EU 2013 Policy Priorities Agriculture, Food & Fisheries

Page 1

EU 2013 Policy Priorities Agriculture, Food and Fisheries

(fish processors), Eurocommerce (Carrefour, MacDonalds...), Food Drink EU (food companies), ARC2020 (good food march campaign), Ocean2012 (NGOs coalition), Greenpeace EU, WWF EU.

I.

Agriculture: Reform of the Common Agricultural Policy

1. Summary Common Agricultural Policy: Key terms

This report outlines the main policy proposals the EU institutions will be putting forward in the field of agricultural policy throughout 2013. The report offers a brief overview of the stand points of the European Greens on these specific policies, and points to the national contexts where these policies are likely to stir most discussions. This report is researched and drafted by Clarisse Heusquin and is current as of April 29, 2013.

Overview Relevant Commissioners: Dacian Cioloş (Agriculture and Rural Development, Romania, independent), Tonio Borg (Health and Consumer Policy, Malta, EPP) & Maria Damanaki (Maritime affairs and Fisheries) Relevant EP Committees: Agriculture and Rural Development (AGRI), Environment, Public Health and Food Safety (ENVI) & Fisheries (PECH) Main Green actors in the European Parliament: AGRI: José Bové (France; Vice-Chair of EP Committee), Martin Häusling (Germany; Greens/EFA Coordinator) ENVI: Carl Schlyter (Sweden, Vice-chair of EP Committee) PECH: Isabella Lövin (Sweden; Greens/EFA Coordinator) Main Lobbies: COPA COGECA (farmers’ union), AIPCE

In addition to offering a job market to 40 million European citizens, agriculture is the main manager of our natural resources since it covers half of the EU territory. EU Agricultural Policy, originally designed to ensure a secure supply of affordable food for Europe, has long been and remains one of the key policy focuses of the EU. In the 2007-2013 period, the Common Agricultural Policy (CAP) represented 34% of the EU budget whilst previously it had peaked at 70%. The latest negotiations on the EU’s budget 2014 - 2020 inside the European Council pointed to a reduction of the CAP spending by 13% compared to the previous budget period. In the meanwhile however, the European Parliament (EP) rejected this EU budget proposal; therefore exact numbers for the likely funding available for the CAP are currently unknown. The CAP is divided into 2 pillars: The 'first pillar' supports farmers' incomes, providing direct payments and market interventions (e.g. intervention buying and export subsidies) and is funded by the European Agricultural Guarantee Fund. The 'second pillar' is dedicated to the development of rural areas and is cofinanced from the European Agricultural Fund for Rural Development. Direct payments: These are payments made directly to farmers in order to support their incomes. The 1992 CAP reform introduced them and reduced by contrast the price support which guaranteed the prices at which farmers sold their products on the market. Decoupling: In 2003, direct payments were decoupled from production and a number of new mechanisms were introduced, such as cross-compliance, financial discipline, farm advisory services and good agricultural and environmental conditions. The majority of direct market aid was converted into a single farm payment


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

(SFP) which was not anymore based on the production but corresponds to the aid received during a past reference period and the number of hectares cultivated. Cross-compliance ties some EU support for farmers to complying with standards of environmental care and public/animal/plant health and animal welfare. How are CAP subsidies distributed? The European Commission does not directly give subsidies to farmers, but the relevant budget allocations are distributed to Member States, who then allocate individual subsidies to farmers. The sizes of “national envelopes” are usually decided in the European Council summits, during the period of EU budget discussions. This implies that payments rates are different per Member State. These differences are not always based on rational criteria, but also on political bargaining, and thus can be quite intransparent. EU rules do not stipulate how Member States sub-divide their allocations, either. Again, the process is not fully transparent: for example, for direct payments to farmers, the UK currently receives €3.65 billion a year, which means €229 per hectare of land. Of this, Scotland, for example, gets €596.6 million, the equivalent of €130 per hectare. The EU average is €268 per hectare. To sum up, until now, the levels of payments obtained by farmers, by regions or by Member States could differ significantly. Common Agricultural Policy: history The CAP is due to be reformed by 2013 addressing concerns about its overall cost in the EU budget, its sustainability and the unequal distribution of its direct payments between older and newer Member States and between eligible entities/farmers of a same country. For the first time, CAP reform will be voted through the codecision procedure with equal powers for the European Parliament and the Council in the 2013 reform. Furthermore, the vote in the Council will be taking into account the positions of 12 new Member States who in previous reforms were not yet EU members, in a general context of growing food products’ prices. CAP reform process After having issued a Consultation in 2010, in October 2011 the European Commission came out with 7 proposals of regulation and a proposed budget under the Multiannual Financial Framework 2014-2020 (€371,7 billion over 7 years) for the future CAP. In the European Parliament, the two biggest groups - the EEP (European

