelling exercise

was carried out in the support study. Only a selection of CAP measures could be included in the

simulation. Notable omissions include fallow land (EFA), for which the simulation cannot

calculate a single year’s impact on emissions, the permanent grassland ratio and most direct

payments. Three simulations were carried out, reflecting the impact of a low, medium and high

scenario in terms of the measures’ potential for emission reduction.

At best, the reduction in emissions is 8.7% compared to a 2016 baseline without CAP, with a

medium scenario at 4.6% and a low at 0.3%. Pillar I contributes most to this reduction, via

greening and, more specifically, protection of environmentally sensitive permanent grassland

and EFA. In the medium scenario, in the absence of these two measures, emissions from

agriculture would have been 3.5% (19.8 million tonnes CO2eq) higher. On the one hand, this

simulation overestimates the mitigation effect of these Pillar I measures: where Natura 2000

management plans already ban the ploughing of permanent grassland, emission reductions

cannot be fully attributed to the greening measure, although it improves implementation of the

ploughing ban. On the other hand, not all measures’ impact could be quantified, such as the

impact of the greening permanent grassland ratio, whose effect on carbon storage depends

heavily on whether such grasslands are ploughed, even if not to convert them into arable land.

Direct payments, including coupled support for extensive livestock systems, prevent land

abandonment and help to maintain permanent grasslands. Where land is abandoned, the

mitigation impact depends on the alternative use of this land: the impact is negative if the land is

ploughed, kept bare-fallow or constructed (soil sealing), but positive if the land is afforested or

left for spontaneous revegetation. Removing the coupled support would reduce EU beef

production and thus GHG emissions. However, in the absence of a significant change in

consumption patterns, higher imports would cancel out about three‐ quarters of this reduction

through emission leakage (i.e. increased emissions outside the EU).

The overall net impact of coupled support on GHG emissions within the EU is thus difficult to

judge. Additional emissions associated with livestock numbers must be balanced against

emission leakage and any positive impacts from protecting permanent grassland and sensitive

soils. The positive impact of additional protein crop production must also be taken into account.

For Pillar II, the measures for which impact was quantifiable (i.e. investments in physical

assets, investments in forest area development, agri-environment-climate measures, organic

farming and Natura 2000 payments) have helped to marginally reduce GHG emissions, by 1.1%

of total emissions from agriculture, in the medium scenario. Most of this reduction is attributed

53

to Natura 2000 payments. In the absence of this compensation payment, protection of Natura

2000 areas which do not fall under greening would be jeopardised.

The support for areas facing natural or other specific constraints helps to prevent land

abandonment and loss of grassland. This protects carbon stocks in soil, but the positive impact

on climate mitigation is not a given, as it depends on farmers’ practices on the land.

The debate on livestock emissions cannot be narrowed down to reducing livestock numbers.

Besides the risk of emissions leakage, it is important to consider that ruminants maintain

marginal land and use cellulose, which is not digestible for human beings, to produce proteins.

Moreover, induced land use changes could have some unexpected effects on biodiversity and

landscape management. As highlighted in the Farm to Fork Strategy and in the Methane

Strategy, changes in consumption patterns towards more sustainable diets would be an effective

way to decrease livestock emissions, while decreasing the risk of unexpected effects and

avoiding that any reduction in herd would lead to increased GHG emissions outside the EU

(leakage). This calls for a holistic approach to livestock systems when assessing their impact and

the impact of the CAP on climate.

Among the simulated measures, mitigation will mainly be achieved from extensive livestock

grazing systems, feed optimisation, manure treatment including anaerobic digestion and

maintaining carbon stocks thanks to the maintenance of permanent grassland. The main

contribution from arable systems comes through the support for nitrogen-fixing crops (EFA,

coupled support), land management which protects and increases soil carbon stocks, and

changes to N2O emissions from soils and manures. Protecting high carbon soils in

predominantly extensively-farmed Natura 2000 areas is particularly important, as the CAP has

achieved fewer reductions in intensive grassland or arable farms.

Effectiveness for climate adaptation

The number of extreme events affecting agriculture is rising. Despite climate adaptation being

considered as a relevant challenge in almost all rural development programmes, only eight

programmes targeted it explicitly. Although very few CAP measures make clear reference to

climate adaptation, several CAP measures could contribute to climate adaptation.

The CAP helps to maintain or enhance diversity of crops and farming systems (slowing down

the specialisation of farming systems), notably by maintaining permanent pasture and

diversifying crops under greening, and through the redistributive payment, certain coupled

payment schemes (protein crops), support for organic farming and assistance for areas facing

natural or other specific constraints. In addition, income support and risk management tools

improve economic resilience to shocks (e.g. drought) linked to the impact of climate change.

Direct payments and investment support can facilitate investments necessary to adapt to

new climate conditions, hence supporting a transition toward more resilient systems and

decreasing farmers’ sensitivity to shocks.

In addition, the CAP limits soil erosion and improves resilience to floods when protecting

permanent grasslands and landscape elements, enhancing catch crops (EFA) and supporting

management commitments beneficial for soil.

However, overall, Member States have not tailored cross-compliance for adaptation purposes, so

their potential cannot be fully used. Although the strong link between adaptation and mitigation

in agriculture makes it difficult to draw a clear line of distinction for the CAP’s effectiveness on

adaptation, case study interviews indicate that advising farmers on how to improve climate

performance has been a low priority. In addition, risk management tools protect farmers against

economic losses linked to extreme events but do not incentivise changes towards more resilient

production systems.

Furthermore, some measures have unintended negative effects on adaptation. Direct payments

may support the maintenance of vulnerable farms, slowing some structural changes that could

54

be necessary for adaptation, while direct payments and risk management tools might support

risk-prone behaviour. In terms of water management, modernising irrigation systems through

investment support improves the capacity of farmers to cope with droughts; however, in some

cases it may also lead, in the long run, to poor adaptation in areas where the water resource is

already depleted.

Effectiveness at stimulating innovation

Innovations in the agricultural sector have strong potential to help reduce emissions and

facilitate adaptation. Their impact depends on local factors such as pedoclimatic conditions,

farm systems and how they are put into practice in specific circ*mstances.

