RSPB response to CAP proposals

They identify that the paper suggests that the higher level environment schemes could be part of a LEADER bottom up approach rather than top down   .  The more general environmental  (ELS) would be part of pillar 1 and therefore a cross compliance arrangement.

http://www.rspb.org.uk/news/264664-eu-cap-proposals-green-rhetoric-must-not-become-green-wash