2

People’s Party) and S&D (Socialists and Democrats) groups – managed to get all the reports in relation to the 7 regulation proposals, avoiding attributions of reports to other groups, such as the Liberals or the Greens, perceived as drivers of more radical reform. The novelties of the Commission’s proposals included: > a fairer, better targeted, simpler and more transparent support to farmers' income regardless their country or their region; > green criteria (crop diversification and maintenance of permanent pasture) as a precondition for 30% of direct payments; > the creation of tools to address crisis management (insurance) > an increase of the budget for agricultural research and innovation; > new incentives to encourage agri-environmental initiatives, facilitate the establishment of young farmers, develop rural employment and entrepreneurship. Given the huge needs for reform the Greens were still disappointed by the content of the proposals and criticised the lack of ambitious measures which would ensure a real sustainable and fair reform of the CAP. The main Green criticism was that the reform proposed by the European Commission would not redress a distorted system of payments which still benefits mostly large farmers and the agro-industry instead of prioritising support for smaller farmers and local food systems (see Greens/EFA press release here). Despite the already weak proposal from the European Commission, the Agriculture Committee in the European Parliament further weakened especially the greening requirements and softened progresses towards a more equitable distribution of the direct payments proposed by the Commission, according to the Greens (see below for Green response). In its amendments to the Commission’s proposal the Parliament argues for (see EP’s explanation here): >

Only paying subsidies to “active farmers”, with a list excluding certain entities such as airports and golf clubs as eligible. However, MEPs voted for the precise definition of “active farmers” to be decided by Member States and not by the European level, which means that each Member States can adapt or extend the list according to other considerations than making the CAP more equitable.


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

>

Basing the payments received by all farmers in any given Member State on a uniform payment per hectare in 2019. MEPs added that the payments could nonetheless in special cases deviate from this average by up to 20% in order to avoid sudden sharp falls in support.

>

Implementing a set of measures ensuring that farmers receive at least 55% of the EU average payment per hectare in 2014, and 75% in 2019 (reducing the difference between farmers in different Member States).

>

Capping direct payments for farms at €300,000 and making them degressive from €150,000 per holding in order to stop favouring the big farms.

>

Tying 30% of direct payments to performance on three environmental measures: crop diversification, maintaining permanent pasture and grassland and creating ecologically-focused areas.

>

A requirement of land fallow of 3% from 2014, rising to 5% in 2016 (instead of 7% proposed by the EC) that farmers must comply with in order to qualify for a portion of their direct subsidies.

>

Requiring farmers with holdings of 10 ha – 30 ha of arable land to plant at least two different crops (rather than requiring three crops for all farmers cultivating more than 3 ha, as proposed by the Commission).

>

Requiring farms of more than 30 hectares of arable land to cultivate three crops with the main one covering not more than 75% and two main crops together not more than 95% of the arable land.

>

An additional 25% payment for young farmers (under 40 years old), but for a maximum of 100 hectares (rather than an average-sized holding) to attract youngsters into farming and rural areas.

2014-2020 negotiations. The deal reached inside the European Council on the 2014-2020 MFF at the beginning of February 2013 also weakens the CAP reform in so far as: > The overall budget allocated to the CAP should be reduced in real terms by 3.4%. > CAP spending should be reduced by 13% compared to the 2007-2013 period. > Member States are permitted to use up to 25% of the money allocated through the CAP for rural development to fund direct payments. This flexibility aims at alleviating the reduction of the CAP budget. > Flexibility for national governments is increased: governments would be able to define specific environmental conditions themselves for the three specific environmental criteria conditioning 30% of direct payments. For example, the proposal of setting aside 7% of arable land for biodiversity must be implemented “in ways that do not require the

land in question to be taken out of production and that avoids unjustified losses.” Especially the last choice would imply that good environmental practice would depend on the practice adopted by each national government. Following these decisions, the Council concluded a general agreement on the CAP after the final vote on the legislation in the EP plenary session on March 19th 2013.