Technological innovation is more likely to be adopted than social innovation. With regard to

technological innovations beneficial for the climate, the use of genetically improved seeds or

animals is quite common at EU level, as is the use of sexed sem*n and climate-controlled

greenhouses and livestock buildings. Designing climate-smart innovative livestock systems

cannot be pursued at the expense of other dimensions, such as animal welfare and reducing the

risk of developing antibiotic resistance.

Social innovations are less frequently implemented by farmers, except for those participating in

water management groups (and to a lesser extent in other stakeholder and farmer groups) and in

local farming systems.

At the EU level, ‘fostering innovation’ is a cross-cutting objective of the CAP and many CAP

measures can affect the rate of innovation and its adoption. However, the use of these measures

to specifically target innovations which have an impact on climate objectives depends on

management authorities’ implementation choices and there is little data available to assess their

effects.

Efficiency

Calculating the efficiency with which the CAP secures climate benefits is complicated by the

fact that most CAP spending is interlinked with other benefits, such as better soil quality.

The analysis pointed out the importance of targeted approaches through many cases where better

targeting of support would lead to an increase in efficiency. For example, protecting carbon-rich

soils such as peatland is particularly beneficial for climate mitigation, compared to protecting

other soils.

The evaluation also highlighted the role of screening for maladaptation that could avoid public

expenditure on infrastructure, or sectors that may increase vulnerability in the medium to long

term, such as irrigation infrastructure in areas with depleted water resources. It could also avoid

promoting excessive specialisation by whole areas, thus improving efficiency. Unfortunately,

the rural development programmes examined in the national case studies contained no evidence

that such screening practices are applied.

Coherence

Overall, the CAP climate measures are coherent with the objectives of sustainable management

of natural resources, viable food production and balanced regional development. The way CAP

measures may be used together is usually coherent. There are few examples of synergies

between measures (such as enhancing protein crops and protecting soil carbon in agricultural

soils via greening, agri-environment-climate measures and cross-compliance), and more could

be done. In addition, a few measures lack coherence under some specific contexts, such as

exempting small farmers scheme beneficiaries from greening and coupled support for sectors

driving an overexploitation of water resources.

Overall, the CAP’s climate-focused measures are coherent with other EU policies related to

climate change. However, there are instances where further opportunities for integration exist,

55

particularly with the EU soil thematic strategy reinforced by Horizon Europe’s Mission: Caring

for Soil is Caring for Life – 75% healthy soils in the EU85, the Water Framework Directive and

the Floods Directive. It is important to note that, although CAP climate-focused measures and

other relevant EU policies do not conflict in principle, some of the rules in place do not

safeguard against conflicts happening in practice through the implementation of the measures.

In addition, the CAP, particularly the rural development programmes, is coherent with national

policies and helps to deliver climate goals at national and regional level.

Relevance

The CAP has objectives which are broad enough to encompass the necessary climate action, and

which correspond closely to the needs identified by Member States and at the level of

agricultural holdings. However, reduction of emissions from managed agricultural soils is better

addressed than livestock emissions by the measures available in the CAP, even if Member States

have the possibility to define more tailored voluntary measures within their rural development

programmes. This is also due to the different nature of emissions; for example, it is more

difficult to tackle enteric fermentation.

Although CAP interventions that are relevant or partially relevant to the EU’s climate needs are

compulsory for Member States (cross-compliance, the greening measures, the farm advisory

services and the agri-environment-climate measures), Member States are left a wide margin to

determine the stringency of the measures. This means that the level of ambition as regards

climate action differs widely among Member States. Some other key measures are only

voluntary (such as advisory services and knowledge transfer, investment support (including for

renewables), risk prevention and risk management). In addition, while cross-compliance and

greening are compulsory for farmers, the relevance of certain other CAP measures may also be

constrained by their voluntary nature for farmers. While voluntary measures give Member States

and farmers the flexibility to target their specific needs with appropriate interventions, there is

no requirement for farmers to take up those measures in areas where the highest needs have

been identified. Farmers also often focus on adaptation challenges rather than mitigation.

The ‘climate and environment ring-fence’, whereby Member States are required to devote 30%

of their rural development budget to measures addressing environment and climate objectives,

would be more accurate if spending on measures for ANC was excluded, as the measure itself

simply provides financial compensation for the additional costs incurred by farmers for

operating in areas with constraints and not for adapting to climate change or mitigating

emissions.

EU added value

The EAFRD requirements to address climate priorities have provided EU added value by

stimulating a higher level of climate ambition in those Member States which had not yet

developed climate action plans for agriculture and forestry. However, the number of targeted

measures for climate mitigation and adaptation, as well as the dedicated budget for such

measures, could be increased.

In addition, Member States’ implementation choices within the revised cross-compliance

framework and greening requirements do not suggest any increase in ambition on the part of

most Member States or farmers to use these measures to improve protection of water resources

and soils generally, or the carbon stores in soils and woody vegetation. Most of the choices have

prioritised farmers’ economic interests, rather than the overall sustainability of farming

(economic, environmental and social).

Lessons learned

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56

Based on a thorough analysis of needs, the targeting of climate mitigation and adaptation in

Member States’ rural development programmes could be improved and better monitored.

The mitigation and adaptation potential of several CAP measures could increase if:

ploughed grassland would not be classified as ‘permanent grassland’;

the ban on ploughing permanent grassland (currently for environmentally sensitive

permanent grasslandss) would be extended to more areas;

small farmers would not be exempted from climate-relevant requirements under current

greening;

fallow land would always be covered;

protection and restoration of wetlands and peatlands would be enhanced;

the level of ambition of CAP instruments/measures would increase;

aid for areas facing natural or other specific constraints would be subject to land

management requirements;

coupled support for livestock would be targeted at extensive systems;

support would be screened to avoid poor adaptation (e.g. irrigation support in areas in

risk of water depletion).

The dissemination of knowledge and improved advice to farmers on techniques and practices

which can improve climate performance (both mitigation and adaptation) can be improved.

In terms of monitoring, a review of the data required to understand, manage and evaluate the

contribution of agriculture and forestry to climate action, particularly mitigation, is missing.

There is a need to cover the availability, granularity (scale), consistency and timeliness of data

for, among other things: soil maps covering carbon content and erosion risk; landscape features

that can be considered as carbon stocks; fertiliser use and application methods by agricultural

holdings; tillage practices on agricultural holdings; manure management arrangements by

agricultural holdings; whether livestock housing is cooled or heated.

