I have, at last, found the time to watch Roger Harrabin's Newsnight special on the Common Agricultural Policy.

The overall message came through loud and clear: the policy is a huge taxpayer investment (some £400 p/year per family) but there are serious questions over what this money is actually buying.

The CAP has a dark past: grotesque over-production driven by production related payments and profound negative impacts on the environment and developing countries.

But the CAP has changed a lot in the last 20 years. A series of reforms has established a clear (if somewhat slow moving) trajectory towards reducing negative impacts (environmental and social). The policy now also uses a small proportion of its vast budget to reward land managers who produce environmental public goods, things like wildlife, healthy soils and water.

But as Newsnight revealed, attempts to further ‘green’ the CAP look set to be scuppered. And who’s responsible? Perhaps those pesky (and deep pocketed) vested interests who’d like the policy to stay largely as it is – lots of [public] money doled out with virtually no strings attached?

One key issue that Newsnight didn’t cover is that of modulation. This mechanism allows Member States to move money from Pillar I, which funds direct payments, into Pillar II, which funds things like agri-environment schemes and wider rural development measures. It has been part of the CAP for over 10 years.

The good news is that this flexibility will remain a part of the next CAP. Member States will be allowed to move up to 15% of their Pillar I budget into Pillar II and each of the UK’s agriculture Ministers will decide how much they want to move later this year.

But modulation is a hot political topic now and one which has raised the ire of a number of farming unions, here and across the EU (see here and here) who claim that it would put UK farmers at a competiveness disadvantage. Their latest contribution is to argue that modulation should be subject to mandatory co-financing by national treasuries – put simply governments would have to put their own money in too.

Now I’m all for extra money in Pillar II but co-financing is just not an option for most countries, including our own – we just don’t have the money. Perhaps the NFU and others have not noticed the economic downturn?  So in straitened financial times, I’d much rather have modulation without co-financing than no modulation at all. As would many farmers.

The fact of the matter is that without modulation Defra, and the devolved administrations, will not be able to invest properly in Pillar II schemes – schemes which not only reward farmers for producing environmental public goods but also help farmers to modernise, diversify, in other words become more competitive and market orientated – something Pillar I payments just don’t help them to do.  And without a well funded agri-environment programme, it is widely accepted that Defra will fall woefully short of meeting its ambitions in the Natural Environment White Paper and its own biodiversity strategy for England.

To a logical mind the modulation issues should be a no-brainer. It’s therefore extremely reassuring that Owen Paterson, Defra’s Secretary of State, is continuing to maintain such a firm position on the importance of moving money into Pillar II.

But rather than espouse the RSPB position, I think it would be more apt to quote one of the many farmers we work with – evidence that the big farming unions’ position on modulation is out of touch with what many farmers think.

“As an arable farmer in Suffolk and receiving high prices for wheat and other commodities I can afford to rely less upon direct payments from the CAP, of course I have always taken the view as a farm business I should not rely upon my single farm payment. I have many poor yielding areas of the farm that I have placed into arable stewardship options, making the best of this land for wildlife means I not only provide benefits for wildlife but also demonstrate I am good value for the public investment I receive. Therefore, I can only view a transfer of funds from pillar one at 15% to agri-environment budget as a good and sensible way forward. Taking out these less productive areas has little impact on yield, little impact on my ability to feed people but big impact on my farm sustainability. My agri-environment options produce a range of benefits but without or with reduced agri-environment funding I as well as other arable farmers have no market for this, which is quite different to how my single farm payment works.”

James Bucher, Hall Farm, Suffolk Arable Farmer

Here are the latest chapters in two salty stories: polyisobutene pollution in the English Channel and reform of the Common Fisheries Policy...

Yesterday, I shared on my blog a statement about the nasty, sticky substance polyisobutene (aka PIB), to be read at the International Maritime Organisation (IMO)’s current meeting of its environmental subcommittee. Due to delays in the agenda, the statement was delivered this morning. It will be formally included in full in the record of the meeting, which is an important first step in getting the status of this material reviewed, as well as bringing the recent PIB disaster to the attention of the full global maritime community.

In response, the UK Government highlighted work being done on the carriage of so-called “high-viscosity” substances, which would presumably include PIB, and highlight the need to wait until the results of the MCA’s investigations into the incidents are released.

Those responsible for releasing PIB into our seas must of course be identified and, if illegal, brought to justice. However, regardless of the eventual outcomes of MCA’s investigations, our view is clear: PIB should have no place in any quantity in our seas. This is why we joined forces with other NGOs and the UK shipping industry to call for an urgent review of PIB’s legal discharge status. If all PIB was removed at ports under strict controls, ships would have no legitimate reason to carry any PIB back out to sea.