2. National considerations Traditionally, EU agricultural policy has been one of the areas of greatest division between Member States, in part due to the huge proportion of the EU budget it makes up, and the disproportionate benefits it yields between the Member States. Key positions: >

Germany and “the gang of five” (UK, Sweden, Denmark, The Netherlands and Malta) are in favour of large cuts for the next CAP budget. The “gang of five”, led by the UK, is traditionally in favour of a more liberal and competitive policy. Germany is preoccupied by material interests as it is the major net contributor to the EU budget.

>

Led by France, Spain, Greece, Ireland and others are more resistant to cut the budget on CAP, to reform direct payments and to

The Parliament approved a Commission proposal to make public the names and municipalities of those receiving direct payments or money from rural development programmes. Inside the Council, the CAP reform strongly depends on the on-going EU Multiannual Financial Framework (MFF)

3


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

implement the environmental conditionality. They are for status quo as they benefit a lot from the current distribution. >

Poland and new Members States support a more rational distribution of subsidies between Member States as criteria such as the wealth of the country are not currently taken into account.

In the European Council of February 2013, when EU budget was negotiated, Germany and the gang of five obtained a big cut, while France preserved its own interests in the negotiations in the Council: if the CAP budget decreased by 13%, subsidies for French farmers only decreased by 3%. French President François Hollande recognised that France keeps this level of aid at the expense of others countries which see their subsidies diminished. In the agreement reached on March 19th 2013 by the Council, decisions taken at the European Council have been confirmed. Ministers of Agriculture approved the increase of flexibility on convergence of direct payments at national or regional level by allowing member states to move towards partial rather than full convergence by 2019 and to limit the first convergence step to 10% of the national or regional ceiling. They also agreed on flexibility of funds between pillars. About greening, they outlined in more detail the progressive application of the crop diversification requirements and clarified the exemptions to that requirement, as well as adjusted the scope of 'equivalent practices' that they added (practices which yield an equivalent or higher benefit for the climate and the environment compared to the greening practices proposed by the Commission). Negotiations on the final legislation between the Parliament, Council and Commission have started on April 11th 2013. There will be around 40 meetings in which they will attempt to agree on the final shape of the CAP 2014 – 2020. It is currently anticipated that a final political agreement will be reached ahead of the Council of Ministers meeting on June 24th 2013 in Luxembourg. Main topics still in discussion include capping of direct payments, young farmers, rural development, redistribution of payments within and between Member States, and coupled support.

3. Green Response After the plenary vote on the CAP reform in the European Parliament, Green MEP and vice-chair of the EP's

4

agriculture committee, José Bové stated: "MEPs have

today voted for the CAP to plough ahead unsustainably, with an outcome that is even worse for the environment than, and just as unfair as, the current model.” Greens are very critical of European agricultural policy, seeing it as favouring large producers and intensive production techniques at the cost of smaller farmers and organic and low stress farming. Greens’ views on the CAP reform are based on three principles: fairness, sustainability and quality. Fairness: Resulting from history and trade-offs among Member States, EU agricultural policy is neither fair among Member States nor among producers/farmers. For example, 20% of farm holdings still receive 80% of all direct payments under the CAP. Greens call for a fair spending of public money. Greens are in favour of a level ceiling of €100000 for direct payments to large farms (much below the proposed €300,000 which only concerns 0.12% of farmers and more effective than the system of degressivity based on a high threshold and a low degressive rate which is now proposed), top-ups for small farms, and transfers of funds from the first pillar to the second one to develop ecological structures and no dumping through export subsidies. Sustainability: Greens call for an efficient spending of public money to respond to environmental challenges such as climate change, biodiversity loss, soil management and to ensure a fair rural development. Even if the CAP budget decreases, it should not be at the expense of decreased sustainability. For the Greens, the CAP should incentivise crop rotation and not monocultures. Agricultural policy should be used as a tool to manage biodiversity, improving soil fertility, water protection and animal welfare. The Greens oppose the fact that CAP funding can be used by insurance companies to reduce the risk of harvest loss. They fight for improving precautionary measures against natural and market risks. Quality: For Greens, two of the key criteria of agricultural policy must be public health and good food quality. They consider the CAP as a tool to end the dependence on antibiotics in feed and treatments by training and supporting farmers in agro-ecology. Implementing crop rotation would contribute to the decrease of pesticides and fertilizers’ use. They also want to diminish waste by shortening the food supply chain. Imported feedstuff should respect the same standards as


