COMMISSION STAFF WORKING DOCUMENT EVALUATION of the impact of the Common Agricultural Policy on climate change and greenhouse gas emissions
Date: 2021-05-21
Institutions: Directorate-General for Agriculture and Rural Development, European Commission
Subjects: European forestry policy, adaptation to climate change, climate change, common agricultural policy, environmental impact, farming sector, greenhouse gas, innovation, pollution control measures, reduction of gas emissions

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}  
 
 
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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 

1 

 
 
 
 
 
 
 
 
Glossary  

Agri-Environment-Climate Measure 
Areas facing Natural Constraints 
Common Agricultural Policy 
Methane 
Carbon dioxide 
CO2 equivalent 
European Agricultural Fund for Rural Development 
European Agriculture Guarantee Fund 
European Court of Auditors 
European Environment Agency 
Ecological Focus Areas 
European Innovation Partnership 
Environmentally Sensitive Permanent Grassland 
European Union 
Euro, Eurozone currency 
Focus Area 
Farm Accountancy Data Network 
Farm Advisory System 
Good Agricultural and Environmental Condition 
Greenhouse Gas 
Hectare 
Indirect Land Use Change 
Intergovernmental Panel on Climate Change 
Livestock Unit 
Land Use Change 
Land Use, Land Use Change and Forestry 
Measure 
Multiannual Financial Framework 
Nitrous oxide 
Non-Governmental Organisation 
Ammonia 
Research and Development 
Single Area Payment Scheme 
Small Farmers Scheme 
Statutory Management Requirement 
United Nations Framework Convention on Climate Change 
Voluntary Coupled Support 
Water Framework Directive 
World Trade Organisation  

AECM  
ANC    
CAP 
CH4  
CO2  
CO2eq  
EAFRD  
EAGF   
ECA 
EEA 
EFA 
EIP  
ESPG   
EU 
EUR 
FA  
FADN   
FAS  
GAEC   
GHG 
Ha  
ILUC   
IPCC   
LU  
LUC    
LULUCF  
M 
MFF 
N2O  
NGO 
NH3 
R&D 
SAPS   
SFS 
SMR    
UNFCCC  
VCS 
WFD   
WTO   

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  

3 

 
 
                                                           
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 Development10, 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 

4 

 
 
 
                                                           
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): 

rice (3C) (CH4); 

enteric fermentation (3A) (CH4); 

 
  manure management (3B) (CH4 and N2O); 
 
  managed agricultural soils (3D) (N2O); 
 
 

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

5 

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

115

110

105

100

95

90

85

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

GHG emissions from agriculture

Agricultural production volume index

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. 

6 

 
 
 
 
                                                           
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. 

7 

 
 
 
                                                           
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 

8 

 
 
 
                                                           
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. 

9 

 
 
 
                                                           
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. 

10 

 
 
 
                                                           
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. 

11 

 
 
 
 
 
                                                           
Table 1: The main climate-relevant CAP measures  

Measure (M)/instrument 

Objective in the Regulation 

Measures targeting 

Mitigation 

Adaptation 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Pillar I -  

Greening measure (permanent 
grassland ratio) 

Environmental benefits (carbon 
sequestration) 

Greening measure 
(environmentally sensitive 
permanent grassland) 

Environmental benefits (carbon 
sequestration)  

Horizontal measures/standards 

GAEC 4 (minimum soil cover)  Limit soil erosion, protect water courses and 
improve resilience against floods and water 
retention  

GAEC 5 (site-specific 
conditions limiting erosion) 

GAEC 6 (maintenance of soil 
organic matter) 

Prevent  the  direct  release  of  CO2  into  the 
atmosphere 

Farm advisory system 

Awareness  raising  about  farm  practices  and 
environmental and other standards 

Pillar II – Rural development 

M1: Knowledge transfer and 
information actions 

Spread  knowledge  and  improve  access  to 
information  

Improve access to advice 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

M2: Advisory farm 
management and relief 
services 

M4: Investments in physical 
assets 

Support provision of physical infrastructure 

Yes 

10  M5: Disaster risk reduction 

Support to reduce probable consequences of 
natural disasters; investments to restore land 
and production potential 

11  M7: Basic services and village 

renewal 

Investments  in  small-scale  infrastructure, 
(also renewable energy and energy saving)  