57

ANNEX 1: PROCEDURAL INFORMATION

1. Lead DG, Decide Planning/CWP references

Lead DG: Directorate-General for Agriculture and Rural Development (DG AGRI).

Decide planning: PLAN/2017/1023

2. Organisation and timing

This evaluation was included in the DG AGRI evaluation plan and followed the Better

Regulation guidelines for evaluations. The evaluation work was carried out through an external

evaluation study, conducted in conformity with DG AGRI’s procedure for organising and

managing policy evaluations by external contractors. The work was supervised under the

technical and the contractual management of DG AGRI’s Unit C.4, in charge of monitoring and

evaluation.

The Commission set up an inter-service steering group (ISG) on 2 May 2017. Its mandate was to

provide information, prepare the terms of reference, monitor the work of the external study

team, discuss and advise on approving the final report, and comment on the draft evaluation

staff working document.

The ISG was composed of the Directorate-General for Agriculture and Rural Development (DG

AGRI), the Directorate-General for Climate Action (CLIMA), the Directorate-General for

Environment (ENV), the Directorate-General for Research and Innovation (RTD), the

Directorate-General for Competition (COMP), the Directorate-General for Internal Market,

Industry, Entrepreneurship and SMEs (DG GROW), the Joint Research Centre (JRC) and the

Secretariat-General (SG).

The ISG started its meetings on 16 May 2017, and held nine meetings throughout the evaluation

process.

The evaluation roadmap was published on 9 June 2017. It set out the context, scope and aim of

the exercise and presented the questions to be addressed under the five criteria of effectiveness,

efficiency, relevance, coherence and EU added value.

During the period in which feedback could be provided on the roadmap (from 9 June to

7 July 2017), five contributions were received86

. An association of Dutch water companies

(Vewin) called for more attention to be paid to water, the WWF’s European policy office

questioned livestock production, while AnTaisce, an Irish NGO, raised questions about the

livestock sector and carbon sequestration in forestry and suggested Ireland as a case study. The

European Public Health Alliance (EPHA) called for more sectoral analysis and comparison of

livestock and dairy with other sectors. A Hungarian NGO (Senior Corporate Silver Spoon,

Environment & Nature Association) asked to include innovation technology as part of the

evaluation. To address these reactions adequately, the livestock and dairy sector, integrative

aspects and important livestock producing countries like Ireland and the Netherlands were duly

covered in the case studies, which played an important role in answering the evaluation

questions.

Attention was paid to water management and innovation technology issues when assessing

climate adaptation, as far as this was possible within the scope of the study.

3. Exceptions to the Better Regulation Guidelines

There was an exception in relation to the need to organise a dedicated public consultation as

part of this evaluation, since the large public consultation on modernising and simplifying the

86

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1408-Evaluation-of-the-impact-of-the-

CAP-on-climate-change-and-greenhouse-gas-emissions

58

CAP had just been held87

, which covered the necessary issues. That consultation, held between

7 February and 2 May 2017, had a very successful response rate of 322 912 replies, with a good

spread of different categories of respondents (individual farmers, public authorities, NGOs, and

farmers’ professional organisations at EU, national, regional and local level).

4. Evidence, sources and quality

An external and independent evaluation support study provides the basis for the

evaluation. This study (‘Evaluation of the Impact of the CAP on Climate Change and

Greenhouse Gas Emissions’) was commissioned under Framework Contract 30-CE-

0807500/00-67 (AGRI 2016-0296). The study was carried out by Alliance Environnement (‘the

contractor’), following the signature of the contract on 15 August 2017, and concluded on

31 October 2018 with the receipt of the final deliverable.

The contractor has exploited the available data sources, including revisions to statistical analyses

when new data became available during the course of the contract and cross-checked the use of

data when requested by the ISG. Nonetheless, there were considerable limitations to the analysis

due to the limited availability of accurate, detailed and hom*ogenous data and the particularities

of the FADN system. From the start of this evaluation, it was clear that the availability of data

on implementation would be limited, given the short period during which the reformed CAP

policy has been in place and the time it takes before FADN data become available. These

limitations are clearly explained in Chapter 4 – methodology.

The evidence in this evaluation is based on interviews with and surveys of key stakeholders,

10 national case studies carried out by experts, a comprehensive literature review, desk research

and a modelling exercise to simulate the mitigation achieved by the CAP in 2016 in comparison

with a situation of no CAP. In addition, stakeholders were consulted in several Civil Dialogue

Groups and at the Environment Working Party of the European Farmers Association Copa-

Cogeca.

In view of the data limitations signalled in this evaluation, the case studies are an important part

of the evidence. The 10 case study countries (Croatia, Czechia, France, Germany, Hungary,

Ireland, Lithuania, the Netherlands, Romania and Spain) chosen for this evaluation represent a

range of farming systems, biogeographical conditions and climate challenges. The case studies

were carried out at national level, but with a particular focus on a single administrative region in

the federal Member States (Aquitaine in France, Saxony-Anhalt in Germany and Andalucía in

Spain88

) to source more detailed information on the way the CAP measures operate in practice

and the implications for climate mitigation and adaptation.

All case studies followed the same general approach and applied the same methodology. A case

study template and guidance was prepared by the core study team to seek as much hom*ogeneity

as possible and to allow the results of the case studies to be synthesised in a streamlined way.

The people leading the case studies also received a data pack containing the existing data

available to the core study team for their Member State.

An online briefing session was carried out with all case study experts prior to starting the work

to explain the context of the evaluation study, its purpose and objectives, the methods and data

collection needs in detail. This was followed by regular exchanges throughout the case study

work.

The ISG for the external evaluation study carried out a quality assessment of the contractor’s

external report on this evaluation, particularly the quality of the methodology, the reliability

of the data and the robustness of the analysis and findings. It judged that the report could be

87

https://ec.europa.eu/agriculture/consultations/cap-modernising/2017_en

88 Since adaptation challenges vary to a greater extent between regions than mitigation challenges, the regions

were chosen to include adaptation challenges too.

59

approved, as it complied fully with the conditions of the contract and relevant professional

evaluation standards.

To ensure that it incorporates all relevant findings and analysis of available studies and the most

up-to-date data on the implementation of CAP measures and instruments, the evaluation draws

on a broad range of additional sources, which have been referenced throughout the

document. As such, it addresses some of the limitations of the evaluation support study, notably

related to its limited observation period regarding the implementation of various CAP measures

and instruments.