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

farmers have to respect within the EU. The trialogue negotiations appear to be difficult for having Green proposals enacted: those who negotiate on the CAP reform on behalf of the whole Parliament come mainly from the conservative wing of the AGRI committee. However, the Greens will continue to fight for a fair, sustainable and quality agriculture in Europe, especially in pressuring governments to utilize the flexibility given by the CAP reform in favor of a greener CAP.

II.

Food: measures in preparation

1. Review of EU policy for organic production on process The Commission launched a public consultation open to all citizens, organisations and public authorities aimed at reviewing the European policy on organic agriculture. Supporting organic production by European funds and through legislation, the Commission would like to know whether “In the current economic downturn, will

consumers continue to turn towards a more sustainable lifestyle and higher consumption of organic products?” This consultation is a first step to deal with the complexity of the legal framework, the co-existence of GM crops with organic farming, the efficiency of control systems and the issue of trade arrangements for organic products. Given the success of organic farming, the Greens worry that organic food becomes undermined: it must stay a benchmark and a reference for sustainable farming practices and consumption patterns. They demand more transparency on the supply chain and the real costs of healthy food. Globally, they promote local food.

2. Regulation to protect bees from pesticides In April 2012, the Commission requested an analysis from the European Food Safety Agency on the impact of 3 pesticides (neonicotinoids) on bees. The analysis was concluded in January 2013 and pointed to several concerns. The Commission consequently asked Member States to agree on proportionate legislative measures, especially on the suspension for two years of pesticides’ use on seeds, granulates and sprays for crops which attract bees.

5

The Greens launched their campaign “Give bees a Chance” and supported the “bee’s knees” actions by civil society, calling for a total ban on neonicotinoids and denouncing the heavy industry lobbying against the ban. On 15 March 2013, experts representing the EU-27 met in the Standing Committee on the Food Chain and Animal Health and failed to reach a qualified majority - either in favour or against – the proposal to restrict the use of three neonicotinoids. The proposal was then referred to the appeal committee on 29 April 2013 where a majority of Member States supported the ban but still did not reach the necessary qualified majority. In absence of an agreement between Member States, the Commission has the right to decide on the adoption of the proposed restriction, what Health and Consumer Commissioner, Tonio Borg, did. New rules should apply from December1st 2013.

3. New regulations for Animal and Plant Health delayed The Plant Health Proposal (designed to protect EU territory against the entry and spread of harmful organisms from third countries) and the Animal Health Proposal (one regulation replacing over 40 directives, especially ensuring disease control and safe trade) have been delayed since 2011. All the stakeholders have been consulted but proposals seem blocked at the Commission’s level. John Dalli’s resignation (former Commissioner for Health and Consumer Protection) has further postponed DG SANCO’s agenda.

4. What’s missing? EU wide regulation of GMOs and other novel foods Greens have been at the forefront of calling for regulation and prohibition of the use of Genetically Modified Organisms in European agriculture. Nothing in the current reform packages addresses Green calls for GMO free zones or alters the Commission’s overall proGMO stance. Comprehensive elimination of trade barriers for agricultural products from outside the EU The Commission has rejected the approach urged by the EP and the Greens in dealing with the trade asymmetries created by the CAP, preferring instead to deal with the imbalance through the Doha Round trade reforms and by granting preferential trade agreements to those


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

countries considered affected. This policy does not help developing countries to promote agriculture with added value. The Greens stand thus for a negotiation outside of WTO through a transparent and democratic international framework fully taking into account the social and environmental issues of agriculture.

III.