12  M8: Forest investments 

improve 

Extend  and 
resources 
(including  agroforestry)  as  climate-friendly 
land 
and 
management (resilience and fire prevention) 

investment 

support 

forest 

use; 

No 

Yes 

Yes 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

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 

15  M12: Natura 2000 and Water 
Framework Directive 

Support,  notably,  conservation  of  wetland 
and peatland 

16  M15: Forest-environment-

climate commitments 

Support  for  forest  land  and  thus  carbon 
stocks  

17  M16: Cooperation 

Support 
joint  actions 
environmental and climate benefits  

to  secure  greater 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Source: DG Agriculture and Rural Development  

12 

 
 
 
 
 
 
 
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  circumstances.  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). 

13 

 
 
 
 
                                                           
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. 

14 

 
 
 
 
                                                           
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%. 

the  crop  diversification  obligation 
In  2019,  74%  of  EU  arable 
(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 

land  fell  under 

37   Bulgaria, Czechia, Greece, Italy, Hungary, Netherlands, Slovakia, Finland and Sweden. 
38   Article 46 of Regulation (EU) No 1307/2013. 

15 

 
 
 
 
                                                           
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). 

16 

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

Measures 

Priority 4 

Priority 5 

EUR 
million 

% 

EUR 
million 

% 

Share of the 
measure 
programmed 
under 

priorities       
4 and 5 

M01 Knowledge transfer/information 
M02 Advisory services 
M04 Investments in physical assets 
M06 Farm business and development 
M07 Basic services and village renewal 
M08 Forest investments 
M10 Agri-environment-climate 
M11 Organic farming 
M12 Natura 2000 
M13 Areas facing natural constraints 
M15 Forest-environment-climate 
M16 Cooperation 
Total 
Source: DG Agriculture and Rural Development  

           363  
           305  
         2 119  

         1 398  
         3 055  
       24 021  
       11 549  
           808  
       24 226  
           286  
           427  
       68 558  

1% 
0.4% 
3% 
0% 
2% 
4% 
35% 
17% 
1% 
35% 
0.4% 
1% 
100% 

         125  
           62  
      4 767  
         146  
         258  
      2 487  
      1 193  
         131  
             7  
         221  
             3  
         208  
      9 608  

1% 
0.6% 
50% 
2% 
3% 
26% 
12% 
1% 
0% 
2% 
0% 
2% 
100% 

34% 
46% 
20% 
2% 
16% 
92% 
100% 
100% 
100% 
97% 
100% 
25% 
52% 

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; 

17 

 
 
 
 
 
  
 

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. 

18 

 
 
 
 
 
                                                           
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). 

19 

 
 
 
 
 
                                                           
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 homogenous 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. 

20 

 
 
 
 
                                                           
 

 

 

 

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. 

21 

 
 
 
 
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. 

22 

 
 
 
 
 
 
                                                           
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) 

ESPG 

EFA + ESPG 

Low 
Medium 
High 

Low 
Medium 
High 
Low 
Medium 
High 

Source: Evaluation support study  

19 
20 
21 

1 466 
15 764 
30 061 
1 486 
15 784 
30 082 

152 
4 005 
7 858 

0 
0 
0 
152 
4 005 
7 858 

0.0% 
0.7% 
1.4% 
0.3% 

2.8% 
5.3% 
0.3% 
3.5% 
6.7% 

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) 
Baseline 
Natura 2000 (measure 
12.1) 
Agri-environment-climate 
commitments (measure 
10.1) 
Organic (measure 11) 
Forestry (measure 8) 
Investments (measure 4) 
Total Pillar II Low 
Total Pillar II Medium 
Total Pillar II High 
Source: Evaluation support study 

CH4 

CO2 

N2O 

287 394 

38 677 

240 201 

0 

3 881 

0 

0.13 

170 

1 125 

0 
0 
13 
6 
13 
20 

0 
367 
0 
812 
4 418 
8 024 

874 
0 
0 
432 
1 999 
3 566 

%  reduction  compared  to  the 
baseline (net CO2eq.) 

0.7% 

0.2% 

0.2% 
0.1% 
0.0% 
0.2% 
1.1% 
2.1% 

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  circumstances,  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 
23 

 
 
 
 
 
 
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. 

24 

 
 
 
 
 
                                                           
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  

25 

 
 
 
 
                                                           
 
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. 

