Effectiveness of the GAEC standard of cross compliance Prohibition of performing unauthorized land levelling on soil erosion control

The GAEC standard land levelling under authorization of cross compliance prohibits farmers from levelling land through bulldozing without a specific permission issued by the proper territorial authority. The aim of the standard is to ensure the protection of soil from accelerated erosion that almost always occurs when land is levelled without conservative criteria. Land levelling prior to planting or replanting specialized crops, especially orchards, is indicated by agronomists as essential to the full mechanization of cultivation and harvesting operations and the success of economic investment. Land levelling leads to a deep modification of the hill slopes, so it may produce serious damage to the environment if carried out in the absence of a carefully planned design. In other words, a design that takes the aspects of soil conservation into account, especially for steep hill slopes where the insite and offsite environmental impacts of soil erosion may be more pronounced. With regard to the areas involved, land levelling plays a key role on a national scale, one only needs to think of the vineyards planted on the country’s hill slopes, which in 1970 covered an area of 793,000 hectares. Moreover, despite the continued reduction in areas planted with vines, from 1990 to 2002 the area devoted to DOC and DOCG wines increased by about 29% and the average size of vineyards has also increased. This is a clear sign of the current trend, with the transition from the family model to the industrial model of orchard management, with extensive use of machinery and thus the use of bulldozers for levelling. The authorization topic, on which the standard of compliance is based, is analysed in detail. In summary we can say that, according to law, the permit required by the GAEC standard is currently mandatory only for those areas subject to the Hydrogeological constraint (Royal decree 30 December 1923 No. 3267) and for parks or other areas for which the regional regulations are more rigorous. Land levelling in other agricultural areas is excluded from the requirement to obtain prior authorization. Owners are only required to submit a DIA (statement of commencement of activity) to the Public Authority. However, permission is granted by law, in the event of lack of ruling by the Authority (implicit consent principle). This GAEC standard assumes that permission (where due) granted by the local authorities responsible for territorial governance is sufficient to avoid the damage that could be caused by land levelling. In other words, the standard does not dictate the agronomic rules to be followed in carrying out land levelling, but refers to already existing local rules and assumes that the authorization is granted on the basis of a detailed Environmental Impact Assessment (EIA). At the present time, only a few local governments take land levelling into consideration in their territorial governance legislation. In general, there is no rule requiring that the application for authorization be accompanied by a project containing the items considered necessary, in the present study, to enable the authorities to express well-pondered judgment. In addition, local territorial rules do not require the execution of land levelling and subsequent approval of the finished work to be carried out under the supervision of a geologist or a pedologist . At present, the GAEC standard is very weak, due to the lack of coordination between the provisions of cross compliance and territorial governance legislation focused on land levelling. It is common practice for the landowner, after obtaining permission, to assign the work to an earthmoving company with no expertise in soil protection and which possibly also has an interest in moving large volumes of earth. This may contribute to an increase in severe environmental damage. Land levelling, undertaken by virtue of a simple DIA and lacking environmental expertise, is very risky and can cause severe damage to soil resources and the landscape. This is particularly true in areas prone to hydrogeological risk or where the soil is thin or fragile in relation to some of its qualities or environmental functions. The results of some researchers on Italian case studies have shown the extent to which land levelling undertaken disregarding the rules of environmental protection can cause serious disturbance to the soil resource, resulting in impressive truncation or burial of the original soil profile, with severe reduction in land capability , even to the extent of desertification. Results showed that there was a drop in production, especially in excavation areas. Furthermore, changes in the quality of products and a general decay in the vegetative state of plants and water stress were observed. In one case study, land levelling performed before planting a vineyard determined excavation and accumulation thicknesses respectively up to 19 and 16 metres. In another case study soil erosion after land levelling reached values of over 300 Mg ha-1 (classified as catastrophic erosion). This value is far from the limits of a tolerable erosion of 6-11 Mg ha-1 year-1 currently internationally accepted. The proposals to update the GAEC standard are as follows: i) extension of the land levelling under authorization rule to include also land remodelling (light bulldozing following the removal of an old plantation, to prepare the land for a new plantation); ii) obligation to submit a geological and pedological feasibility study in order to obtain authorization.