Proposal for a regulation of the Farm Sustainability Data Network
We are collecting comments on the proposed regulation for the conversion of the Farm Accountancy Data Network into a Farm Sustainability Data Network as of the new Council Regulation (EC) No 1217/2009.
The aim of the act is to streamline and expand data collected from farms to include social and environmental factors, as opposed to the primary economic focus of the FADN. This is stated to have benefits for statistical evaluation, relating to the following:
- CAP’s Integrated Administration and Control System (IACS) (meant to provide data-based control systems for CAP schemes),
- Integrated Farm Statistics (IFS) (provide comparable data on the agricultural holdings of the EU),
- CAP monitoring and evaluation framework (CMEF),
- simplification of the FADN data collection (not to lose the already existing database, ensure continuation),
- parallel data collection should be reduced and the total administrational burdens of farms must be aimed,
- remote sensing data collection should be taken place, especially by the European Space program (e.g. use of satellites, sensors measuring) and linking them with other available administrative data- collecting data remotely,
- distinguish between annual and periodical (every few years) data collection, as some variables may not need to be collected every year,
- reduce/limit financial costs of the data collection - administrative burden and costs related to their data collection (member states decision), and
- financial support to the Member States and farmers' potential future decisions.
The AGROMIX partnership welcomes some of the efforts of the new regulation, such as:
- minimising overlap in data collection
- embedding other EU-level data collection to FSDN and vice versa (IACS, IFS, CMEF)
- continuing data collection started in FADN, avoiding loss of long-term datasets
- a well-designed and explained process of formalising the new regulation
We, therefore, highlight the urgent need for the implementation of the regulation. Nonetheless, we also identified the following as shortcomings of the regulation:
- Data collection should be financed/subsidised at the EU level (not by the Member States), to ensure the actual implementation of the regulation.
- Regulation should also contain guarantees at the EU level to avoid differences in implementation (data collection) in each Member State.
- It is not well defined how the regulation will serve/match F2F and the Carbon Farming Initiative.
For the further improvement of the regulation the Partnership suggests the following basic recommendations (using FLINT indicators for the elaboration of the regulation in detail and see beyond):
- Clarify how gaps in socio-environmental data will be filled, how data will be transferred into respective collection systems, and solve GDPR issues. At present:
- Social objectives are not clear
- Labour conditions are not easy to provide
- Identified flows of products/more information on economic inputs/outputs are needed based on the farm scale
- Pesticide, herbicide, and nutrition used to be registered
Involve several already existing datasets, promoting their integration alongside national spatial data:
- The national census, FSS
- Parcel level registry systems
- Soil database
- Share all data on the IACS (Integrated Administration Control System) (solve the GDPR issues) and don’t keep information back!
- Avoid overlapping data collection as stated in the regulation, not as in FLINT indicators, and avoid multiple uses of the same data in different aggregated indicators to avoid multiplied errors.
- Avoid generic indicators, instead, use already existing datasets for these cases, and concentrate on specific indicators, even if follow-up studies are needed at the individual farm level
- Data collection might be needed beyond the actual farm to provide a broader context eg. of ecological connectivity, biodiversity status, target species status of the actual environment
- Habitat heterogeneity might be more important than the extent of semi-natural land cover when it comes to increasing general biodiversity. Therefore, the spatial arrangement of different land cover/habitats within the farm and between farms might be a very relevant factor, and probably relatively easy to estimate from remotely sensed data.
AGROMIX's specific recommendations:
Provide information on mixed system combinations, by a more detailed classification
There isn’t any data in FADN about agroforestry, so solving the remote sensing difficulty is crucial.
The proposal can be found here and is in its second feedback period regarding its adoption into the EU legislature.
If you wish to provide input/participate in the debate on the topic contact Dr Gabriella Nagy.