Reform of the Common Fisheries Policy

1. Summary Common Fisheries Policy (CFP): Key terms The EU is the world’s second largest fishing power after China. Herring, anchovy, tuna, sandeels and sprat are the largest fisheries in European waters. The top EU fishing nations, that between themselves amount for more than 50% of all EU landed catch are Denmark, Spain, the United Kingdom and France. Today overfishing leads to smaller catches for the fishing industry and consequently an uncertain future. Reform of the CFP is therefore urgent. Equal access: Under the CFP all Member States have "equal access" to the European Economic Community fishing grounds, which become a "common resource". As an opt-out, exclusive fishing rights for UK fishermen up to six miles off the British coasts were accepted. Total Allowable Catch (TAC): In 1983, the principle of “equal access” was modified in an attempt to curb overfishing through TACs and quotas on a species-byspecies basis (these quotas are managed by Member States’ governments). This led to the discard of caught fish that did not fit the species quota, by throwing “unfitting” catch back into the sea. This policy led to a dramatic decrease of fish stocks. Greens have not been satisfied with key aspects of the CFP since they first entered the European Parliament in 1984. Their key objections include: >

There is a lack of clear fishing control rules to make overfishing illegal and to sanction Member States that mismanage the quotas

>

There is insufficient environmental protection and regulation

>

The distorting effect by CFP to the detriment of the developing world (Europe’s agricultural

6

products’ prices are kept artificially low due to subsidies) >

Subsidies are promoting inefficient and/or wasteful production techniques and practices in CFP

Thirty years from the onset of the Common Fisheries Policy (CFP), fisheries in the EU are in a dramatic state. Years of over-fishing have created an environmental disaster that is provoking a socio-economic crisis: as fish stocks are depleted, fishermen fish less and do not earn enough money to live decently. So far, the policy has failed to redress the situation, partly because Member States failed to implement existing agreements. In July 2011, the European Commission published its proposals for a major reform of the CFP, which included: >

Phasing-out the discard practice: fishermen will be obliged to land all the fish that they catch.

>

Achieving the Maximum Sustainable Yield by 2015 (defined as the largest catch that can be safely taken year after year and which maintains the fish population size at maximum productivity) through multiannual plans instead of annual horse-trading between EU governments over fishing quotas.

>

Clear targets and timeframes to stop overfishing: market-based approaches such as individual tradable catch shares; support measures for small-scale fisheries; improved data collection; and strategies to promote sustainable aquaculture in Europe.

>

Financial support only to environmentallyfriendly initiatives contributing to smart and sustainable growth of fish stocks. A strict control mechanism will rule out any perverse funding of illicit activities or overcapacity.

>

General policy principles and goals will be prescribed from the European level, while Member States will have to decide and apply the most appropriate conservation measures. This will also deliver solutions tailored to regional and local needs.


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

In February 2013, the European Parliament voted in favour of the Commission’s proposal and supported the requirement of sustainable levels of fishing from 2015 onwards and the restoration of fish stocks to abundant levels by 2020. They supported the end of discards for all harvested species and a key Green proposal to ensure that the right to fish is allocated based on best performance, with a view to rewarding environmentally and socially sustainable fishermen.

must be prioritised over short term economic gains. >

End discarding of fish within 5 years: According to the Greens, no fish should be dumped back in the sea and all fish landed must be deducted from the quota allocated for the catch. This must be coupled with incentives for fishermen to avoid catching the unwanted marine species in the first place – for example by using more selective gear.

>

Establish long-term management plans: To ensure clear fishing control rules, binding long term management plans must be established for all fisheries.

>

Decentralise decision making: The targets and timelines shall be set at the EU level – but the ways to reach the goals shall be decided and implemented on a level closest to other stakeholders, such as the people dependent on fisheries.

>

Use public money for the transition of the fishing fleet: Funds should not be used for enhancing fleet capacity. Instead, public money should be used to help the transitioning into a sustainable fishing industry, for example by subsidising selective fishing gear, adopting less environmentally destructive fishing practices or measures of common interest such as control, data collection etc.

>

Make everyone follow the rules: There should be sanctions against Member States that do not fully respect their obligations under the Common Fisheries Policy, such as reporting complete data on fleet capacity and catches.

>

Stop the privatisation of the sea: Greens do not support the Commission's proposal to make transferable fishing concessions (TFCs) mandatory for Member States.