60

ANNEX 2: SYNOPSIS REPORT ON THE STAKEHOLDER CONSULTATION

A wide range of consultation methods and activities were carried out for this evaluation. They

can be grouped in the following manner:

1. Consultations by the European Commission: Special Eurobarometer 47389; the public

consultation on modernising and simplifying the CAP90; the consultation of the relevant

Civil Dialogue Groups, notably the one on arable crops, cotton, flax and hemp, dried

fodder, energy and non-food crops sectors on 25 June 2019, as well as the Civil Dialogue

Group on environment and climate change on 8 July 2019; consultation in the Environment

Working Party of the European Farmers Association Copa-Cogeca on 17 June 2019; the

Special Eurobarometer survey on Europeans, Agriculture and the CAP conducted in

August-September 2020.

2. Consultations by the contractor carrying out the external evaluation study: interviews

with key stakeholders, including farmers, advisers and representatives of the farming,

forestry and wider rural sectors, regional and national authorities, climate researchers,

academics and NGOs. Within the 10 national case studies, the following stakeholders were

consulted through interviews: national and regional authorities, and national and regional

agricultural cooperative unions. Climate researchers and academics studying agricultural

policy and their works were also consulted. The case studies were supplemented by two

short surveys: one to gather specific information on the uptake of adaptation techniques and

technologies, which was addressed to advisers and farmers’ representatives; and one on the

extent of knowledge and uptake of mitigation actions, which was addressed to farmers. In

both cases, the short survey questionnaires were sent to a non-representative group of

advisers and farmers in the 10 case study countries. On average, nine farmers and 23 farm

advisers responded per country, with the response rate by farmers depressed by three

Member State administrations that chose to administer the farmer survey themselves for

data protection reasons but failed to elicit any responses.

For stakeholders, particularly to avoid consultation fatigue and confusion of the public, no

additional public consultation was carried out, as the large public consultation on modernising

and simplifying the CAP had just been held91

, which covered the necessary issues.

In view of the CAP post-2020 impact assessment, the Commission’s CAP policy proposals and

the next MFF, possible misunderstanding with stakeholders had to be avoided where possible.

The Special Eurobarometer 473 survey (December 2017) showed that EU citizens still

consider the CAP to be an important result of the EU in terms of public goods. The independent

survey, carried out in the 28 Member States and involving 28 000 participants (report published

in February 2018), indicates that the majority of respondents (75%) believe that the CAP is

fulfilling its roles, particularly in ensuring a stable, safe and healthy food supply.

There is a consensus on the EU value added of the CAP, with a majority of respondents thinking

that the CAP benefits all European citizens and not just farmers (60%). However, the level of

agreement on this statement is considerably lower than in 2013 (-16%) in all countries except

for Slovenia. Compared to the last survey, the overall acceptance by society of the CAP has

declined, but there is an increase in the proportion of respondents that mention providing safe,

healthy, high quality food as the main objective of the CAP (62%).

89

Special Eurobarometer 473: Europeans, Agriculture and the CAP

https://data.europa.eu/euodp/en/data/dataset/S2161_88_4_473_ENG

90 Consultation on modernising and simplifying the CAP, held between February and May 2017. It was open to all

interested citizens and organised through a questionnaire available on DG AGRI’s website. The results were

based on an analysis of replies from 58 520 respondents, of which 36.5% were farmers, 47.7% other citizens

and 15.8% organisations. 91

https://ec.europa.eu/agriculture/consultations/cap-modernising/2017_en

61

In spring 2017, the Commission (particularly DG AGRI) carried out a broad internet-based

public consultation on modernising and simplifying the CAP. This was open to all citizens

and addressed matters that are also relevant for this evaluation.

The public consultation harvested a very high number of opinions from a wide spectrum of

stakeholders. 322 912 online replies were received and 1 417 position papers were submitted

(after identifying campaigns and excluding duplicates, there were still 58 520 online

contributions and 693 position papers).

The contributions were received from all the main categories of stakeholders. The highest

contribution came from citizens (47.7%, high interest), followed by farmers (36.5%, very

high interest) and organisations (15.8%). The majority of position papers was submitted by

organisations (61.5%), followed by citizens (21.6%) and farmers (16.9%).

The key stakeholders for climate change evaluation are farmers and organisations such as:

public authorities responsible for implementing CAP measures in Member States at national,

regional and/or local level (very high interest); the agro-food sector (very high interest); the

forestry sector (high interest); civil society (e.g. NGOs and organisations from, among others,

the agriculture, environment, climate change and forestry sectors) (very high interest);

academics, researchers, experts, think-tanks, consultancies (high interest).

Given that the contributions were received only half a year before the evaluation of the impact

of the CAP on climate change, the participants would most likely not have amended their

responses drastically if there had been a specific public consultation.

The need to guarantee a level playing field within the single market and the existence of cross-

border challenges like food security, environment and climate change (with a positive reply of

more than 90% of the respondents) emerged as key reasons that justify an agricultural policy

commonly managed at EU level. Other justifications include the need to have a common

position at international level, the need to maintain economic, social and territorial cohesion

across the EU, and the need for a common framework for sharing best practices.

The two surveys also explored, in line with the subsidiarity principle, whether, and to what

extent, CAP governance should be executed on a regional, national or European level.

The 2017 public consultation on modernising and simplifying the CAP, in more detail

One of the 33 questions in the public consultation directly addressed climate change: ‘Which are

the most important objectives for the CAP to better address climate change?’

Overall, respondents said the most important objectives are ‘Providing sustainable renewable

energy resources’ (17%), ‘Promoting afforestation and sustainable forest management’ (16%)

and ‘Reducing Green House Gas (GHG) emissions in the agricultural sector’ (15%).

For farmers, the first choice was ‘Providing sustainable renewable energy resources’ (20%),

followed by ‘Improving climate change adaptation and enhancing the resilience of agriculture

production systems’ (16%) and ‘Fostering carbon conservation and sequestration in agriculture

and forestry’ (15%).

For citizens, the first choice was ‘Reducing Green House Gas (GHG) emissions in the

agricultural sector’ (23%), followed by ‘Promoting afforestation and sustainable forest

management’ (20%) and ‘Promoting diversification of farming systems’ (14%).

For respondents from organisations, the first choice was ‘Providing sustainable renewable

energy resources’ (19%), followed by ‘Improving climate change adaptation and enhancing the

resilience of agriculture production systems’ (17%) and ‘Promoting diversification of farming

systems’ (14%).

62

Figure 6: Which are the most important objectives for the CAP to better address climate change?

Note: Respondents were invited to select three choices out of seven options.

Source: The 2017 public consultation on modernising and simplifying the CAP

Other questions where climate change is considered

This analysis focuses on the value given to climate change against other topical issues in

agriculture.

In the following questions, climate change is one topic among many and respondents selected

the topics that they considered important. The answers from respondents from organisations

vary according to the sector and the type of organisation, so this analysis focuses more closely

on the responses of farmers and other citizens.

13% of farmers and 23% of other citizens highlighted climate change as one of the most

important challenges for EU agriculture. The main challenge for farmers remains ensuring a fair

standard of living for farmers (32%), while for citizens it is pressure on natural resources (32%).

Regarding the current CAP policy tools best suited to meet these challenges, farmers most

frequently selected rural development (RD) support (18%) and decoupled payments (15%).

Other citizens most frequently selected ‘Support for RD environment & climate actions in

agriculture and rural areas’ (30%), followed by ‘Support for RD investments in physical/human

capital in agriculture and rural areas’ (16%) and ‘Regulatory approaches (such as standards and

rules)’ (14%).

For a majority of respondents, these challenges are successfully addressed only to some extent.

63

Figure 7: Which are the most important challenges for EU agriculture and rural areas?

Source: The 2017 public consultation on modernising and simplifying the CAP

Figure 8: Which of the current CAP policy tools are best suited to meeting the challenges identified

above?

Source: The 2017 public consultation on modernising and simplifying the CAP

Figure 9: To what extent does the current CAP successfully address these challenges?

Source: The 2017 public consultation on modernising and simplifying the CAP

32%

22%

31%

27%

14%

12%

13%

13%

15%

32%

16%

23%

13%

23%

13%

18%

14%

7%

15%

11%

12%

5%

11%

8%

0% 50% 100%

Farmers (n = 54706)

Other citizens (n = 74739)

Organisations (n = 23478)

Total (n = 152923)

Fair standard of living for farmers

Adaptation to trends in consumer/societal demands

Pressures on the environment and on natural resources

Climate change (mitigation and adaptation)

Lack of jobs and growth in rural areas

Uneven territorial development throughout the EU

15%

7%

15%

12%

11%

8%

12%

10%

18%

30%

18%

23%

18%

16%

19%

17%

7%

4%

7%

6%

11%

6%

11%

9%

8%

5%

8%

7%

7%

9%

6%

8%

4%

14%

5%

9%

0% 50% 100%

Farmers (n = 68153)

Other citizens (n = 76446)

Organisations (n = 29537)

Total (n = 174136)

Decoupled payments to farmers

Coupled support

Support for RD environment & climate actions in agriculture and rural areas

Support for RD investments in physical/ human capital in agriculture and rural areas

Trade measures

Market safety nets (e.g. market intervention)

Risk management schemes

Support for integration into producers' organisations

Regulatory approaches (such as standards and rules)

3% 1% 3% 2%

19%

4%

19%

12%

62%

51%

61% 57%

13%

27%

15% 20%

3%

17%

2%

10%

0%

35%

70%

To a large extent To a fairly good extent To some extent only Not at all Don't Know

64

Addressing climate change is not highlighted as the main contribution of farmers to our society

(5% for all respondents). For respondents, the most important contribution of farmers relate to

supplying healthy, safe and diversified products (27%), followed by protecting the environment

and landscapes (22%).

Figure 10: Which of the following do you think are the most important contributions of farmers in

our society?

Source: The 2017 public consultation on modernising and simplifying the CAP

However, when asked about the most relevant priorities for the CAP 2014-2020, mitigating and

adapting to the impact of climate change comes third for farmers (18%), behind boosting

investment, growth and employment, as well as strengthening the EU single market. For other

citizens, climate action is the most relevant priority by far (37%).

Figure 11: Of the European Commission’s priorities for 2014-2020, which are the most relevant to

the CAP?

Source: The 2017 public consultation on modernising and simplifying the CAP

When asked about the most important objectives of the CAP, answers are consistent with the

answers to the main challenges. For farmers it should be, firstly, ensuring a fair standard of

living for farmers (21%) and, secondly, ensuring the supply of healthy and quality products as

well as developing rural areas. Climate action comes last (5%).

18%

9%

19%

14%

28%

27%

27%

27%

17%

28%

17%

22%

3%

8%

3%

5%

6%

2%

5%

4%

17%

7%

19%

13%

2%

1%

2%

1%

8%

20%

7%

13%

0% 50% 100%

Farmers (n = 60278)

Other citizens (n = 76558)

Organisations (n = 25691)

Total (n = 162527)

Ensuring that enough food is available

Supplying healthy, safe and diversified products

Protecting the environment and landscapes

Addressing climate change

Contributing to renewable energy

Maintaining economic activity and employment in rural areas

Contributing to EU trade performance

Ensuring the health and welfare of farm animals

29%

17%

30%

24%

17%

13%

15%

15%

18%

37%

18%

26%

21%

17%

20%

19%

10%

4%

11%

7%

6%

13%

6%

9%

0% 50% 100%

Farmers (n = 49981)

Other citizens (n = 55822)

Organisations (n = 21377)

Total (n = 127180)

Boosting investment, growth and employment

Improving connectivity and digitalisation of the rural economy

Mitigating and adapting to the impact of Climate Change and providing renewable energy

Strengthening the EU Single Market

Participating in world trade

Help addressing challenges related to migration

65

For citizens, climate action ranks higher (14%), still behind the supply of healthy and quality

products and the contribution to environmental protection.

Figure 12: Which of the following should be the most important objectives of the CAP?

Source: The 2017 public consultation on modernising and simplifying the CAP

According to other citizens, the most relevant criteria when allocating direct support is practices

with the highest environmental/climate benefits (19%), while for farmers the most relevant is

compensating for farming activities in ANC (18%).

Figure 13: Which of the following criteria are most relevant when allocating direct support?