26 

 
 
 
 
                                                           
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. 

27 

 
 
 
 
                                                           
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%. 

28 

 
 
 
 
                                                           
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. 

29 

 
 
 
 
                                                           
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.  

30 

 
 
 
 
 
 
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. 

31 

 
 
 
 
                                                           
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. 

32 

 
 
 
 
                                                           
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. 

33 

 
 
 
 
                                                           
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  circumstances,  be 
beneficial  for  adaptation.  Furthermore,  the  measure  may  also  improve  resilience  thanks  to  the 
conservation, use and development of varieties more resilient to droughts. 

34 

 
 
 
 
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) semen; 

-  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 

35 

 
 
 
 
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 semen 
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. 

36 

 
 
 
 
                                                           
Figure 4: Innovation adoption rate per technological (red) and social (green) innovation (%)* 

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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 

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Source: DG Agriculture and Rural Development, based on Eurostat 

Number of dairy cows

Milk yield

‘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 

37 

 
 
 
 
 
 
 
 
 
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. 

38 

 
 
 
 
 
                                                           
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 

39 

 
 
 
 
                                                           
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.  

40 

 
 
 
 
                                                           
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. 

41 

 
 
 
 
                                                           
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).  

42 

 
 
 
 
 
                                                           
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 circumstances. 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 

43 

 
 
 
 
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 
the 
and  vegetable,  cotton  and  rice  sectors 
overexploitation  of  water  resources  in  the  region  but  also  brings  significant  social  benefits  in 
terms of employment. 

in  Andalucía,  whose  production  drives 

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.  

44 

 
 
 
 
                                                           
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.  

45 

 
 
 
 
 
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.  

46 

 
 
 
 
 
                                                           
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. 

47 

 
 
 
 
                                                           
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 
Reducing 
GHG 
emissions 

Energy 
efficiency 

Increasing 
removals 

Replacing 
emissions 

Climate 
adaptation 

P 

P 

P 

P 

P 

P 

P 

P 

N 

N 

N 

N 

N 

N 

N 

N 

N 

N 

N 

N 

R 
R 

R 
R 

N 
P 
R 

N 
P 
P 

N 
P 
P 

N 
N 
N 

N 
N 
N 

R 
R 
P 
P 

N 
N 
P 
N 

N 
N 
N 
N 

N 
N 
N 
N 

Voluntary redistributive 
payment 
Greening (crop 
diversification) 
N 
Greening (PG ratio) 
N 
Greening (ESPG) 
P 
Greening (EFA) 
Voluntary payment ANC  N 
Voluntary coupled 
support 
Small farmers scheme 
Cross-compliance 
Farm advisory system 
M1: Knowledge and 
information 
M2: Advisory services 
M4: Physical assets 
M5: Disaster risk 
reduction 
M6: Farm business and 
development 
P 
M7: Basic services  
M8: Forest investments 
R 
M10: Agri-env-climate  R 
P 
M11: Organic farming 
N 
M12: N2000 and WFD 
M13: ANC 
N 
M15: Forest-env-climate  R 
P 
M16: Cooperation 
M17: Risk management  N 
P 
M19: LEADER 
Score 
N  
P  
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 
48 

Meaning 
Not relevant (N) 
Partially relevant (P) 
Relevant (R) 

P 
R 
R 
N 
N 
N 
N 
P 
N 
P 

R 
R 
N 
N 
N 
N 
N 
P 
N 
P 

P 
R 
R 
P 
P 
N 
R 
P 
P 
P 

P 
R 
R 
P 
P 
P 
R 
P 
R 
P 

R 
P 

R 
R 

R 
R 

N 

N 

N 

N 

R 

P 

P 

P 

P 

P 

 
 
 
 
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).  

49 

 
 
 
 
                                                           
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. 

50 

 
 
 
 
 
                                                           
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. 

51 

 
 
 
 
 
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 

52 

 
 
 
 
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 

53 

 
 
 
 
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 circumstances.  

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  semen  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, 

54 

 
 
 
 
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 

85 https://ec.europa.eu/info/horizon-europe/missions-horizon-europe/soil-health-and-food_en  

55 

 
 
 
 
                                                           
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.  

56 

 
 
 
 
 
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  

57 

 
 
 
 
                                                           
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 homogenous 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 homogeneity 
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. 

58 

 
 
 
 
                                                           
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.  