There is no quick fix here.  It will take time to achieve a formal review of PIB at international level, and a review does not guarantee an ultimate ban.  But we have made good progress in a short amount of time, and have the support of key players in the maritime industry. 

This week has also seen 36 hours of talks by European Fisheries Ministers, as they made crucial decisions about reform to the Common Fisheries Policy.  The UK’s Richard Benyon fought hard for the radical reform needed, but key aspects of the plan have been watered down.  The discard ban – already long overdue – has been rolled back yet another year and will not start until 2015, and Ministers voted not to close gaping loopholes which will allow some discarding to continue.

The CFP is in desperate need of reform on bycatch, not just to revive our dwindling fish stocks, but other marine life killed as bycatch too.  Today a new study has revealed that a staggering 400,000 seabirds are killed each year in gillnet fisheries.  This number exceeds the estimated toll of bird deaths documented in longline fisheries.  This is the first time the massive scale of this problem has been laid bare - making it clear that urgent action is needed to tackle it.

This is not quite the end of the road – each member state will take their counter-proposals back to the European Parliament and try and reach a compromise. But there is no guarantee that MEPs will back proposals, which will further extend the protracted negotiations, and threaten any chance of the much needed reforms in 2013. 

If you want updates on either of these salty sagas, watch this space or please do follow our excellent safeguard our sealife blog.

While we await the full outcome of the meeting of European Fisheries Ministers (details remain patchy at the moment) attention turns to the International Maritime Organisation's environmental subcommittee.  Today, we have stepped up efforts to prevent pollution incidents such as the discharge of polyisobutylene which has had such a devastating effect on seabirds in the English Channel.

This morning, the following statement will be read out from the Clean Shipping Coalition... 

Mr Chairman, thank you very much for the opportunity to address the meeting this morning.

This year, over 4,000 seabirds have been recorded washed up dead or dying along the south coast of England, covered in the substance polyisobutylene, alternatively polyisobutene or PIB. This substance, when discharged into the sea, coalesces into a glue-like consistency, coating birds’ wings and bodies and preventing them from feeding or flying.

The impact on populations at sea is likely to have been far higher, possibly affecting up to 40,000 birds. The longer term impacts of releasing PIB on other parts of the marine ecosystem are currently not well studied or understood.

The cause of this tragedy is still being investigated. However, the exact origin of previous PIB incidents has rarely been found and to our knowledge there have been no successful prosecutions against breaches of the MARPOL Convention in relation to PIB.

Mr Chairman, Under Annex II of the MARPOL Convention, the various forms of PIB are classified as Category Y, where although it is deemed to be a hazard that justifies a limitation on its release, it remains legal for a ship to discharge PIB under certain conditions. 

It is our understanding, however, that the testing of these substances to determine Annex II classification does not take place in realistic marine conditions, and in PIB’s case does not sufficiently consider the full range of potential impacts of PIB upon marine ecosystems when mixed with seawater, beyond whether the substance floats or sinks.

We also simply do not know how much PIB is released into the marine environment as part of routine tank-washing operations, and the cumulative impacts of these chronic releases.

As such, Mr Chairman, it is our opinion that the risks of releasing PIB into the marine environment in any quantity are underestimated, both alone and with potentially corrosive cleaning agents, and that an urgent review is needed of PIB’s classification status under MARPOL Annex II, for presentation at a future meeting of MEPC. We are also concerned that when legal discharges of a harmful substance are allowed it becomes more difficult to stop illegal discharges, as ships have a legitimate reason for proceeding to sea with the waste on board.

This week, leading UK wildlife charities also signed a joint statement with the UK Chamber of Shipping, supported by the UK ports and maritime business sectors, strongly supporting such a review. There are copies of this statement on the table outside this meeting room and here at the CSC desk .

We would like to urge IMO Member States to respond swiftly to this serious issue and take a proactive approach to such a review.

PIB has no proper place in our precious oceans and seas, and we must ensure that the classification of PIB under MARPOL fully reflects its impacts on marine life.

Thank you very much for your attention.

You might be interested in this advert that will appear in today's paper.  It is timed to coincide with a crucial EU Council of Fisheries Ministers.  Our Biodiversity Minister has been leading the charge for radical reform of the Common Fisheries Policy and it is vital that his counterparts across the negotiating table realise the strength of public support for the stance he has been taking.  Read here to find out more and then (if you do this sort of thing) please show your support for Richard Benyon by tweeting for a strong CFP deal @RICHARDBENYONMP #CFPREFORM.

I don't know whether you manged to catch the Channel 4 News nature conservation special last night. I couldn't watch it all as the opening section was so dramatic that my boy ran out of the room screaming "I don't want the hedgehogs to disappear". I thought that was probably a rational response to the crisis we face.

