Summary and conclusions The CAP decisions on the Greening of Direct payments with regard to the area of national auton-omy in applying the three greening components, crop diversification, maintenance of permanent grassland and ecological focus areas (EFA), are evaluated in the following position paper and rec-ommendations are made. Here the questions of how far the individual national implementation options affect biodiversity and the costs associated with the individual EFA measures are consid-ered. Furthermore the administrative requirements are evaluated. The results can be summa-rized as follows:Crop Diversification Crop diversification will have only a very minimal positive effect on biodiversity and climate pro-tection in the current form of planning, since only very few farms will be affected by this re-quirement and therefor must expand their crop sequences. For an effect on the biodiversity, more crops in sequence, minimal upper limits of individual crops and further requirements for use intensity must be given. The requirements for crop diversification hardly extend beyond the current status of agricultural practice. If existing standards for crop sequences, as for humus bal-ancing or in the baseline of agricultural environment and climate measures, are to be replaced through the diversification requirements, the danger even exists that the standards will be wa-tered down. Feed crop farms with a large portion of maize on the arable areas could then change grassland to arable land and in this manner fulfil the requirements for greening for crop diversifi-cation and ecological focus areas. This would especially be the case if grassland areas are not used sensibly or grass silage is substituted with clover or field grass.Maintaining permanent grassland Two aspects must be differentiated in the context of the CAP Reform with regard to the mainte-nance and promotion of permanent grassland. The first relates to the possibility to expand the definition limits of permanent grassland, the second deals with the protection of permanent grassland in the framework of greening. As described earlier, from a farm economic perspective, the conversion of grassland could be an attractive adaption measure to the requirements for crop diversification and ecological focus areas. The accelerated loss of grassland areas through unintentional interactions between greening components can only be prevented by a restrictive implementation of grassland maintenance on the individual farm level and/ or via comprehensive area specific maintenance requirements. In order to maintain the natural living spaces of wild animals and plant species, or rather to re-store them, it is absolutely necessary to prevent the conversion of permanent grassland to arable land in Sites of Community Importance and Special Protection Areas. The conversion prohibition should apply from a number of environmental concerns (biodiversity, climate, water and soil pro-tection) also for carbon rich soils and moor areas as well as flooding and erosion endangered are-as. The restoration of species communities of the species communities of species rich grasslands is a delicate task. Therefore, the ban of first ploughing is pivotal in those parts of the Natura 2000 network which are designated to the protection of communities of species rich grassland or spe-cies depending on such habitats. Many pasture areas that do not fall under the current definition of permanent grassland have significance in terms of species protection and the maintenance of tradition cultivated land-scapes. For this reason an extension of the definition of permanent grassland should be targeted. The requirements for good agricultural and ecological condition of agricultural areas should be adapted accordingly. Heath areas as well as pasture bushes and perennials should no longer be considered undesirable vegetation, but rather as typical and biodiversity-promoting parts of the supported areas. In addition salt meadows, oligotrophic grassland and moors and comparable areas should be included in the definition of permanent grassland.Ecological Focus Areas (EFA) With the requirements for ecological focus areas it shall be ensured that parts of the agricultural-ly used area are used in the interests of the environment. However, only little scientific evidence exists as to which parts of EFA are actually necessary for a positive impact on biodiversity. This holds true especially for agricultural development in the normal landscape, meaning outside of protected areas. In grassland dominated and structurally rich landscapes with extensive farming the EFA requirement will hardly play any role, since here no landscape changes are to be ex-pected. It is very likely that the number of existing elements is sufficient to fulfil the require-ments. An effect can especially be anticipated for regions characterized by intensive arable crop production. However, this is only the case if the national implementation excludes EFA on grass-land areas converted to arable land. In consideration of the relatively low, at approximately 5%, obligation for the provision of EFA, as well as the expected regional variability in the efficiency of the EFA, regionally oriented and strongly coordinated implementation is of high importance for the national shaping of the EFA. In this manner the biodiversity promotion impact could be in-creased. Here agri-environmental measures are on appropriate tool to enhance the quality and steer the placement of EFA. In addition, alternative instruments (for example, funding by founda-tions) should be taken into consideration especially if the remuneration by the second pillar payments is too low in comparison to the implementation costs Through an appropriate weighting of the different EFA options and the definition of upper limits for individual measures, the impact of these greening components can be increased. Valuable measures, for example like flower strips, are assigned a weighting factor of 1.5 according to the European Commission recommendations, while the catch crop areas are multiplied by 0.3. From the perspective of biodiversity, catch crops are over rated with the factor of 0.3. In order to pre-vent a pure windfall effect, an upper limit should be introduced for the calculation of existing and protects structural elements. A farm economic evaluation of the different options for preparation for EFA permits the following conclusions: (1) The costs for flower strips increase according to their width and the requirements for the type of growth (self-greening, special seed mixtures). Narrow border strips are generally a low cost option to fulfil the EFA requirements. (2) For farms with spring crops in the crop sequence, the planting of catch crops provides a budget alternative to fulfil the EFA. (3) Due to the assumed yield relations, local grain legumes are not a competitive option for fulfilling the EFA with the recommended conversion factors. Thus there are hardly impulses for the cropping of local grain legumes to be expected. An exemption is soy beans which could profit from greening. (4) Agro forestry systems and short coppice plantations are also an attractive option for many farms to realize the EFA, but due to the long term obligation for land use are accompanied by high risk.The options for collective or regional fulfilment of the EFA open possibilities to increase the effi-ciency of the greening components, as they reduce the farm costs to fulfil the EFA and / or in-crease the ecological value of the EFA. In an evaluation of the options, it must be considered that even without special regulations, farm adjustments will occur such that de facto a shift in the EFA obligations between farms and/or regions will occur. The practical implementation of collective and regional implementation schemes would face a number of challenges. The collective fulfil-ment can thus be tied to higher transaction costs for farmers than in the forming of bilateral leas-ing contracts. Efficient use of the regional options to prove the EFA requires high planning and administrative costs. Against this background, it seems to be necessary to consider more exactly whether a targeted fulfilment of regional environmental and biodiversity targets could not be more efficiently achieved with appropriate measures of the second pillar (for example, agri envi-ronmental measures or contractual natural protection) together with existing plans (biotope network planning, landscape plans, etc.).The promotional instruments with regard to biodiversity and their sanction mechanisms affect many interrelated levels. The greening is promoted by the first pillar of the CAP, while additional funding is available for agri-environmental and climate measure from the second pillar. Double promotion is not possible, which de facto causes lower funding for agri-environmental and cli-mate measure in the second pillar (for example for flower strips, Natura 2000 compensation.) Sanctions affect both non-compliant farms in promoted areas as well as the non–compliance with administrative law. In the case of a conversion from grassland protected as a habitat of community interest, the farmer may face a triple sanction in the form of the cessation of the greening component, a cross compliance sanction and a penalty due to violation of administra-tive law.


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