The EEB welcomes the evaluation of the impact of the CAP on water, but would like to point out the following gaps in the current roadmap.
First of all, it should include additional sources, such as reports and opinions by the European Court of Auditors (particularly the special report “Integration of EU water policy objectives with the CAP: a partial success”).
The evaluation should also address current gaps and missed opportunities which could easily reduce water pollution from agriculture. It should especially assess the extent to which improvements in water quality would have been achieved by the inclusion of the sustainable pesticide use directive and of measures to control phosphorus under cross compliance.
Likewise, the polluter pays principle is currently not applied by the CAP. Specifically, penalties for pollution do not equal the cost of the damage caused.
With respect to the “quantity of water”, the evaluation should assess rebound effects caused by measures trying to increase efficient use. In particular, RDP measures helping farmers to invest in more efficient irrigation systems are known to eventually increase overall water abstraction.
In that context, Art. 45 should also fall within the scope of the evaluation, since these other investments can be related to e.g. use of fertilizers or management of manure and thereby also have an effect on water.
Furthermore, the scope of the assessment currently excludes sectoral interventions (currently under the CMO). As investments for irrigation can also be financed through them, they should also be included in the evaluation.
Likewise, all RDP measures from all priorities should be included from a results-based perspective and with respect to their effect on water quality, quantity and hydro-morphology.
In addition to water quality and quantity, the evaluation should also include the impacts that agriculture and the CAP have on hydro-morphology, as many agricultural practices (such as dredging, bed and bank reinforcement, river realignment and impounding for land drainage, etc.) cause massive modifications of hydro-morphology.
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