59 

 
 
 
 
 
 
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  

60 

 
 
 
 
                                                           
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%). 

61 

 
 
 
 
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. 

62 

 
 
 
 
 
Figure 7: Which are the most important challenges for EU agriculture and rural areas? 

Farmers (n = 54706)

32% 

14% 

15% 

13% 

14% 

12% 

Other citizens (n = 74739)

22% 

12% 

32% 

23% 

7% 

5% 

Organisations (n = 23478)

31% 

13% 

16% 

13% 

15% 

11% 

Total (n = 152923)

27% 

13% 

23% 

18% 

11% 

8% 

0%

50%

100%

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

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? 

Farmers (n = 68153)

15% 

11% 

18% 

18% 

7% 

11% 

8% 

7% 

4% 

Other citizens (n = 76446)

7% 

8% 

30% 

16% 

4% 

6% 

5% 

9% 

14% 

Organisations (n = 29537)

15% 

12% 

18% 

19% 

7% 

11% 

8% 

6% 

5% 

Total (n = 174136)

12% 

10% 

23% 

17% 

6% 

9% 

7% 

8% 

9% 

0%

50%

100%

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)

Source: The 2017 public consultation on modernising and simplifying the CAP 

Figure 9: To what extent does the current CAP successfully address these challenges? 

70%

62% 

61% 

57% 

51% 

27% 

17% 

19% 

13% 

19% 

15% 

20% 

12% 

10% 

3% 

3% 

4% 

1% 

3% 

2% 

2% 

35%

0%

To a large extent To a fairly good extent To some extent only Not at all Don't Know

Source: The 2017 public consultation on modernising and simplifying the CAP 

63 

 
 
 
 
 
 
 
 
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?  

Farmers (n = 60278)

18% 

28% 

17% 

3% 

6% 

17% 

2% 

8% 

Other citizens (n = 76558)

9% 

27% 

28% 

8% 

2% 

7% 

1% 

20% 

Organisations (n = 25691)

19% 

27% 

17% 

3% 

5% 

19% 

2% 

7% 

Total (n = 162527)

14% 

27% 

22% 

5% 

4% 

13% 

1% 

13% 

0%

50%

100%

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

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?  

Farmers (n = 49981)

29% 

17% 

18% 

21% 

10% 

6% 

Other citizens (n = 55822)

17% 

13% 

37% 

17% 

4% 

13% 

Organisations (n = 21377)

30% 

15% 

18% 

20% 

11% 

6% 

Total (n = 127180)

24% 

15% 

26% 

19% 

7% 

9% 

0%

50%

100%

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

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%).  

64 

 
 
 
 
 
 
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? 

Farmers (n = 78762)

7% 

6% 

18% 

3% 

9% 

7% 

10% 

12% 

14% 

14% 

Other citizens (n = 106228)

4% 

2% 

17% 

1% 

19% 

12% 

3% 

17% 

15% 

10% 

Organisations (n = 33308)

9% 

7% 

17% 

4% 

10% 

8% 

9% 

10% 

13% 

13% 

Total (n = 218298)

6% 

4% 

17% 

2% 

14% 

9% 

6% 

14% 

15% 

12% 

0%

50%

100%

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)

Source: The 2017 public consultation on modernising and simplifying the CAP 

65 

 
 
 
 
 
 
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 
66 

 
 
 
 
 
(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%). 

67 

 
 
 
 
 
 
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 

Data collection tools 

Simulation 

Documentary 
research / 
Literature 
reviews / 
Statistical data 
analysis  

Questionnaire- 
based surveys 

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. 

To  draw  on  the  available  literature,  key  unpublished  grey 
literature and other datasets (statistical, etc.) to: 
- 
establish the counterfactual situation; 
-  map  Member  States’  and 

implementation 

regions’ 

- 

- 

- 
- 

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 
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. 

inform 

To identify any issues of coherence. 

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.   

Case studies 

Used to provide a detailed picture of CAP implementation and 
climate action in 10 Member States. 

Type of tool 

Relevant 
evaluation 
question 

Quantitative 

1-4 

All  

Qualitative 
& 
quantitative 

5,6,10  

Qualitative 
(because  of 
sample size) 

All 

Qualitative 
& 
quantitative 

Analytical tools 

Cost-
effectiveness 
analysis 

Coherence 
matrix and 
scoring 

Comparison of the benefits of a policy instrument with the costs 
involved in securing them. 

