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In a Fact-Sheet published this week “Working with Parliament and Council to make the CAP reform fit for the European Green Deal” the Commission tries to re-write the history of the latest CAP reform.

The Commission criticises the European Parliament and Council positions because they ask for flexibility in the implementation of eco-schemes and that according to the Commission could lower resources for climate and environmental benefit.

The Commission seems to forget that it proposed total flexibility for the implementation of the eco-schemes, without any ring-fencing of resources, contrary to the positions of the EP and Council. In fact what the Commission proposed could lead to fewer resources for climate and environment, and in any case make it impossible to attain EU wide objectives.

The Commission also criticises the co-legislators for watering down the performance framework of the reformed CAP. The Commission seems to forget that it did not propose a single performance indicator to be monitored, all the targets proposed were no more than statistical outputs.

We could go on giving more examples, as the Commission left to Member States the design of the national and regional policies, including basic conditionality requirements like the definition of rotation.

The fact is that the impact of the Commission proposal on the climate and environment was a black box.

The Commission seems to attempt to re-write the history to find a new legitimacy to impose its own Green Deal objectives and align the CAP with the Farm to Fork and Biodiversity Strategies. The reasoning of the Commission is that the Green Deal objectives were agreed by all, but unfortunately “certain aspects of the positions of the legislator do not match with the shared objective that the new CAP delivers on the Green deal objectives”, and therefore the Commission is entitled to “verify coherence of the Strategic Plans with the Green Deal targets”.

We see in the Commission position two serious issues of legitimacy. Firstly, only the Green Deal overall objectives of reducing GHG emissions are shared at this stage. The Commission objectives in the Farm to Fork and Biodiversity Strategies were not agreed. There isn’t even a legislative proposal. Thus the Commission lacks institutional legitimacy to try to impose them through the approval of the CAP Strategic Plans.

The Commission also lacks the policy legitimacy to impose those targets (10% agricultural land set-aside, -20% chemical fertilizers,-50% chemical pesticides, 25% share of organic production, plantation of 3bn trees, -50% antimicrobials for livestock), as the Commission did not make a prior Impact Assessment of these far-reaching proposals, nor did it publish studies on their impact so far.

According to the sole Impact Assessment published, by the USDA, it would be a disaster for the agriculture sector, for EU consumers and food security (it would reduce EU agriculture production by 12%, increase prices by 17%, reduce exports by 20%, increase imports by 2%, shrink gross farm income by 16%, and increase the annual per capita food cost in the EU by $ 153).

In this context, it is high time that the Commission publishes an Impact Assessment independent from political pressure, and without delay releases the evaluation study on the impact of the Farm to Fork and Biodiversity strategies on agriculture, as it referred to in its impact assessment of the 2030 Climate plan.