>

Give priority access to low-impact fishing vessels

>

Fish responsibly in the rest of the world: 28% of the fish caught by EU fishing vessels are taken

2. National considerations At the end of February 2013, the European Council showed a less ambitious position than that of the European Parliament on the reform. The compromise in the Council was hard-fought. The UK, Germany and the Nordic countries were in favour of an early end date of discarding with few loopholes. Spain, Portugal and France however succeeded in pushing to allow up to 7% of the catch to be discarded after 2017 and to limit the ban on discarding to specific species. Thus, under the Council agreement, discards would be phased out between 2014 and 2017, depending on the type of fish (whether it lives close to the surface, near the bottom of the sea or in the Mediterranean Sea). Trialogue negotiations between the European Council, Parliament and the Commission started in March 2013. Ireland, which holds the presidency of the Council of Ministers, hopes to reach a final agreement on the CFP reform by July 2013.

3. Green Response Greens argue that marine resources are a public good, not a private resource. The right to exploit those resources should be therefore allocated according to criteria that ensure that fishing contributes as far as possible to the public interest.

7

The Greens want to: >

End overfishing by 2015: The EU must end overfishing by 2015 in order to rebuild stocks by 2020 above levels which can produce the maximum sustainable yield (MSY).

>

Make environmental protection a prerequisite: It is only with more fish in the sea that we can have socially and economically sustainable jobs for fishermen. Long term environmental goals


EU 2013 Policy Priorities: Agriculture, Food and Fisheries

8

outside EU waters. These vessels should operate under the same rules as vessels within the EU. The Greens’ positions have been heard and the agreement reached by the EP definitively ensures a more sustainable CFP. The final reform of the CFP is now negotiated between the ambitious EP proposal and the disappointing Council stance. Green fisheries spokesperson Isabella Lövin commented: “Just weeks after a historic European Parliament

vote to put the CFP on a more sustainable footing, EU governments have agreed a depressingly unambitious position (…). MEPs must now fight to uphold their vote for a meaningful CFP reform to ensure this unique opportunity is not missed.”

>

http://www.europeancouncil.europa.eu/council-meetings?lang=en

>

The Green/EFA vision of the 2013 CAP reform: http://www.greensefa.eu/fileadmin/dam/Documents/Publications/ CAP_reform/CAP_reform_EN.pdf

>

The Green/EFAh vision on bees and neonicotinoids: http://www.greens-efa.eu/bee-s-kneescampaigning-9618.html

>

The Green EFA vision on organic food: http://www.greens-efa.eu/organic-fooddiscounted-9554.html

>

The Green/EFA demands for the EU fisheries policy reform: http://www.greens-efa.eu/10demands-in-the-eu-common-fisheries-policyreform-2012-2013-7862.html

>

Including CAP post 2013 proposals: http://ec.europa.eu/agriculture/cap-post2013/legal-proposals/index_en.htm

>

The Green New Deal website developed and promoted by GEF for the Greens/EFA group, and uniting materials from GEF, the Greens/EFA Group and the EGP, focuses heavily on agriculture, including publications and best practices on the best ways to produce a fairer, greener European Agricultural Policy: http://greennewdeal.eu/agriculture.html

For more information >

Commission’s 2013 work programme and annexes: http://ec.europa.eu/atwork/pdf/cwp2013_annex _en.pdf

>

DG Agriculture and rural development: http://ec.europa.eu/agriculture/

>

DG Fisheries: http://ec.europa.eu/fisheries/index_en.htm

>

DG Health and consumers: http://ec.europa.eu/dgs/health_consumer/index _en.htm

>

http://www.consilium.europa.eu/policies/counci l-configurations/agriculture-and-fisheries

This text is the result of an original research carried out by Clarisse Heusquin for the Green European Foundation. © Green European Foundation, April 2013 The views expressed in this article are those of the authors’ alone. They do not necessarily reflect the views of the Green European Foundation. With support of the European Parliament. Green European Foundation asbl 1, rue du Fort Elisabeth, 1463 Luxembourg Brussels Office: 15 rue d’Arlon, 1050 Brussels, Belgium Phone: +32 2 234 65 70 - Fax: +32 2 234 65 79 E - mail: info@gef.eu - Web: www.gef.eu


Turn static files into dynamic content formats.

Create a flipbook
Issuu converts static files into: digital portfolios, online yearbooks, online catalogs, digital photo albums and more. Sign up and create your flipbook.