Source: The 2017 public consultation on modernising and simplifying the CAP

7%

4%

9%

6%

6%

2%

7%

4%

18%

17%

17%

17%

3%

1%

4%

2%

9%

19%

10%

14%

7%

12%

8%

9%

10%

3%

9%

6%

12%

17%

10%

14%

14%

15%

13%

15%

14%

10%

13%

12%

0% 50% 100%

Farmers (n = 78762)

Other citizens (n = 106228)

Organisations (n = 33308)

Total (n = 218298)

Specific products and/or sectors

Risk management tools

Compensation to farming activities in Areas with Natural Constraints/ High Nature Value Areas

Territories with higher agricultural potential

Practices with the highest environmental/climate benefits

Linkage to standards (e.g. food safety, labour)

An equal level of support for farmers within the same territory

Small producers

Limit in support for large beneficiaries (capping)

66

For 19% of other citizens and 13% of farmers, environment and climate standards are the main

element for which the linkage between CAP and standards can be improved.

Figure 14: Considering consumer and wider societal demands, where can the linkage between CAP

and standards be improved?

Source: The 2017 public consultation on modernising and simplifying the CAP

Analysis of the open questions

The 2017 public consultation on the CAP also included five open questions, two of which

(questions 12 and 13) are relevant to climate.

Question 12: What are the main problems/obstacles preventing the current policy from

successfully delivering on its objectives? What are the drivers behind these problems?

The most discussed topics were the ‘environment’, ‘simplification’, ‘politics and decision-

making’ and ‘subsidies’.

The responses to the topic of the ‘environment’ emphasised environmental pollution and lack of

attention to sustainability: environmental pollution, especially of soil, water, air, climate and

biodiversity, are indicated by the participants as important problems. In relation to these issues,

participants included the lack of attention to sustainability, which poses a barrier to attaining

environmental objectives. The use of pesticides, fertilisers and herbicides is mentioned as an

obstacle both in the sense that they are used too much and that the rules on their use are too

strict.

Question 13: Which elements of the current CAP are the most burdensome or complex,

and why?

Under this question, the most discussed topic was ‘simplification’ linked to ‘greening’,

‘application’, ‘controls - too many, too much’ and ‘bureaucracy’. Answers regarding greening

indicate it to be a burdensome element, making specific references to the definition of

permanent grassland and EFA, especially the declaration of landscape elements. Many of the

participants referring to greening also indicate cross-compliance as complex and burdensome.

The Special Eurobarometer survey on Europeans, Agriculture and the CAP, conducted in

August-September 2020, revealed that 51% of EU citizens think that one of the main

objectives of the EU in terms of agriculture and rural development policy should be ‘Protecting

the environment and tackling climate change’.

Although the number of EU citizens thinking that agriculture is one of the major causes of

climate change has increased over the last 10 years to 42%, up by 13 points, more people also

recognise that the agricultural sector has already made significant contributions to tackling

climate change (54%, +8pp). In addition, a larger share of Europeans are even prepared to pay

10% more for agricultural products that are produced in a way that limits their carbon footprint

67

(66%, +8pp). Despite this, more respondents think that EU farmers need to change the way they

work in order to fight climate change, even if it comes at the price of making EU agriculture less

competitive (69%, +2pp). 27% of Europeans think that one of the main responsibilities of

farmers is protecting the environment and tackling climate change (+2pp).

More people (62%, +5pp) think that the CAP is fulfilling its role, among others, in protecting

the environment and tackling climate change. In terms of the new priorities of the CAP, the vast

majority of people participating in the survey consider each priority important (ranging from

83% to 92%), and particularly the priorities of ‘Ensuring sustainable management of natural

resources’ (92%) and ‘Helping tackle climate change’ (90%).

68

ANNEX 3: METHODOLOGY

The methodological approach to the evaluation combined quantitative and qualitative analysis,

including a literature review, desk research, econometric analysis, surveys, interviews and case

studies, primarily as part of the external and independent evaluation support study carried out by

Alliance Environnement. DG AGRI further complemented the study with additional analysis

(using up-to-date statistics) and synthesis of newly available literature. The wide range of

consultation methods and activities carried out for this evaluation are described in Annex 2.

Table 6: Description of the data collection and analytical tools

Method/Tool Brief description of tool Type of tool

Relevant

evaluation

question

Data collection tools

Simulation To quantify the impact of CAP measures on GHG emissions by

combining uptake data reported by Member States with

relevant emissions factors from literature, using a modelled

baseline with which to contextualise the results.

Quantitative 1-4

Documentary

research /

Literature

reviews /

Statistical data

analysis

To draw on the available literature, key unpublished grey

literature and other datasets (statistical, etc.) to:

- establish the counterfactual situation;

- map Member States’ and regions’ implementation

decisions;

- examine the causal relationship between the actions or

management practices supported by a policy instrument or

measure and the main outcomes, and how these might

differ geographically in different biophysical or climatic

situations;

- establish the key drivers and pressures influencing the

agriculture and forest sectors, and rural areas more

generally, the state of the environment and key threats, to

help inform the counterfactual/baseline situation and

enable an assessment of their relevance;

- review the effects of previous CAP instruments/measures;

- review the range of factors influencing, among other

things, the effectiveness and efficiency of measures’

implementation.

To identify any issues of coherence.

Qualitative

&

quantitative

All

Questionnaire-

based surveys

Used to gather data from a small, non-representative sample of

farmers in each of 10 case study countries on their experience

of climate pressures and relevant CAP instruments. Also used

with farm advisers to gain information on the extent of uptake

of different types of innovation.

Qualitative

(because of

sample size)

5,6,10

Case studies Used to provide a detailed picture of CAP implementation and

climate action in 10 Member States.

Qualitative

&

quantitative

All

Analytical tools

Cost-

effectiveness

analysis

Comparison of the benefits of a policy instrument with the costs

involved in securing them.

Quantitative 7

Coherence

matrix and

scoring

Used to analyse the coherence between regulations and/or

intervention logics. Standardised approach used for the

assessment of the internal and external coherence of different

CAP instruments and the way they have been applied in

Member States/regions.

Qualitative 10 & 11

Source: External evaluation study

69

Methods for estimating leakage

Estimating leakage in an agricultural context is complex and subject to high levels of

uncertainty. The consequences of changes in production are related to market and political

forces and occur in an industry which is highly dispersed and disaggregated, with many small

operators (farmers) throughout the world. Furthermore, production is related to yield (e.g.

production per unit area for crops) and the area of land used for production. A change in

production area will not necessarily lead to an increase in production area elsewhere (with

potential land use change), because the change in production area may incentivise, perhaps

indirectly, improvements in yield.

