The public consultation that ends today focused on incomplete information, insufficiently framed and grounded, and was marked by the absence of disclosure of the Ex-Ante Evaluation and the Strategic Environmental Assessment. The next few months will be decisive for improving PEPAC until the new government resulting from the next elections approves the final version, based on dialogue with the European Commission and national civic and political participation.
Today ends the 2nd Extended Public Consultation on the Common Agricultural Policy Strategic Plan (PEPAC) promoted by the Ministry of Agriculture, which will determine the destination of more than 6 billion euros in Portugal in the 2023-2027 programming period. This plan should thus consist of a structured set of interventions (measures) solidly based and consistent with each other, indicating the individual budget allocation.
But, contrary to what the title suggests, the object of this consultation is not the PEPAC, but rather a panoply of scattered elements, from which stand out dozens of separate intervention sheets, many of them incomplete, and a Financial Plan. Its coherence is not explained, the consultation is made without the framework of a text of presentation and rationale and, also, is not accompanied by an updated diagnosis, nor of the Ex Ante Evaluation, already completed, but of which the content and whereabouts are unknown, nor of any reference to the legally required Strategic Environmental Assessment.
hus, the PEPAC that the Government will send to the European Commission in January 2022, by regulatory imperative, will always be provisional and not legitimized by an adequate Public Consultation from the formal point of view or a genuine dialogue with all stakeholders The Civic Coalition Participate in the PEPAC argues that only the next Government will be in a position to present the PEPAC of Portugal valid for political negotiation with the European Commission, and when it is in office.
Only then will there be enough time to prepare a well-founded PEPAC proposal, subject to public debate and better able to meet the needs and expectations of Portuguese society as a whole, and in particular of farmers, forestry producers and rural territories, in its plurality, regarding the environmental, social and economic performance of national agriculture and forestry.
Consistent with its mission, the Coalition maintains the determination and commitment to promote civic participation in the preparation of the PEPAC, in dialogue with society as a whole and the organs of sovereignty, in particular with the Government and other institutions responsible for preparing and presenting the PEPAC to the European Commission.
The time horizon we have ahead of us is a few more months. We will do what we can so that this period is used to build a better PEPAC, legitimized by a broad civic participation.
Priorities and agenda
The Coalition embarks on this new cycle anchored in the heritage of its 28 member organizations and in the learning resulting from four months of shared activity. And also supported by the extended network of dialogue and cooperation relationships established with the Assembly of the Republic, the Government and Public Administrations, the Confederations and other Agricultural and Forestry Organizations, the Communities and Institutions of territorial base and other partners interested in this common cause.
We intend to take a position and promote information and public debate on all the contents of PEPAC. But we act within the framework of the 10 priorities we have defined for PEPAC (see document with the coalition's priorities here) and guided by three fundamental political concerns:
Our immediate agenda for action on each of these three key issues is as follows.
Right to information and duty to inform
The information made available in the Public Consultation is neither sufficient nor adequately framed and reasoned. Under the Aarhus Convention (on access to information, public participation in decision-making processes and access to justice in environmental matters, and which will also apply to PEPAC given the environmental impact of agriculture) and the Law of Access to Administrative Documents, we will seek to ensure the right of all citizens to access complete information on the PEPAC, the duty of the State to adequately inform its citizens, and the duty to hold public consultations with a duration adequate to the volume of information made available (11 working days to analyze information regarding the application of more than 6 billion euros... ).
Right to question and answer and duty to accept to be questioned and answer
The Civic Coalition has based its actions on dialogue with the Ministry, and with other stakeholders in PEPAC. Unfortunately, the government has not fully reciprocated, failing to maintain dialogue with the Coalition or respond to its requests for information, or to provide information it had previously promised. The Coalition remains fully available to engage in a constructive dialogue about the rationale and options for PEPAC, and how it can be improved to meet the real needs of the country.
Today, we sent a letter to the Minister of Agriculture requesting, as a matter of urgency, access to information necessary to understand the reasons for the Government's decisions on the Strategic Plan for the Common Agricultural Policy 2023-27. It is essential that all citizens have equal access to the information necessary to form an opinion and participate in the construction of the PEPAC. It is an ethical imperative, of legitimacy and even legality.
Commitment to fighting exclusion and discrimination in access to CAP support
It is public knowledge, and was finally unequivocally acknowledged by the Minister of Agriculture at the hearing in Parliament last November 23rd, that many thousands of farmers and large swathes of the country are excluded or underprivileged in access to CAP support.
The proposals that have been submitted to public consultation do not provide an adequate response to overcome this unacceptable situation, postponing until after 2027 the opening of the basic payment scheme to all farmers on an equal footing. This would also be essential to "leave no one behind" in the CAP's political objective of making a real transition in agriculture towards greater sustainability.
Some Members of the Civic Coalition will participate in the extended consultation individually or in joint positions.
The Coalition, in cooperation with various public departments, farmers' organizations and other social and political partners interested in contributing to a fairer and more effective distribution of CAP support for better environmental performance, will present an in-depth diagnosis of current inequalities, environmental shortcomings and their consequences and propose a set of remedial measures to be integrated into the PEPAC.
6 of December of 2021
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