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1 1 of 6 The Reform of the CAP towards 2020 Consultation document for Impact Assessment With reference to the European Commission s Consultation document for Impact Assessment and the Consultation Questions, Yara International (Yara) would like to submit following commentary. In the EU s consultation document, a number of broad challenges are identified, which the new policy scenarios will need to address. Yara will comment on a limited number of these challenges as they concern the business segment in which we operate. In general, Yara wants to underline the importance of promoting a healthy and competitive EU agricultural sector based on environmental responsibility. Both aspects have strategic implications for the long-term future of the agricultural sector. European agriculture can play a key role in securing global food security and addressing society s environmental concerns, including the mitigation of GHG emissions. We believe that through a combination of the use of fertilizers with the lowest carbon footprint, innovative technology and best agricultural practice, European farmers are able to increase food production and food quality, while at the same time reduce the environmental impact. 1) Modern Agriculture feeds the World ; Fertilizers Europe, ) Stanford study ; Burney et al, T:\agriculture_documentum\agriculture\cap-post-2013\consultation\contributions\yara.docx Postal Address Visiting Address Telephone Telefax Registration No. Yara S.A. Av. Marcel Thiry R.C. Bruxelles Avenue Marcel Thiry 83 B-1200 Brussels Telex Bank Account B-1200 Brussels hydro n COM VAT : BE Belgium

2 2 of 6 1. A sustainable EU agriculture is the only long term solution Only a competitive and profitable agricultural sector answering to the environmental concerns of society can be sustainable in the long run. EU policy should promote and financially encourage, best agricultural practices and where necessary institute and provide further fertilization training and educational programs for farmers, in order to mitigate unwanted effects of farming. EU should include a fertilizer management component in their Farm Advisory Services program, either as part of Pillar I to establish a green component, or as part of longer term measures of Pillar II. Fertilizer management programs should focus on agricultural best practice; the use of innovative technology, such as precision farming and sensor technology; the use of most efficient fertilizers with the lowest carbon footprint in order to improve nutrient use efficiency and reduce environmental impact. See attachment: 3) Use of Nitrogen Sensor technology ; Yara International 2. Global food security is also a challenge for the EU Yara underlines the fundamental role that mineral fertilizers play for the world food production and will have to play in the future if we want to meet the needs of a growing population. Continuing intensive crop production and even producing more food per hectare of arable land in Europe will reduce the need for food and feed imports into Europe and therefore help preserve the environment without turning more forests or virgin lands into agricultural land. EU farmers are among the most efficient, knowledgeable and productive in the world and can contribute to the global food security without placing an increasing burden on the environment.

3 3 of 6 For the same reasons EU should continue to support agricultural productivity in developing countries as well as a necessary component of meeting the Millennium Development Goals by ) Haber-Bosch paper ; Von Erisman et al, ) Von-Witzke study on land grabbing (2010) 3. Promote R&D and innovation within agriculture The technological aspects of agriculture are becoming increasingly important. EU should support farmers to adopt new techniques in order to use water more efficiently, to improve nitrogen use efficiency and to enhance nutrient uptake by plants and thereby minimize the environmental impact. Through new technologies such as the nitrogen-sensors, farmers are able to conduct precision farming, i.e. applying the correct nutrients, the correct amount at the correct time for optimal yield and minimal environmental impact. EU should support farmers with innovative and user-friendly mineral nutrient management systems, as part of Pillar I or Pillar II measures, which aim for economic optimal yield to secure crop production and optimize nutrient input to reduce environmental impact. 6) Sustainable Food Security ; Yara International

4 4 of 6 4. Agriculture can mitigate climate change and reduce environmental impact The latest reports from IPCC confirm that agriculture will play a key role in mitigating climate change, and must be seen as a part of the solution and less as part of the problem. Emissions from agricultural soils in the EU have been reduced steadily since 1990, while food production has increased. To further reduce emissions we recommend EU should introducing following measures: a) Promote the substitution of urea based fertilizers by nitrate based fertilizers. Although mineral fertilizers (both production and use) account for about 20 % of EU s GHG emissions from agriculture (about 500 Mt CO2 eq in 2005), a full substitution of all agricultural urea based fertilizers by nitrate based fertilizers would lead to an immediate reduction of over 7.5 % of emissions (about 7.5 million mt CO2 eq based on IFS, 2008) of mineral fertilizers. In addition this will lead to a significant reduction of ammonia emissions to the atmosphere, which have known detrimental effects on human health and environment (eutrophication of surface waters), as recognized by the UN Gothenburg Protocol, which has been ratified by the EU. Nitrate based fertilizers have a much lower carbon footprint than urea based fertilizers and offer in addition other agronomic and economic advantages to European farmers. Presently, EU farmers use over 2.5 million mt of nitrogen per year in the form of urea and UAN. b) Develop mechanisms (e.g. access for agriculture to the Emission Trading System), that will encourage and reward farmers to adopt methods to further reduce GHG emissions from agriculture. We propose to develop a European GHG Emission Protocol for agriculture in cooperation with all stakeholders.

5 5 of 6 c) Introduce a sustainability label for mineral fertilizers EU should consider the introduction of a sustainability label for mineral fertilizers, based upon the Life Cycle Approach (LCA) methodology, which will rank mineral fertilizers according to their overall carbon footprint. (Similar to the concept used for ranking household appliances according energy efficiency). A sustainability label will provide information and raise awareness to farmers about the environmental impact of the fertilizer product they plan to use, while at the same time diminish the risk for carbonleakage. 7) Mineral Fertilizer & Climate Change ; Yara International 8) Best Management Principles and Techniques to Optimize Nutrient Use Efficiency ; International Fertilizer Society / Fertilizer Europe. 5. Food quality can be increased through balanced plant nutrition We believe investing in sustainable agriculture and sufficient food production is a basic investment in human health. We underline the importance of balanced plant nutrition as a pre-requisite for healthy and quality food. As the future of crop production has to involve less use of water, more efficient nutrient use and less dependence on soil quality, balanced application of all necessary plant nutrients can make a major contribution towards food production and is the most effective way to ensure that crops and food contain all necessary minerals vital for human and animal health.

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