Action needed for the EU Common Agricultural Policy to address sustainability challenges

Making agriculture sustainable is a global challenge. In the European Union (EU), the Common Agricultural Policy (CAP) is failing with respect to biodiversity, climate, soil, land degradation as well as socio-economic challenges. The European Commission's proposal for a CAP post-2020 provides a scope for enhanced sustainability. However, it also allows Member States to choose low-ambition implementation pathways. It therefore remains essential to address citizens' demands for sustainable agriculture and rectify systemic weaknesses in the CAP, using the full breadth of available scientific evidence and knowledge. Concerned about current attempts to dilute the environmental ambition of the future CAP, and the lack of concrete proposals for improving the CAP in the draft of the European Green Deal, we call on the European Parliament, Council and Commission to adopt 10 urgent action points for delivering sustainable food production, biodiversity conservation and climate mitigation. Knowledge is available to help moving towards evidence-based, sustainable European agriculture that can benefit people, nature and their joint futures. The statements made in this article have the broad support of the scientific community, as expressed by above 3,600 signatories to the preprint version of this manuscript. The list can be found here (https://doi.org/10.5281/zenodo.3685632).


Agriculture is the Main Driver of Environmental Degradation in Europe
Agricultural expansion and intensification are key drivers of biodiversity and ecosystem services loss (Diaz et al., 2019) as well as climate change (IPCC, 2019). His torically some agricultural practices supported biodiversity and multiple ecosystem services. Yet such practices have been increasingly abandoned or replaced by farming systems which maximize yields through unsustainable use of natural resources and at the expense of biodiversity and ecosystem services (Stoate et al., 2009). These processes are driven by socio-economic and technological forces but also supported by public policies. The European Union's (EU) Common Agricultural Policy (CAP; see Box 1) shapes the EU's agricultural sector (Hodge, Hauck, & Bonn, 2015) and supports a variety of practices contributing to wide-scale biodiversity loss (Gregory, Skorpilova, Vorisek, & Butler, 2019;Pe'er et al., 2014Pe'er et al., , 2019Van Swaay et al., 2019), climate change (Alliance Environment, 2019), soil erosion (Orgiazzi et al., 2016) and land degradation (IPBES, 2018). CAP programmes that could counteract these developments have been insufficient and/or underfunded (Alliance Environment, 2019; Pe'er et al., 2019). Furthermore, the current CAP is ineffective and inefficient also in addressing the social and economic challenges (ECA, 2016;Pe'er, Lakner, et al., 2017). The CAP has undergone several reforms, partly aiming to enhance its environmental and social performance. Some positive outcomes have been described (Batáry, Dicks, Kleijn, & Sutherland, 2015;Walker et al., 2018), yet effective measures are required to reverse negative trends (e.g. Pe'er, Zinngrebe, et al., 2017)-indicating the need of a much more fundamental change of the CAP to deliver on both environmental and socio-economic challenges. The CAP post-2020, as proposed by the European Commission in June 2018 (EC, 2018), acknowledges the need to address environmental and sustainability challenges and introduces a new Green Architecture and a delivery model that offers Member States (MSs) higher flexibility as to how they implement the CAP (see Box 1; Figure 1). The post-2020 CAP proposal is currently under final phases of negotiations.

Reasons for Concern
Analysis of the Commission's proposal indicates that it generally retains the structure and weaknesses of the current CAP (see also Pe'er et al., 2019). Key shortcomings include:

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Continuation of subsidies through area-based 'Direct Payments' (in Pillar 1) with low levels of environmental requirements. Area-based payments are inefficient both with respect to farmers' income and environmental aims, and their recent 'greening' has achieved minimal change in agricultural practice and environmental performance -only <5% of the area under greening has seen a change in management (ECA, 2017). Direct Payments are often passed on to landowners rather than benefiting those who manage the land (Hennig & Breustedt, 2018;WBAE, 2018), and attempts to cap the maximum allowable payments, and redistribute the funds to address their highly inequitable distribution, are likely to remain unsuccessful (Matthews 2018a(Matthews , 2018b. Moreover, the coupling of some Direct Payments to high-input production remains permitted despite strong evidence that Coupled Payments lead to market distortion (OECD, 2017), foster greenhouse gas (GHG) emissions and support practices with demonstrated negative impacts on biodiversity .
• Budget cuts for Rural Development Programmes (so-called Pillar 2), including Agri-Environment-Climate Measures (AECM). If designed and implemented well, these policy tools are the most effective in supporting proenvironmental farming practices (Batáry et al., 2015;Walker et al., 2018). Cutting the respective budgets, rather than reducing barriers to effective implementation (such as insufficient funding, high administrative complexity and insufficient incentives for uptake), are therefore counterproductive (CEJA et al., 2019).

