Kommentit komissiolle Pellolta pöytään -aloitteen tiekartasta

Suomen luonnonsuojeluliitto (Finnish Association for Nature Conservation) is the biggest environmental NGO in Finland.

We are looking forward to the Farm to Fork strategy, because the EU needs more integrated food policy. The whole food system should be revised: the targets should start from needs (customers, society) and go to production (CAP, CFP).

The current CAP and CFP are aimed at production – to produce more kilograms and litres. They don’t meet the needs of customers to get more healthy and sustainable food. More holistic approach can give more added value for farmers and fishermen, nature and environment, securing planetary boundaries of the nature and EU targets to halt the loss of biodiversity, to reach Good Ecological Status for waters and Climate Change mitigation and adaptation etc.

Deep connections to eviromental policies are essential. For example, in our country all the traditional rural habitats (meadows etc.) are threatened, agriculture is the biggest problem for our waters and the Climate Change emissions from agriculture are as big as emissions from car traffic. In the long run, you can’t have agriculture without working and resilient ecosystems (pollinators, soil etc.) and you can’t fish without sufficient fish populations.

The challenge in the timetable is that preparations for the next CAP programming period are far away in both the EU and Members States level, despite the EU budget is still not adopted. That is why more time is needed to include new targets of the European Green Deal, Biodiversity Strategy and the Farm to Fork properly into CAP preparations. Also the COVID-19 crisis can make more delays. For these reasons, the new CAP should start after two years delay – now planned one extra year is not enough. Without this extra time Member States don’t include new targets properly in their CAP strategies.

Farm to Fork proposal should be very radical and clear to make real impact to CAP or CFP/EMFF preparations. If even the EC proposal is a weak compromise, it can’t lead to real changes in the Member States. There should be clear quantitative targets and timetables. For example, if there are no binding numeric targets how to reduce pesticides, even our Goverment goes on business as usual – and they don’t develop agroecology etc.

Farm to Fork should lead to more deep revision of the CAP than Hogan’s proposal has been. The current CAP takes vast amount of money, but it produces lots of unhealthy and environmentally or ethically (animal welfare) unsustainable bulk food for consumers. However, even the farmers have problems because they don’t get just salaries for their work, because of bulk prices and their bad situation in the value chain from farm to fork. Environmentally CAP can be classified largely to harmful subsidiaries or perverse incentives. (The environmental problems can become even worse if the new EU budget is cutting most money from the 2nd pillar and enviromental measures.)

On the other hand, the current CFP is rather good and needs mainly better implementation (e.g. the target to stop overfishing by 2020 is not coming true because of too big fishing opportunities – TACs – for many species).

The EU has two good tools in Farm to Fork: in the EU Public Procurement rules and international trade agreements. Both of them should be used effectively.

The Commission should not accept poor national CAP or CFP/EMFF plans, if European Green Deal, Farm to Fork, Biodiversity Strategy or environmental targets are poorly implemented. However, there will not be much time and staff to check national plans. There are not many people in the Commission who can read Finnish or know about Finnish environmental problems. That is why it is important to evaluate environmental performance of Farm to Fork before decisions consulting also researchers and NGOs. Monitoring is essential, too.

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