Quantitative 

7 

logics.  Standardised  approach  used  for 

Used  to  analyse  the  coherence  between  regulations  and/or 
intervention 
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  

68 

 
 
 
 
 
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. 

69 

 
 
 
 
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. 

70 

 
 
 
 
 
 
 
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) 

Greening crop 
diversification 

Greening permanent 
grassland 

Greening EFA 

Voluntary coupled 
support 

Small farmers 
scheme 

M1 Knowledge 
transfer/Information 

M2 Advisory 
services 

4 (CC, FAS, 
nitrogen-fixing crops 
(NFC) in VCS and in 
EFA) 

2 (CC and FAS) 

4 (CC, FAS, NFC in 
VCS and crop 
diversification) 

3 positive 
relationships for VCS 
for protein crops (CC, 
crop diversification 
and NFC options in 
EFA) 

6 (knowledge, 
training and advice 
can maximise the 
climate benefits 
potentially arising 
from M8, M7, M10, 
M15, CC and FAS) 
6 (knowledge, 
training and advice 
can maximise the 
climate benefits 
potentially arising 
from M8, M7, M10, 
M15, CC and FAS) 

M16 Cooperation 

4 (M7.2, M10, M15, 
M5.1) 

M4 Investments 

3  (M4.3 and M4.4 in 
particular can support 
the potential positive 
climate effects arising 
from M10, M15 and 
CC) 

M6 Farm/business 
development 

- 

M8 Forest 
investment 

4 (M1, M2, M15, 
CC) 

M7 Basic services 
and village renewal 
M10 Agri-
environment-climate 

3 (M1, M2 and M16) 

5 (M1, M2, M16, M4 
and CC) 

21 

18 

19 

18 

15 

19 

10 

10 

12 

14 

22 

16 

19 

14 

1 (FAS may be used by 
MS to advise farmers on 
climate issues which may 
help BPS recipients to 
mitigate their emissions) 

1 (VCS) 

1 (SFS) 

1 (SFS) 

1 (SFS) 

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 

3 (exemptions from the 3 
greening obligations) 

1 (FAS) 

- 

- 

- 

- 

- 

1 (VCS-livestock and 
M8.1-8.2 can contradict 
each other) 

7 (M2, M16, M4, M3, 
M11, M5, M17), 
depending strongly on 
MS/region’s 
implementation choices 

7 (M2, M16, M4, M3, 
M11, M5, M17),  
depending strongly on 
MS/region’s 
implementation choices 

7 (M1, M2, M4, M8, M3, 
M11 and FAS), depending 
strongly on MS/region’s 
implementation choices 

6 (M1, M2, M16, M3, 
M11 and FAS) 

1 (FAS) 

2 (FAS and M16) 

- 

1 (FAS) 

1  (VCS-livestock) 

3 (M3, M11 and FAS) 

71 

 
 
 
 
 
 
 
 
 
M15 Forest-
environment-climate 
M11 Organic 
farming 

M12 Natura 2000 

M13 Areas facing 
natural constraints 

M5 Risk reduction 

M17 Risk 
prevention 

Cross-compliance 
(CC) 

Farm advisory 
system 

Number of positive 
relationships 
identified 

6 (M1, M2, M16, M4, 
M8 and CC) 

1 (CC) 

1 (CC) 

1 (CC) 

1 (M16.5 can 
maximise M5.1 
impact) 

- 

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) 
6 (FAS must cover 
CC and the 3 
greening obligations 
and can maximise the 
benefits from M1 and 
M2) 

Number of  
neutral  
or no 
relationships 

Number of negative 
relationships identified 

Number of relationships 
identified as having 
mixed impacts 

16 

15 

22 

20 

19 

20 

8 

2 

- 

- 

- 

1 (potentially 
exacerbating negative 
climate impacts when 
VCS-livestock is 
combined with M13) 

1 (FAS) 

7 (M1, M2, M16, M4, M3, 
M10 and FAS) 

- 

1 (FAS) 

- 

- 

- 

3 (M1, M2, FAS) 

3 (M1, M2, FAS) 

- 

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  

72 

 
 
 
 
 
 
 
Table 8: External coherence of the CAP climate measures 

Greening 

EFA 

PG 

Diversifi
cation 

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) 