Anyway, I promised an assessment of the environmental assessment of the Queen's Speech.  Sorry it's a day late.  And I cannot blame the sunshine this time.

There are four notable bills proposed and I thought I'd give a quick view on each.  I've given a "nature-rating" for each where 5 stars suggests that this could give nature conservation a great boost and 1 star suggests the interests of wildlife could be seriously undermined.

1. Deregulation Bill (**)
The Bill (which was unexpected) aims to “reduce the burden of excessive regulation on businesses”, in particular via the introduction of a “growth duty” on statutory regulators such as Natural England. While we strongly support the principle of identifying opportunities for more efficient and effective regulation, and agree that regulatory bodies should carefully consider the impacts that their activities have on those that they regulate, we are mindful of the considerable risks associated with a new duty that weakens the focus on safeguarding the natural environment.  As I wrote here, we need agencies to be free from political interference or requirements to boost short-term economic growth.

The ground-breaking 2011 UK National Ecosystems Assessment clearly highlighted the wide variety of significant benefits provided by the natural environment in terms of economic prosperity, human health and well-being; the risks posed to the delivery of these benefits through inadequate protection and management; and the importance of regulation in safeguarding and enhancing the delivery of key services.  Therefore, when regulators are faced with situations where protecting the natural environment may result in short-term costs to regulated bodies, we do not believe that economic factors should be given priority over social and environmental factors in deciding the best course of action.

I would have given this one star, but for the fact that the wording proposed for the duty "is have regard to" rather than "further" growth.  That said, we shall be looking to ensure the pre-legislative scrutiny considers the implications of this new duty on the role of agencies in protecting the environment.

2. Energy Bill (***)
The Energy Bill (which carries over in to this sessiono of Parliament) will introduce sweeping changes to the way the UK energy market is regulated and to how different energy sources, including renewable energy is subsidised. It aims to bring about the investment needed to replace the fossil fuel and nuclear power plants that are coming to the end of their operating lives, and to meet our renewable energy and climate targets. The Bill should have been a seminal moment for the ‘greenest government ever’, but instead it has failed to establish a clear commitment to a near-zero carbon electricity sector by 2030, in spite of overwhelming support from businesses and NGOs. What’s more, the complex changes that the Bill will introduce are causing confusion and a hiatus in investment in clean green energy, just when we need it the most.

I have given this one three stars because there is still a chance that this Bill steers us confidently down a path towards a low carbon future.  This will however require a change of heart from the Coalition Government. 

3. High Speed Rail (Preparation) Bill and the HS2 Hybrid Bill (The HS2 Preparation Bill will authorise expenditure to build a High Speed Rail network, while the Hybrid Bill will provide the Government with the legal powers to construct and operate the High Speed 2 railway. ) (***)
Few would argue that the UK's strategic transport infrastructure does not need improving. The question is whether HS2 is the right solution. There’s two tests it will have to pass before we would agree that it is. Firstly, it must reduce our greenhouse gas emissions. A report last year for the RSPB, CPRE and Campaign for Better Transport showed that this is by no means a given; it will only help the climate if its part of an overall strategy that ensures passengers are get out of their cars and planes and on to public transport, including HS2 itself. Secondly, the route must minimise any damage to wildlife.  Like many others, we are concerned about the damage likely to be caused to special sites for wildlife and want to see Government do much more to avoid impacts. Where impacts are unavoidable, however, we expect proposals that replace the losses on a like for like basis.  

4. Water Bill (**)
The Water Bill aims to “improve the water industry” by making the water sector more resilient to droughts and floods, increasing customer choice and encouraging investment and innovation. We are disappointed to see that Defra appear to have discounted a primary sustainability duty for Ofwat. Instead, they are promoting the idea of a resilience duty. This raises the question of what resilience is. At one end of the spectrum, resilience might be seen as a mandate to maintain business as usual in the face of ever greater economic, social and environmental pressure. At the other end of the spectrum resilience could mean building environmental and socio-economic limits into how we manage water, fundamentally changing the way we organise land management, water supply and demand controls. Where Defra sit on this spectrum will determine how useful the resilience duty will be for the environment, but it’s clear that if we continue to lurch from drought to flood, maintaining the status quo won’t be enough. The Draft Water Bill, which received pre-legislative scrutiny by the EFRA select committee, focussed on competition within the water industry as an end in itself, with no evidence that progress on abstraction licensing, water allocation and management will be accelerated. I fear we have some way to go before we can describe the way we manage our water resources as either sustainable or resilient - hence two stars.

That's it for this session of Parliament.  And then there's just one more opportunity for a five-star bill for nature before the General Election in 2015...