It is certain that net GHG emissions occur from activity related to land use change, and that the

emissions can be large relative to emissions from annual agricultural production of a particular

product. However, the allocation or attribution of these emissions to particular production

sectors or particular production changes is not known, and is difficult to estimate.

The methods used to estimate leakage in the context of agricultural production mainly focused

on emissions associated with Indirect Land Use Change (ILUC), in the context of the GHG

mitigation potential of biofuels.

Two main types of method have been used, with some methods that combine aspects of both:

Modelling approaches. Econometric models have been used to predict changes in trade

flows as a consequence of policy- or market-driven scenarios for change in agricultural

production. Changes in land use and GHG emissions are then also predicted.

Simplified allocation. GHG emissions from land use change, for each region or country

in the world, are estimated using land use statistics and carbon stock change factors. The

emissions are allocated to the land used for agricultural production in various ways,

depending on the detail of the method. Weightings can be applied for yield or the

proportion of production traded internationally, for example.

Full quantification of leakage, even when complex modelling is involved, is subject to high

uncertainty. Quantification of leakage requires predictions of future impacts, and the results

cannot easily be validated because the actual allocation of LUC to policy and activity changes in

another place cannot be observed or measured (European Commission, 2010). An attempt to

compare modelled vs observed LUC has concluded that most ILUC models overestimate ILUC

emissions as they do not properly account for cropland that is not fully used (O’Connor, 2015).

The use of case studies

The case studies provide detailed and context-specific qualitative and quantitative information to

complement the EU-wide information collected to inform the analysis and answers to the

evaluation questions. The information was gathered through interviews with key stakeholders,

including advisers and representatives of the farming, forestry and wider rural sectors,

government officials and climate researchers and NGOs, and by sourcing and analysing

national/regional literature, statistics and other data sources. All information from the case

studies has been carefully interpreted to determine what generic conclusions can be drawn from

them for the analysis and answers to the evaluation questions.

Analytical model

To calculate the emission reductions brought about by the CAP measures in 2016, the evaluation

used the GAINS model (Greenhouse gas-Air pollution Interactions).

The emissions with the 24 CAP measures in place were compared with a GAINS scenario that

assumed these measures were absent, from which the mitigation due to the CAP measures was

calculated. To distinguish between the effect of both CAP pillars, two scenarios were run, one

without the Pillar I measures and the other without the Pillar II measures.

70

The GAINS model explores cost-effective emission control strategies that simultaneously tackle

local air quality and greenhouse gases, so as to maximise benefits at all scales. GAINS is now

used for the whole world, distinguishing 165 regions, including 48 European countries.

GAINS provides an authoritative framework for assessing strategies that reduce emissions of

multiple air pollutants and greenhouse gases at least cost, and minimise their negative effects on

human health, ecosystems and climate change.

GAINS estimates historic emissions of 10 air pollutants and 6 GHGs for each country, based on

data from international energy and industrial statistics, emission inventories and on

data supplied by countries themselves. It assesses emissions on a medium-term time horizon,

with projections being specified in five-year intervals until 2050. GAINS estimates for each

country/region the potential emission reductions that are offered by about 2 000 specific

emission control measures and their costs.

For user-specified packages of measures, GAINS calculates resulting effects on ambient air

quality (fine particles, ground-level ozone, deposition of sulphur and nitrogen), and the

subsequent impacts on human health and ecosystems.

The GAINS model can be operated in two ways:

In ‘scenario analysis’ mode, it follows emission pathways from sources to impacts,

providing estimates of regional costs and the environmental benefits of alternative

emission control strategies.

In ‘optimisation’ mode, it identifies where emissions can be reduced most cost-

effectively. The model identifies a balance of concrete measures for different pollutants,

sectors and countries/regions that achieve air quality and GHG reduction targets at least

cost, considering the contributions of different pollutants to different air quality and

climate problems.

71

ANNEX 4: CAP CLIMATE MEASURES - COHERENCE AND ADDED VALUE

Table 7: Summary of the theoretical internal coherence analysis of CAP measures

Number of positive

relationships

identified

Number of

neutral

or no

relationships

Number of negative

relationships identified

Number of relationships

identified as having

mixed impacts

Basic payment

scheme (BPS) 1 (FAS) 21

1 (FAS may be used by

MS to advise farmers on

climate issues which may

help BPS recipients to

mitigate their emissions)

Greening crop

diversification

4 (CC, FAS,

nitrogen-fixing crops

(NFC) in VCS and in

EFA)

18 1 (SFS)

Greening permanent

grassland 2 (CC and FAS) 19 1 (SFS) 1 (VCS)

Greening EFA

4 (CC, FAS, NFC in

VCS and crop

diversification)

18 1 (SFS)

Voluntary coupled

support

3 positive

relationships for VCS

for protein crops (CC,

crop diversification

and NFC options in

EFA)

15

3 potential negative

relationships for VCS for

livestock (potentially

exacerbating negative

climate impacts when

used in conjunction with

M13)

2 for VCS for livestock

(greening PG ratio may

help maintain livestock

systems, similarly to VCS

for livestock, but their

climate impact is context-

specific)

FAS may be used by MS

to advise farmers on

climate issues

Small farmers

scheme 19

3 (exemptions from the 3

greening obligations) 1 (FAS)

M1 Knowledge

transfer/Information

6 (knowledge,

training and advice

can maximise the

climate benefits

potentially arising

from M8, M7, M10,

M15, CC and FAS)

10 -

7 (M2, M16, M4, M3,

M11, M5, M17),

depending strongly on

MS/region’s

implementation choices

M2 Advisory

services

6 (knowledge,

training and advice

can maximise the

climate benefits

potentially arising

from M8, M7, M10,

M15, CC and FAS)

10 -

7 (M2, M16, M4, M3,

M11, M5, M17),

depending strongly on

MS/region’s

implementation choices

M16 Cooperation 4 (M7.2, M10, M15,

M5.1) 12 -

7 (M1, M2, M4, M8, M3,

M11 and FAS), depending

strongly on MS/region’s

implementation choices

M4 Investments

3 (M4.3 and M4.4 in

particular can support

the potential positive

climate effects arising

from M10, M15 and

CC)