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Misleading claims attached to insufficient climate action. The Commission's proposal states that 40% of the expenditures for Direct Payments and Support for Areas of Natural Constraints (ANC) will be labelled as 'climate-friendly'. Yet these instruments are not systematically linked to any effective measure for greenhouse gas reduction or climate adaptation, thus lacking any justification of this statement. Instead, they even partly support practices and sectors with significant greenhouse gas emissions (Alliance Environment, 2019; Pe'er et al., 2019). proposal also demands higher ambition from the MSs on the environmental performance compared to the current period (article 92 in EC, 2018). However, the proposal fails to list concrete measures that are known as essential for biodiversity and environment and thus should be prioritized by MSs, such as maintaining and restoring small-scale landscape features (see Harvey et al., 2020), buffer strips, fallow land, high-diversity grasslands, and at the landscape level, viability of High Nature Value farmland regions (Navarro & López-Bao, 2019). While flexibility for MSs and farmers to make their own choices is valuable for developing context-specific solutions, the experience of past and current CAP cycles is that a lack of clear requirements and evaluation criteria encourages a 'race to the bottom' where MSs 'compete' for the lowest requirements for their farmers' Direct Payments (Heinemann & Weiss, 2018;WBAE, 2018). The proposed 'performance bonus' (article 123 in EC, 2018), which should incentivize MSs to meet their goals, may adversely fuel such a race by incentivizing MSs to set easy-to-achieve targets from the onset.
• Insufficient set of indicators (Annex I of EC, 2018). The planned 'output' and 'results' indicators basically monitor the administrative and financial implementation of the CAP. The proposed 'impact' indicators mostly describe farming structures rather than actual impacts. They are insufficient for an effective monitoring of the CAP objectives and instruments and provide little guidance for policy steering. For example, there is a lack of indicators on farm management, land-use and land cover, environmental parameters and the economic performance of farming households WBAE, 2018). This stands in stark contradiction to the result-based principles that the future CAP is proposed to follow. Moreover, complex administrative burdens that are disproportionate to their simplistic contents, set major hurdles to ambitious environmental implementation by MSs (WBAE, 2019a, 2019b).

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Extending insurance instruments without a link to risk mitigation can promote unsustainable, risk-prone behaviour. Extending risk management tools (i.e. insurance; article 70 in EC, 2018) seems reasonable given the increased risks to farmers from market exposure, environmental degradation (partly due to overuse of resources) and climate change (especially extreme weather events such as heat, droughts and wildfires). Climate change also enhances sanitary hazards (through pests and pathogens) and phytosanitary hazards (through plant pathogens; Altizer, Ostfeld, Johnson, Kutz, & Harvell, 2013;Velásquez, Castroverde, & He, 2018). However, without requiring proper risk mitigation measures, insurance may promote risk-prone behaviour, that is, disregarding avoidable risks (Goodrich, Yu, & Vandeveer, 2020;Müller, Johnson, & Kreuer, 2017).
• Lack of consistency and transparency. The proposed CAP post-2020 repeats the heavily criticized procedure of restructuring and renaming CAP elements in a way that impedes learning and undermines transparency and legitimacy (Erjavec & Erjavec, 2015;Rutz, Dwyer, & Schramek, 2014), rather than conducting a deep reform. Previous reforms have failed to redesign or integrate existing instruments to improve the CAP's performance (Alons, 2017;Feindt, 2010;Pe'er et al., 2014Pe'er et al., , 2019Simoncini et al., 2019). Along the same line, the Commission's proposal for the CAP post-2020 retains vagueness in its guidance for implementation, thereby risking a dilution of ambition in implementation. On top of that, there are current pressures to water down further the environmental requirements set by the CAP. This can be evidenced in the amendments voted for by the European Parliament's Committee for Agriculture and Rural Development (COMAGRI, 2019), and in a draft proposal from the EU's Council (representing the MSs) which reduces or removes a range of environmental requirements (Council of the European Union, 2019). Both of these show that, as in the previous reform cycle, a closed institutional process is used to defend the interests of a few at the expense of many (Erjavec & Erjavec, 2015)-thereby, disregarding both public calls for decisive action on the environment and the robust scientific evidence indicating the need for a profound policy change (Matthews, 2017;Pe'er, Lakner, et al., 2017).

