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equalisation would take place at the regional/<br />

Member State level only.<br />

So, where is the spirit of the leveling of<br />

the conditions of competition within<br />

the European Union? Did we not learn<br />

anything from the crisis that we are<br />

witnessing?<br />

Introduction of new – as I said – additional<br />

tasks for the CAP (including the restrictions for<br />

production practices) while retaining the present<br />

budget level shall lead to a restriction in the<br />

international competitiveness of EU agriculture<br />

and the moving of partial production outside<br />

the EU which would have negative consequences,<br />

i.e., environmental ones.<br />

Besides, I would like to emphasise that the<br />

scope of leveling of direct support among the<br />

Member States is insignificant and in fact the<br />

diversification of rates based on the historical<br />

intensity of production is maintained (although<br />

reduced). The project provides for only a partial<br />

reduction in the disproportions of payments<br />

amount among the Member States. There are<br />

no proposals guaranteeing the complete leveling<br />

of direct payments across the European<br />

Union based on flat rates which would be consistent<br />

with the Polish postulate that the area<br />

of arable land should be the only or basic criterion<br />

determining the amount of national envelopes<br />

(i.e. properly describing the potential with<br />

regard to food production and environmental<br />

protection). By the end of 2019, such leveling<br />

would take place at a regional/Member State<br />

level only.<br />

Also, it is unfavourable to abandon financial<br />

strengthening of the 2 nd pillar,<br />

which was an element of all existing<br />

reforms of the CAP and the favoured<br />

support method for the active development<br />

of EU agricultural and rural areas.<br />

I would also like to highlight the fact that<br />

moving certain functions and measures between<br />

the pillars as well as new components of<br />

the 1 st pillar will result in the obliteration of the<br />

currently clear allocation of roles between the<br />

1 st and 2 nd pillar.<br />

As a consequence, it will result in an increased<br />

complexity of the CAP, in particular<br />

within the 1 st pillar, inter alia, by separating the<br />

green component of payments, complex relations<br />

under the Good Agricultural and Environmental<br />

Condition (GAEC), green component of<br />

the 1 st pillar and agri-environmental measures<br />

of the 2 nd pillar.<br />

I can, however also notice some positive elements<br />

in the presented proposal. They include,<br />

undoubtedly, an improvement in the distribution<br />

of direct support among holdings of various<br />

sizes through the mechanism of degressive<br />

payment reduction – for large holdings (capping)<br />

and increase in unit support rates – for<br />

small holdings (the effect of lump-sum payment<br />

for small holdings).<br />

A step in the right direction is also to feature<br />

the role of small holdings in the European agricultural<br />

model and in the implementation of<br />

the objectives of the Europe 2020 strategy, in<br />

particular those regarding growth which is sustainable<br />

and favours creation of thematic subprogrammes<br />

under the RDP for this group of<br />

holdings. Lump-sum direct payment for small<br />

holdings and support for the diversification of<br />

income under the 2 nd pillar as well as instruments<br />

strengthening their market position are<br />

to be used for this purpose.<br />

It is also beneficial to extend the scope<br />

of the CAP toolbox by new measures<br />

which are complementary to the present<br />

instruments and respond to new<br />

challenges.<br />

I mean here, for example, new risk management<br />

instruments, extension of the scope of<br />

measures: support for producer groups and<br />

extension of certain market measures to all<br />

products.<br />

It is not possible to mention all the negative<br />

and positive elements of the so-called legislative<br />

package presented by the European Commission.<br />

Many of them certainly require further<br />

clarification and making them more specific.<br />

Certainly, the proposed solutions are not a reform<br />

of the Common Agricultural Policy to an<br />

extent which is necessary for European agriculture<br />

and besides they do not correspond to<br />

expectations. As Ministers of Agriculture, we<br />

gave voice to this during the debate of the EU<br />

Council for Agriculture and Fisheries in Luxembourg<br />

which was held on 20-21 October 2011.<br />

The proposal to exclude from production 7%<br />

Autumn 2011 5

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