14 - 6 (M1, M2, M16, M3,

M11 and FAS)

M6 Farm/business

development - 22 - 1 (FAS)

M8 Forest

investment

4 (M1, M2, M15,

CC) 16

1 (VCS-livestock and

M8.1-8.2 can contradict

each other)

2 (FAS and M16)

M7 Basic services

and village renewal 3 (M1, M2 and M16) 19 - 1 (FAS)

M10 Agri-

environment-climate

5 (M1, M2, M16, M4

and CC) 14 1 (VCS-livestock) 3 (M3, M11 and FAS)

72

Number of positive

relationships

identified

Number of

neutral

or no

relationships

Number of negative

relationships identified

Number of relationships

identified as having

mixed impacts

M15 Forest-

environment-climate

6 (M1, M2, M16, M4,

M8 and CC) 16 - 1 (FAS)

M11 Organic

farming 1 (CC) 15 -

7 (M1, M2, M16, M4, M3,

M10 and FAS)

M12 Natura 2000 1 (CC) 22 - -

M13 Areas facing

natural constraints 1 (CC) 20

1 (potentially

exacerbating negative

climate impacts when

VCS-livestock is

combined with M13)

1 (FAS)

M5 Risk reduction

1 (M16.5 can

maximise M5.1

impact)

19 - 3 (M1, M2, FAS)

M17 Risk

prevention - 20 - 3 (M1, M2, FAS)

Cross-compliance

(CC)

15 (because CC is

conditional on a range

of measures and is

beneficial for climate,

it positively interacts

with BPS, the 3

greening obligations,

VCS, M1, M2, M4,

M8, M10, M15, M11,

M12, M13 and FAS)

8

-

Farm advisory

system

6 (FAS must cover

CC and the 3

greening obligations

and can maximise the

benefits from M1 and

M2)

2 -

15 (BPS, SFS, M16, M4,

M6, M8, M3, M7, M10,

M15, M11, M13, M5,

M17 and VCS)

Note: CC: cross-compliance (in this table it refers to GAEC 1, 4, 5, 6, and 7); SFS: Small farmers scheme; VCS: Voluntary

coupled support; FAS: Farm advisory system.

Source: Evaluation support study

73

Table 8: External coherence of the CAP climate measures

Policies/mechanisms/strategies

aiming at:

Greening RDP soft

measures

(M 1, 2, 16)

M4

Investments in

physical assets

M5

Disaster risk

reduction

M8

Investment

forest

M10 Agri-

environme

nt-climate

M15 Forest-

environment-

climate

Cross-compliance

(GAEC standards) EFA PG Diversifi

cation

MI

TI

GA

TI

ON

Mitigation of non-CO2 emissions

Nitrates Directive

Emission Trading System

Effort Sharing Decision

Low-carbon economy roadmap

National Emissions Ceiling Directive

GAEC 1, 4

Mitigation of CO2 emissions

EU Soil Thematic Strategy

Low-carbon economy roadmap

LULUCF Decision

EU Forest Strategy

Circular Economy Package

GAEC 1, 4, 5, 6, 7

Improved energy efficiency

Energy Efficiency Directive GAEC 5

Development of renewable energies

Renewable Energy Directive

ILUC Directive

EU Bioeconomy Strategy

ADAPTATION

EU Forest Strategy

Floods Directive

Water Framework Directive

GAEC 1, 4, 5, 6, 7

INNOVATION

EU Bioeconomy Strategy

LIFE programme

Horizon 2020

European Innovation Partnership

Legend: Yellow = Neutral; Green = Coherent; Blue = Mixed

Source: Evaluation support study

74

Table 9: EU added value of CAP mitigation and adaptation measures

Potential CAP measures Counterfactual EU added value

A higher level

of ambition for

climate action at

EU level

Mitigation: only the EAFRD

has been shown to foster a

higher level of ambition for

climate action. The

implementation choices of the

other CAP measures show little

evidence of increased ambition

overall, yet GAEC and greening

may have prevented a decline in

ambition. There is an evident

lack of ambition in addressing

CH4 reductions across all the

CAP measures.

Adaptation: the strategic

planning process required for

programming the EAFRD may

have stimulated integration of

adaptation in rural development

programmes (RDP).

MS would not necessarily

attach environmental

conditions to direct

payments, or replace

EAFRD measures with

incentives to address EU

climate mitigation or

adaptation, through land

management and

investment support, or

through ‘soft’ measures

such as knowledge

transfer and advice.

Yes, for

mitigation there

is strong

evidence of the

added value of

the EAFRD.

To a limited

extent for

adaptation

ambition, but

only for the

EAFRD.

Increased

effectiveness

through EU

action

Mitigation: EAFRD funding

rules promote the use of agri-

environment-climate

commitments that benefit both

mitigation and adaptation

(particularly for soil and carbon

protection). These, and some of

the forest measures, also

contribute to adaptation.

Theoretically, the EAFRD has

considerable potential for

transboundary adaptation

actions in both agriculture and

forests, but data is lacking on

the extent to which this has

occurred.

Adaptation: FAS and RDP

measures also strengthen the

Agricultural Knowledge and

Innovation Systems in many

MS. Such support is an essential

complement to other measures

(e.g. M4, M10), improving their

effectiveness.

Yes

75

Coordination

gains

Work by the European Network

for Rural Development and EIP-

AGRI has promoted sharing of

good practice relevant to climate

action.

None Yes

Efficiency gains

The flexibility available in the

design and targeting of the

EAFRD allows managing

authorities to achieve high

levels of efficiency, but this

potential has not yet been fully

realised.

None

Yes, for the

EAFRD, but the

potential for

environmental

efficiency has

not yet been fully

realised.

Legal certainty

and policy

framework

EAFRD environmental land

management contracts for 5-

7 years provide certainty for

contract holders or between

programming periods.

MS could choose to

provide an improved level

of certainty if they wished

(for example, through

longer contracts for soil

management).

Yes, to some

extent, for

EAFRD land

management

contracts.

Promoting

complementarity

and synergy

CAP measures are designed to

complement each other and to

be used coherently, although the

extent to which synergies are

achieved depends on Member

States’ implementation choices.

EAFRD and other ESI Funds

are used synergistically.

More risk of double

funding under

combinations of national

schemes and other EU

funds.

Yes

Source: Evaluation support study