On October 12, the European Commission presented the legislative proposals for the revised Common Agricultural Policy (CAP) for 2013. After careful review, it is Slow Food’s view that the Commission has not managed to keep its promises to promote a more sustainable, equitable and fair CAP. In particular, while the proposals anticipate ways of supporting small- and medium-scale production, the overall formulation of the future CAP does not change the current scenario significantly and continues to favor big agri-businesses. At a theoretical level, the Commission emphasizes the need to create “a new partnership between Europe and its farmers”, to be able to best confront the serious challenges of our times: food security, the sustainable management of natural resources and the fight against climate change. However, beyond the declarations of principle, the framework outlined by the Commission lacks that paradigm shift that would benefit small-scale farmers - our most resilient food producers due their use of sustainable production techniques and their undeniable role in safeguarding biodiversity and the landscape. Renewing support for the agro-industry powers will prove disastrous. In the past decades, the industry has dragged Europe away from a model of sustainable and fair agricultural development, and towards a model that has brought devastating environmental exploitation, injustice for both virtuous farmers and consumers and a concentration of economic advantages in a few hands. The initial positive intentions for the CAP reform, expressed on many occasions by Commissioner Dacian Ciolos, have likely been hindered by the actions of the major agricultural lobbies and certain governments. In addition to the misguided basic framework, the proposals do not include in any significant way many of the suggestions made by civil society, nor do they seem able to contribute to responding to the many crisis factors that characterize the current food production system. It is important to emphasize that the goal of this reform process, as strongly demanded by civil society, must be to prepare European agriculture to tackle the challenges of the coming decades, to dismantle the domination of agro-industry and to promote a more sustainable and fairer agricultural model. It should not be to protect the anachronistic and damaging interests of a few. Slow Food will continue to follow the reform process closely, in an attempt to bring the post-2013 CAP back onto the path of environmental sustainability, fairness and quality. The following aspects of the Commission’s proposals for a new CAP concern Slow Food the most: Surface area as a criterion for the new basic payments: Though the abandonment of historical criteria should be welcomed, defining the new basic payments based only on surface area is disappointing. This system will continue to financially favor large-scale food production. Slow Food is not happy about the introduction of this measure, as it goes against the spirit of the association’s proposals, founded on a rethinking of the food system based on sustainable small- and medium-scale production. Lack of greening: One of the main changes civil society is demanding of this reform process is to make the European food system more sustainable, however the Commission’s proposals largely ignore this aspect. The most significant environmental measure included is the new “green payment”, which will take up to 30 percent of the resources available for direct payments. Courageous CAP reform would have required every cent paid out to be linked to the provision of important environmental services. The criteria on which the new green payment will be based do not include the essential practice of crop rotation. We welcome the Commission’s expressed intention to integrate the directives on water and sustainable pesticide use into the criteria soon, however stress that this integration must happen as quickly as possible. The new possibility for certain countries to divert a percentage of the funds destined for the second pillar to the first pillar is entirely negative in terms of the greening of the CAP. Equally deplorable is the lack of an increase in the resources available for agri-environmental measures under the second pillar. More generally, there is a lack of sufficient measures to stop the loss of biodiversity and to reach the target of halving the rate of biodiversity loss by 2020. Certainly the measure that requires leaving 7 percent of land as “environmental focus areas” is positive, but this alone can never be enough. Along the same lines is the measure aimed at maintaining permanent pastures and the consequent ban on converting them to agricultural production. In itself the measure is positive, but the protection will come into force only after 2014. In the intervening period, many of these pastures will almost certainly be converted to agricultural production. Price control and the fight against speculation: There is no doubt that one of the main problems with the contemporary food system is the dramatic volatility of prices. Instead of proposing market measures to help control price fluctuations, the Commission has chosen to propose ex post measures, aimed at compensating damages caused by price variations (see, for example, insurance programs). This approach seems paradoxical; it would be considerably more effective to try to avoid prices fluctuating so much in the first place, primarily by curbing speculation. Some of the proposals do not yet include enough information for a full evaluation: Measures to support small-scale production: Slow Food has long underlined the crucial role played by small-scale production in Europe. This is why it welcomes the proposed innovations, especially concerning the simplification that will benefit small-scale producers. However we question if the guaranteed support (between 500 and 1,000 euros a year per business) is sufficient. Definition of active farmers: The introduction of a definition of an active farmer was absolutely necessary, but the proposed definition seems too nebulous and vague. The following proposals, strongly promoted by Slow Food since the start of the reform process, are welcomed: Introduction of a ceiling on direct payments: Despite strong opposition, the Commission has proposed a maximum limit on the direct payments that each farmer can receive (up to a maximum of 300,000 euros). However, the threshold must be lowered even further. Partnership for research and innovation: It is positive that funding for research and innovation will increase. It is however necessary to ensure research also focuses on the integration between traditional wisdom and official science. It is also necessary to make sure the term “innovation” does not include clearance for GMOs. The attention to the exchange of intergenerational knowledge is also positive. New food production and distribution chain: It is positive that the Commission recognizes that farmers, at the bottom of the food production chain, find themselves in a weak and unprotected position. Also positive are the measures proposed to support producer organizations, inter-professional organizations and the development of short distribution chains (few steps and few intermediaries). Supplementary direct payment to young farmers: The Commission has shown that it has understood the urgency of the generational issue. While we could have expected more, the proposed measures are a good starting point to provide extra assistance to young farmers. Supplementary payment for farmers working in disadvantaged areas: Clearly farmers working in disadvantaged areas face many difficulties, so the Commission’s proposal to make supplementary payments to people working in these areas is welcomed. In conclusion, the proposals presented do not offer much hope for the future in their current state. In particular, the lack of consideration of ‘greening’ the policy is of great concern, especially since it is considered the main objective of this reform process by many. Furthermore, it is probable that some of the most innovative aspects of the proposals will be trimmed back following discussion in the European Parliament and the Council. There is a real risk that a proposal that from the start did not set out to be particularly bold and ambitious will find itself weakened to the point of being a “non-reform,” or, worse, a step backwards compared to the current situation. Slow Food will continue to publicize the CAP reform and mobilize to stop that happening, in the hope that this reform process can instead go down in history as having saved European agriculture.