1.
Transform Direct Payments into payments for public goods, to align both environmental and socio-environmental dimensions of sustainability, given the poor performance of Direct Payments for both (Navarro & López-Bao, 2019). Most urgent would be the abolishment of Coupled Payments for intensive production systems with high GHG emissions but low delivery of public goods, and to diminish the distortion of markets (OECD, 2017). Transforming Direct Payments would allow using public funds in a more target-oriented way, be it as funds for Eco-Schemes, for gradual expansion of Rural Development, to improve support for multi-functional farming systems that are designed according to agroecological principles like organic farming and agroforestry (Lampkin et al., 2015), or to help protect High Nature Value farming systems (EIP-AGRI Focus Group, 2016).

2.
Provide sufficient support for effective climate change mitigation, aiming to reduce GHG emissions in the agricultural sector with a focus on improved nitrogen fertilizer application, rewetting of peatlands and improved GHG balances from livestock husbandry (WBAE, 2016). Insurance against climaterelated risks should be conditional on tangible risk mitigation measures for droughts, wildfires, floods, soil losses and GHG emissions, for example through relevant landscape features and proper management of vegetation and soil cover.

3.
Provide sufficient support for effective instruments to maintain biodiversity and ecosystems, aiming to halt and reverse ongoing declines in farmland biodiversity (Mace et al., 2018). This can be done by securing and enhancing budgets for AECM and Eco-Schemes and other environmental measures in both Pillars; restoring the pre-2009 requirements for Member States to set aside at least 10% of Utilized Agricultural Area for nature and semi-natural habitats; expanding support for low-input production without or with minimal chemical fertilizers or pesticides (e.g. organic farming), expansion and longer-term maintenance of fallow land  and extensive grazing on High Nature Value farmland; channelling support to efficient (so-called 'dark green') measures; and achieving a coherent and synergistic policy design across Pillars (e.g. Lakner, Holst, Dittrich, Hoyer, & Pe'er, 2019).

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Promote innovative approaches to design and implement measures addressing the environmental challenges, such as result-based remuneration of AECM (e.g. oriented to target species or habitats, Herzon et al., 2018), collective measures to support landscape-level management (see below) or the introduction of a points system to reward farmers for their ambition and/or investments, as also proposed by several farmer organizations (e.g. Neumann, Dierking, & Taube, 2017).

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Enhance spatial planning and collaborative implementation of landscapelevel measures, as such approaches have been shown to be successful with respect to environmental aims (Westerink et al., 2017). Policy 'experiments' are urgently needed, for both Pillars, to allow local targeting of management measures that can achieve a more effective delivery of public goods such as maintaining water quality (Jones et al., 2017;Lomba et al., 2020), reducing fire hazard (Moreira & Pe'er, 2018) and contributing to the EU's strategy on Green Infrastructure. Such approaches should entail longer-term contracts with farmers to improve income security and ecological benefits.

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Require MSs to set S.M.A.R.T. targets in their Strategic Plans (i.e. specific, measurable, ambitious, realistic and time-bound; Green et al., 2019) in order to fulfil all CAP objectives. This is essential for aligning the CAP with other national and international policies and commitments. MSs should be obliged to demonstrate how they address trade-offs between objectives (see Supporting Information in: Pe'er et al., 2019). This will require guidance by the Commission, as well as close monitoring of implementation and outcomes.

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Revise the set of indicators to ensure they are supported by the best available science and comply with the indicators of the Sustainable Development Goals (SDGs), the Convention for Biological Diversity (CBD) and the United Nations' Framework Convention on Climate Change (UNFCCC). Implementing a resultbased approach requires both result and impact indicators to be adequate and meaningful (Herzon et al., 2018). For example, well-established biodiversity indicators such as the Butterfly Grassland Indicator (Van Swaay et al., 2019) should be added to complement the Farmland Bird Index, and the indicator of High Nature Value farming should be maintained and improved. Opening the indicators' list to scientific evaluation and participation and clarifying the (currently non-transparent) process of updating the indicators would pave the way for future improvements of the indicator framework.

8.
Strengthen environmental monitoring and enforcement to ensure that CAP instruments lead to desirable results. Annual monitoring (e.g. using the EU's reporting system to account for yearly changes in land-use/cover and management) is imperative for evaluating effectiveness and efficiency, enabling policy makers and land managers to react promptly to developments, providing incentives and placing efficient sanctions in cases of infringements of the requirements. These data must be made open and freely available for science and independent impact evaluation, within a reasonable time. To reduce complexity, financial reporting and reporting for sustainability indicators should be separated.

9.
Identify and address global impacts of the CAP especially in the global South, to achieve a reduction of environmental leakage and global negative landuse effects as well as market distortions by EU agriculture, and to comply with the EU's principle of 'Policy Coherence for Development' (Article 208 of the Treaty of the European Union; EC, 2019a; Matthews 2018a, 2018b). The EU needs to strive for a better understanding of the impacts of its agricultural sector on developing countries' ability to meet the SDGs, and the roles of agricultural payments (Yang, Lupi, Zhang, Chen, & Liu, 2018) and unsustainable imports, especially of animal-derived products, feed and biofuel (Barthel et al., 2018;Matthews 2018aMatthews , 2018bSchulmeister, 2015). Beyond the CAP, strengthening international agreements and environmental governance systems, as well as communicating about sustainable consumption levels that reflect European and global capacity, are options here.

10.
Improve governance of the CAP and its reform in order to enhance transparency, accountability, participation and knowledge-uptake in line with SDG 16, and thereby regain legitimacy and public trust . This requires opening and enabling public scrutiny of data, CAP-reform negotiation documents and implementation data, throughout the policy cycle and prior to approval. Conflicts of interest in decision-making and implementation must be identified and managed, and a more inclusive participation enabled. A more proactive integration of all affected DG's in CAP policy formulation would facilitate more policy synergies and coherence.
Overall, the breadth of scientific evidence, best-practice examples, decision-support tools and sustainability assessments should be integrated more effectively into the CAP design and implementation, in a way that acknowledges and addresses the expectations of European citizens, the multi-functionality of agricultural lands, the diversity of affected stakeholders and all three dimensions of sustainability -social, economic and environmental.

Ambitious and Responsible Actions
Sustainability is a top societal priority and an urgent challenge. It is enshrined as a goal in the Treaty of the European Union (European Union, 2016). Given the documented poor performance of the CAP with respect to sustainability, business as usual is no longer an option. Urgent and efficient actions are needed to ensure environmental and social sustainability and long-term food security.
Transforming the CAP to help farmers adapt to the sustainability challenges would serve as a landmark for the new European Commission and the Green Deal, but it will require political courage to overcome a resistance to change. Despite a potential slow-down of the reform process, it is critical to reflect on the unequivocal scientific evidence behind the demands made by civil society to direct the CAP towards sustainability targets. We therefore call on the Commission, Parliament and Council to fulfil their responsibility toward current and future generations (Hagedorn et al., 2019) by ensuring a high level of environmental and climate protection, investing in healthy food and diverse landscapes and promoting rural vitality and citizens' well-being.
The scientific community stands ready to support the process with the knowledge and tools required for transformative changes, both at the national and EU levels, as personally indicated by above 3,600 signatories to the preprint version of this manuscript.  The CAP in a nutshell

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As one of the founding policies of the EU, the CAP was established in the Treaty of Rome of 1957, aiming to increase productivity, enhance farmers' income, stabilize markets and ensure food supplies and reasonable consumer prices. The CAP has been subject to numerous reforms and is currently undergoing another reform process. The CAP is now mainly an agricultural funding policy, with a budget of €58.4 bn./year (as of 2019), i.e. 36% of the total EU budget (EC, 2019c). It is divided into two 'Pillars'.
• Pillar 1 consists of income support and market measures. Income support is granted through different types of Direct Payments (€40.4 bn., 69.4% of CAP in 2019; Figure 1). Direct Payments are mostly paid per hectare and are conditional on compliance with various regulations including environmental aspects (e.g. 'Good Environmental Agricultural Conditions', or GEAC, in 'Cross Compliance'). Since 2014, 30% of Direct Payments are linked to three 'Greening' requirements, evaluated as mostly ineffective (ECA, 2017;Pe'er, Lakner, et al., 2017). €5.7 bn. of the Direct Payments is coupled to specifictypes of production, such as sugar, cotton, beef and veal, dairy, sheep and goats and protein crops. €3.0 bn. (5.3%) is for market support and stabilization.
• Pillar 2 refers to the Rural Development Programmes (€14.4 bn.; Figure 1), and includes instruments supporting rural areas (€8.6 bn.) as well as Agri-Environment-Climate Measures (AECM), payments for organic farming and Natura 2000 sites (€3.5 bn.). The latter three are regarded as ecologically effective (Batáry et al., 2015). Support for Areas of Natural Constraints (ANC, €2.5 bn.) has mixed environmental impacts (Oppermann, Beaufoy, & Jones, 2012).    Geijzendorffer et al., 2016) • Revise monitoring requirements together with scientists and relevant bodies to expand the extent and frequency of monitoring with respect to Cross Compliance, Eco-Schemes and AECM • Support development, testing and implementation of emerging technologies and approaches (such as remote sensing, citizen science, DNA-based methods) for data collection and analysis across all MSs (ECA, 2020) • Redesign the control and sanctioning mechanisms for putting greater emphasis on addressing potential environmental harm and less on mere 'formal' errors • Disconnect administrative reporting requirements (=outputs/results) from performance indicators on socio-economic and environmental impacts of the CAP