GAEC 1, 4 

GAEC 1, 4, 5, 6, 7 

 GAEC 5 

GAEC 1, 4, 5, 6, 7 

Policies/mechanisms/strategies  
aiming at: 

Mitigation of non-CO2 emissions  
  Nitrates Directive 

 

 

 

Emission Trading System 

Effort Sharing Decision 

Low-carbon economy roadmap 

  National Emissions Ceiling Directive 

Mitigation of CO2 emissions 

MI
TI
GA
TI
ON 

 

 

 

 

EU Soil Thematic Strategy 

Low-carbon economy roadmap 

LULUCF Decision 

EU Forest Strategy 

  Circular Economy Package 

Improved energy efficiency 

 

Energy Efficiency Directive 

Development of renewable energies  

  Renewable Energy Directive 

 

 

ILUC Directive 

EU Bioeconomy Strategy 

ADAPTATION  

 

 

EU Forest Strategy 

Floods Directive 

  Water Framework Directive 

INNOVATION  

 

 

EU Bioeconomy Strategy 

LIFE programme 

  Horizon 2020 

 

European Innovation Partnership 

Legend: Yellow = Neutral; Green = Coherent; Blue = Mixed 
Source: Evaluation support study 

73 

 
 
 
 
 
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 9: EU added value of CAP mitigation and adaptation measures 

Counterfactual 

EU added value 

to 
or 

MS would not  necessarily 
environmental 
attach 
direct 
conditions 
payments, 
replace 
EAFRD  measures  with 
incentives  to  address  EU 
climate  mitigation 
or 
adaptation,  through  land 
management 
and 
support,  or 
investment 
through  ‘soft’  measures 
such 
knowledge 
as 
transfer and advice. 

Yes, 
for 
mitigation 
there 
strong 
is 
evidence  of  the 
added  value  of 
the EAFRD.  

To 
a 
extent 
adaptation 
ambition, 
only 
EAFRD.  

for 

limited 
for 

but 
the 

Yes 

Potential 

A higher level 
of ambition for 
climate action at 
EU level 

action. 

CAP measures 
Mitigation:  only  the  EAFRD 
has  been  shown  to  foster  a 
higher  level  of  ambition  for 
climate 
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. 

the 

Adaptation: 
strategic 
planning  process  required  for 
programming  the  EAFRD  may 
have  stimulated  integration  of 
adaptation  in  rural  development 
programmes (RDP).   
funding 
Mitigation:  EAFRD 
rules  promote  the  use  of  agri-
environment-climate 
commitments  that  benefit  both 
mitigation 
adaptation 
and 
(particularly  for soil  and carbon 
protection).  These,  and  some  of 
also 
forest  measures, 
the 
contribute 
adaptation. 
to 
Theoretically,  the  EAFRD  has 
for 
considerable 
transboundary 
adaptation 
actions  in  both  agriculture  and 
forests,  but  data  is  lacking  on 
the  extent  to  which  this  has 
occurred. 

potential 

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. 

74 

Increased 
effectiveness 
through EU 
action 

 
 
 
  
 
  
 
 
 
 
 
Coordination 
gains 

Efficiency gains 

Legal certainty 
and policy 
framework 

Promoting 
complementarity 
and synergy 

Work by the European Network 
for Rural Development and EIP-
AGRI  has  promoted  sharing  of 
good practice relevant to climate 
action.  
The  flexibility  available  in  the 
design  and 
the 
allows  managing 
EAFRD 
authorities 
to  achieve  high 
levels  of  efficiency,  but  this 
potential  has  not  yet  been  fully 
realised. 

targeting  of 

environmental 

EAFRD 
land 
management  contracts  for  5-
7 years  provide  certainty  for 
contract  holders  or  between 
programming periods. 

None 

Yes 

None  

Yes, 
the 
for 
EAFRD,  but  the 
for 
potential 
environmental 
efficiency 
has 
not yet been fully 
realised. 

could 

choose 

MS 
to 
provide an improved level 
of certainty if they wished 
through 
(for 
longer  contracts  for  soil 
management). 

example, 

some 
for 
land 

to 

Yes, 
extent, 
EAFRD 
management 
contracts. 

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. 

risk  of  double 
More 
funding 
under 
combinations  of  national 
schemes  and  other  EU 
funds.  

Yes 

Source: Evaluation support study 

75