Leaked Letters Reveal Environment & Climate Commissions’ Severe Criticism of CAP Plans

The European information platform ARC 2020 has published the texts of two leaked letters which reveal serious criticism of European Commission’s DG ENV and DG CLIMA regarding the national strategic plans (SPs) for the future Common Agricultural Policy (CAP). Letters point to almost complete lack of effort by the national capitals to integrate any improvements suggested in the Commission’s observation letters.

Read here the letter of DG CLIMA 

Read here the letter of DG ENV 

For DG CLIMA the general focus was on four main criticism:

  1. Lack of at least a “rough qualified estimate” on the mitigation potential of climate relevant measures, regarding Emissions Sharing Regulation (ESR) and Land Use Land Use Change and Forestry (LULUCF). Only Ireland from all member states has addressed the request for some level of quantification –  with the rest arguing that it was not a legal requirement.
  2. Lack of consideration on the new proposed national ESR and LULUCF targets, to avoid the need to review the CSPs during 2023 shortly after their adoption. “No Member State included the new targets in the design of the green architecture, with the argument that they are not yet included in legally binding legislation”.
  3. Insufficient ambition about the CSPs in accordance with Article 105 SPR.
  4. Lack of guarantee for the climate effectiveness of the intervention strategy by means of a series of targeted comments.

Equally, DG ENV criticizes member states for the almost complete lack of efforts. “In some cases, MSs’ proposals are not in line with the conditionality provisions of the Regulation…in other cases, the absence of, or the very low improvement of ambition of the original plan, make for an insufficient contribution to the needs identified by MSs themselves and to the pieces of environmental legislation listed in Annex XIII of the Regulation.”

DG ENV‘s letter states that „these issues should be solved before the Commission can give the green light to MS to resubmit their plan for adoption” and that “Commission observations have resulted in no or very little reshuffling of budgets/result indicators”.

Overall, these letters point to serious disadvantages in shaping the new CAP. Current CAP’s ecological results are generally low, shows the European Court of Auditors. And now, yet again, environmental authorities find the CAP – which we will be stuck with until 2027  – to fall far short of any real environmental ambition.

How far is the process of examining the national strategic plans?

Currently all of the member states have submitted first draft of SPs for CAP. This month 10 of the states should submit second draft of their SPs – Austria, Denmark, Estonia, Spain, Finland, France, Ireland, Luxembourg, Portugal and Poland. The Netherlands and Hungary should follow them in August.

See the whole article of ARC 2020: https://www.arc2020.eu/leaked-letters-reveal-environment-climate-commissions-severe-criticism-of-cap-plans/