09/05/16 Letter to DG AGRI. on the inclusion of miscanthus in greening legislation

On Monday 9th, 2016, AEBIOM together with nine key stakeholders, sent a letter to the European Commission (DG AGRI) to include Miscanthus (Miscanthus x giganteus) in the list of elements to be qualified as areas under the CAP’s Ecological Focus Area (EFA) :

“The undersigned organisations welcome the Commission´s efforts to simplify the CAP rules, especially the initiative to examine the greening obligations announced by the Commission in its declaration of 2th April 2014 thoroughly evaluating the experience with the implementation of the obligations on EFAs after the first year of application.

The list of elements to be qualified as areas under Ecological Focus Area (EFA) has been established by Regulation (EU) No 1307/2013 and reflects the results of the political agreement on the recent reform of the common agricultural policy. Miscanthus (Miscanthus x giganteus) does not fall under any category of this list.
In particular, as regards Short Rotation Coppice (SRC) qualifying as EFA, SRC are defined pursuant to Article 4(1)(k) of the said Regulation as areas planted with tree species of CN code 0602 90 41 to be defined by Member States. Miscanthus (Miscanthus x giganteus) does not comply with this definition because it is not a tree, therefore it does not qualify as EFA.
In this framework, we would like to draw your attention on the positive contribution of miscanthus (Miscanthus x giganteus) to environmental protection in the agricultural landscape, while diversifying farmers’ income and developing the energetic autonomy of rural regions.

There are numerous contributions of miscanthus to environmental protection:

• This non-invasive crop is the most effective and sustainable biomass system in the prevention and fight against muddy runoffs.
• Installed as buffer strip along water streams, miscanthus acts as a screen, reducing fertilizer and pesticide pollution, thanks to deep rooting and the fact that the crop can be grown without fertilizers and pesticides.
• Popular with hunters, miscanthus houses diverse wildlife seeking shelter in winter.
• Last but not least, miscanthus restores soil organic carbon levels, affected by years of conventional cropping, and contributes to carbon sequestration in soils.

In addition, perennial crops such as miscanthus allow the consolidation and diversification of farmers’ incomes and the development of a green infrastructure contributing to high levels of environmental protection. The local production and supply of miscanthus can be used for energetic and materials uses, which develop the autonomy of rural regions and lower the greenhouse gas emissions of the communities.

Despite these numerous environmental qualities and their contribution to several European objectives (conservation and management of natural resources, climate change, clean energy, etc.), miscanthus suffers from a lack of recognition and support in the CAP.

We hope that these arguments will be granted your full consideration to make it possible to use harvestable miscanthus strips and plots as EFA in order to accelerate and simplify the installation of key green infrastructure components in the agricultural landscape.

We would be delighted with an opportunity to meet you to discuss this issue and share further scientific evidence with you and for any further information you may need.

Yours sincerely,”

The signatory associations: