Developing CAP Strategic Plans

Brussels returns to business this week, but slowly from the perspective of deciding on the shape of the CAP post 2020. COMAGRI is scheduled to meet on Wednesday 4 September to discuss the Union’s general budget for the financial year 2020. Also on the agenda is an item “Approval of recommendations from AGRI Coordinators” which may reveal how the Committee plans to proceed with the CAP post 2020 files.

The choices range from endorsing the work of the previous Committee and forwarding its Reports to the new Parliament for adoption, to starting afresh to re-examine the Commission’s proposal. According to Euractiv reporting in late July, the AGRI Coordinators are leaning towards a middle way, resubmitting the Reports to the Committee and keeping them open to new amendments but without radical changes (though its not clear to me how that would be enforced). Perhaps we will find out on Wednesday what the Committee proposes to do.

On the Council side, the AGRIFISH September Council meeting has been cancelled (instead, an informal Council will be held later in the month), so the Council has no formal meeting between July and October. The Finnish Presidency may feel there is little point in investing further energy in discussing the Commission’s post 2020 CAP proposals until it becomes clearer what the EP AGRI Committee proposes to do. Waiting for the views of the next Commissioner who will not be confirmed until the end of October and for the prospects for an agreement on the next Multi-annual Financial Framework at the October European Council meeting may be other explanations for the Council go-slow even if technical work continues in the Council Working Groups.

Thus, at the moment, the legislative process is just marking time on the Commission’s post-2020 CAP proposal. One consequence is that the deadline set out in the draft CAP Strategic Plans Regulation that Member States should forward draft Strategic Plans to Brussels by the end of this year to allow approval in the first half of 2020 looks hopelessly unrealistic.

The process of developing a Strategic Plan begins with two steps. First, a SWOT analysis must be prepared based on an assessment and prioritisation of needs. Even if draft SWOT analyses are prepared by a research institute or consultancy firm, they must involve and allow for feedback from stakeholders through various mechanisms. Second, an ex ante evaluator must be chosen who is required to appraise the assessment of needs including the procedures used to involve stakeholders.

There seems to be little information publicly available on where Member States are with these steps. The European Network on Rural Development organised a training seminar in October 2018 on ‘Key steps for CAP strategic planning’ and the European Evaluation Helpdesk for Rural Development organised one in March 2019 on ‘Getting prepared for the ex ante evaluation of the CAP Strategic Plan’. The Helpdesk has also created a Thematic Working Group to support evaluation stakeholders in preparing for the ex ante evaluation of the CAP Strategic Plans (this work is described in the July 2019 edition of Rural Evaluation News). One assumes there is also regular contact between the national contact points and Commission officials to provide technical support to the process.

But publicly, information on the state of play of preparations for CAP strategic planning is very scarce. For example, searching for relevant phrases in German or French on the German and French Ministry of Agriculture websites throws up no relevant hits, even if Germany which has asked the Von Thünen-Institut to prepare a draft of its SWOT analysis seems to have made some progress

It would be very helpful to follow this process if some pan-European group with the necessary resources and correspondents in each country might offer to host a website where each country’s steps towards preparing its Strategic Plan could be documented.

Stakeholder involvement in developing Strategic Plans

One of the things Managing Authorities must do is to define the stakeholder engagement strategy when drawing up their Strategic Plan. For example, stakeholders can be asked to sit on the Steering Committee, to respond to a public consultation, or to take part in thematic working groups or in focus groups.

I took part in a potential engagement tool at Wageningen University last week. This was an ‘escape room experience ’ organised as a Master Class at the fourth annual Wageningen Soil Conference. It turned out that many of the 15 participants had previously participated in escape room experiences but for readers who, like myself, have never done so, let me briefly explain the idea.

In an escape room experience, teams of participants work together to solve puzzles to allow them to proceed through and eventually ‘escape’ from the room within a given time, in this case 60 minutes. The purpose of the Wageningen escape room was to combine interactive puzzle-solving with the educational objective to introduce participants (in this case, participants in a soils conference) to some of the ideas behind a more performance-based CAP based on strategic planning.

Participants were initially welcomed by ‘Commissioner Hogan’, theatrically portrayed by Professor Rogier Schulte who had conceived the Master Class. He took 10 minutes to explain the background to the CAP and the changes that the Commission had proposed to make in the policy for the period after 2020. Participants were asked to identify themselves as national policy-makers with the objective to design their country’s CAP Strategic Plan (for the sake of time, the game focused on the three environmental and climate specific objectives out of the nine put forward for the next CAP). Participants had to move through five rooms in all, finally escaping when their Strategic Plans were complete.

‘Commissioner Hogan’ explains the thinking behind his proposal for the CAP post 2020

I don’t want to create spoilers and describe the puzzles the teams were asked to solve. Suffice to say that the first room introduced players to the SWOT analysis, the next room to the needs assessment, the next room to the choice of appropriate interventions, the next room to the allocation of funding to various interventions including the balance between Pillar 1 and Pillar 2, while in the final room each team assembled its Strategic Plan. The puzzles, props, maps, video sequences and other paraphernalia that helped (or hindered!) the teams to escape were brilliantly conceived and designed by Mariana Debernardini (Mariana takes up a job as a Sustainability & Research liaison for the European Council of Young Farmers (CEJA) in Brussels this week). To my surprise (as I had thought some of the puzzles would prove quite difficult), each of the three teams escaped from the room with a completed Strategic Plan and each with just a couple of minutes to spare.

Resolving the SWOT analysis and assessing needs

The second part of the Master Class was the debriefing where participants had the opportunity to ask questions and to reflect on their experiences. For some (if not many) of the participants, the escape room had been largely about the puzzle-solving, so the debriefing was an opportunity to highlight the insights and lessons learned and thus was an essential part of the experience.

Debriefing on the CAP Strategic Plans

Many of the questions which have surfaced during the legislative process following the publication of the Commission’s proposals were also raised in the debriefing. How would performance and impact be measured? What would be the incentives to pursue ambitious Plans? One observation was that the teams designed their Strategic Plans in the later rooms largely based on their own personal assessment of what were the important priorities, without referring back to the insights from the SWOT analysis identifying the country’s strengths, weaknesses, opportunities and threats. I suspect that this is not unusual and will also be the case when stakeholders meet in reality to discuss the draft Strategic Plans.

Using a game to get stakeholders talking to each other requires a certain level of investment but it may be something some Managing Authorities might wish to consider when planning their stakeholder engagement. If so, I can strongly recommend drawing on the experience of the Wageningen team.

Update 5 Sept 2019: A reference to the informal AGRIFISH Council in late September has been included.

This post was written by Alan Matthews

Evaluating the legislative basis for the new CAP Strategic Plans

The main novelty in the Commission’s legislative proposals for the CAP after 2020 is the New Delivery Model (NDM) which has been described by Commissioner Hogan as representing a shift from a compliance-based to a performance-based or results-based governance system for the CAP.

As set out in a recital to the CAP legislation: “In the CAP based on delivery of performance (‘delivery model’), the Union should set the basic policy parameters, such as objectives of the CAP and basic requirements, while Member States should bear greater responsibility as to how they meet the objectives and achieve targets. Enhanced subsidiarity makes it possible to better take into account local conditions and needs, tailoring the support to maximise the contribution to Union objectives.”

The key instrument designed to underpin the NDM will be the requirement for each Member State to draw up a Strategic Plan setting out its assessment of needs, the specific CAP objectives it intends to address, its intervention strategy including the targets it intends to achieve with respect to these objectives, and the interventions it plans to use. The rules for these Strategic Plans are set out in Title V of the Commission’s draft Regulation establishing rules on support for strategic plans to be drawn up by Member States under the Common Agricultural Policy (CAP Strategic Plans).

Whether these rules are adequate to ensure that the Commission’s declared objectives for the CAP post 2020 can be realised or not has just been thoroughly examined in a study by Professor Emil Erjavec and his colleagues from the University of Ljubljana in Slovenia commissioned by the Policy Department for Structural and Cohesion Policies of the European Parliament (this builds on a previous post on this blog by Professor Erjavec). The purpose of the study is to assist the COMAGRI rapporteurs and members in drawing up their reports on the Commission’s legislative proposals.

In this post, I review the suggested rules in the draft Regulation and outline seven suggestions in the Erjavec at al. paper on how they could be improved.

CAP Strategic Plan

The rules cover the four main elements for Strategic Plans: the procedural requirements for drawing up the Plans, the content of the Plans, the method for their approval, and their performance monitoring.

Procedural requirements (Art 94)

Member States should use transparent procedures when preparing their Strategic Plans. The competent regional and local authorities, including relevant public authorities, economic and social partners, and relevant bodies representing civil society, should be involved in the preparation of the plan. Specifically, the competent authorities for environment and climate should be effectively involved in the preparation of the environmental and climate aspects of the plan.

Elements making up the Strategic Plans (Art 95-103)

An explicit structure for the Strategic Plans is proposed containing the following sections.

(a) an assessment of needs. The Plan should include an identification and description of needs for all nine specific objectives set out in Article 6 of the draft Regulation regardless whether they will be addressed in the CAP Strategic Plan or not (a summary of these nine specific objectives taken from the Erjavec et al. study is shown in Table 1). Needs in relation to risk management in connection with the specific objective of support for viable farm incomes and resilience should be specifically described. These needs should then be ranked and prioritised and a sound justification of the choices made should be given, including why certain identified needs might not be addressed or only partially addressed in the Strategic Plans. (In passing, while this suggests that Member States may decide not to pursue one or more of the specific objectives shown in Table 1 if they can provide appropriate justification, in practice the mandatory nature of the agri-environment-climate interventions and the existence of the performance bonus (see below) makes the inclusion of the related specific objectives for the general environment and climate objective also mandatory).

(b) an intervention strategy. This section should set out quantitative targets and milestones to achieve each specific objective set out in Table 1 that is addressed in the Strategic Plan (not all objectives need to be addressed if the omissions are justified, as noted in previous paragraph). Targets should be defined using a common set of result indicators set out in an Annex to the draft Regulation. The value of the targets should be justified by reference to the needs assessment.

The intervention strategy should also set out the interventions proposed to reach these targets drawn from the menu set out in the Regulation. It should describe how the interventions allow reaching the targets and how they are mutually coherent and compatible.

Additional specific requirements include (i) an overview of the environmental and climate architecture showing the complementarity and coherence between the proposed conditionality attached to receipt of farm payments, the eco-scheme in Pillar 1 and the AECM measures in Pillar 2 and how this architecture contributes to meeting long-term national targets set out in relevant environmental legislation; (ii) in relation to the specific objective ‘attract young farmers and facilitate their business development’ the overall package of measures included in the Plan should be described, including their interplay with relevant national instruments; (iii) where coupled supports and other sector-related interventions are included in the Plan, the justification for targeting the sectors concerned, the list of interventions per sector, their complementarity, as well as the possible specific additional targets related to the interventions should be described; as well as (iv) an explanation as to which interventions will contribute to ensure a coherent and integrated approach to risk management.

(c) a description of elements common to several interventions. This is a catch-all heading that refers to a few disparate requirements. The most important is a description of the system of conditionality, including a detailed account of how each GAEC standard in the Regulation will be implemented and, specifically, how it will contribute to the environmental and climate specific objectives set out in Article 6 (see Table 1). Member States should also include information on the specific definitions they have adopted for some of the terms in the Regulation that are left up to Member States (for example, the definitions of agricultural activity, agricultural area, eligible area, genuine farmer, small farm and young farmer); on the use made of technical assistance; on the functioning of payment entitlements where the Member State opts to continue their use; on the uses made of revenues raised by capping and degressivity; as well as an overview of the coordination, demarcation and complementarities between the EAFRD and other Union funds active in rural areas.

(d) a description of the direct payments, sectoral and rural development interventions specified in the strategy. This should include an account of the design of the intervention and its eligibility conditions, the annual planned outputs for the intervention, the annual planned unit amount of support and its justification; and the resulting annual financial allocation for the intervention. Member States should also show how the intervention relates to the criteria for determining whether measures are trade-distorting or not in the WTO Agreement on Agriculture, and whether the intervention falls outside the scope of Article 42 TFEU and is subject to State aid assessment.

(e) target and financial plans. These should build on the annual financial allocations per intervention set out in (d) as well as detail transfers between Pillars and confirm that any minimum spending requirements set down in the Regulation have been met.

(f) a description of the governance and coordination system. The most important element here is information on the control system and penalties including the integrated administration and control system and the control and penalty system for conditionality. The monitoring and reporting structure should also be described.

(g) a description of the elements that ensure modernisation of the CAP. This covers two specific obligations; an overview how the Strategic Plan will contribute to the fostering and sharing of knowledge, innovation and digitalisation and encourage their uptake, including a description of the AKIS organisational set-up and how advice and innovation services are provided; and a description of the strategy for the development of digital technologies in agriculture and rural areas and for the use of these technologies to improve the effectiveness and efficiency of the CAP Strategic Plan interventions.

(h) a description of the elements related to simplification and reduced administrative burden for final beneficiaries. In addition, each CAP Strategic Plan should contain the following annexes:
(a) Annex I on the ex-ante evaluation and the strategic environmental assessment (SEA);
(b) Annex II on the SWOT analysis;
(c) Annex III on the consultation of the partners;
(d) Annex IV on the crop-specific payment for cotton;
(e) Annex V on the additional national financing provided within the scope of the CAP Strategic Plan.

Approval procedure (Art 106-108)

Member States are required to submit their Strategic Plans no later than 1 January 2020, although there is some ambiguity in the text whether this date is intended to be in square brackets or not (indicating that it is subject to further negotiation). The specific conditions for approval of the Strategic Plans are worth citing in full:

“The Commission shall assess the proposed CAP Strategic Plans on the basis of the completeness of the plans, the consistency and coherence with the general principles of Union law, with this Regulation and the provisions adopted pursuant to it and with the Horizontal Regulation, their effective contribution to the specific objectives set out in Article 6(1), the impact on the proper functioning of the internal market and distortion of competition, the level of administrative burden on beneficiaries and administration. The assessment shall address, in particular, the adequacy of the strategy of the CAP Strategic Plan, the corresponding specific objectives, targets, interventions and the allocation of budgetary resources to meet the specific CAP Strategic Plan objectives through the proposed set of interventions on the basis of the SWOT analysis and the ex-ante evaluation.”

Annexes 1-4 as well as the Member State plans for controls and penalties are explicitly excluded from the approval process. The Commission can address observations to the Member State within three months of receiving the Plan, and the Member State is required to provide any additional information requested and, if necessary, to revise the proposed Plan. It is further specified that approval should not take longer than eight months after submission of a Plan (but this time limit excludes any time required for a Member State to respond to Commission observations). Partial approval of elements of the Plan is also permitted. Member States can amend their Plans at any stage by following the prescribed procedure.

Performance monitoring (Art 115-124)

The draft Regulation specifies a performance framework consisting of a set of common context, output, result and impact indicators that will be used as the basis for monitoring, evaluation and annual performance reporting. Targets and annual milestones will be based on output and result indicators and progress will be reported in an annual performance report.

Mechanisms to reward good performance and to address low performance are proposed. Where the reported value of one or more result indicators deviates by more than 25% from the respective milestone for the reporting year concerned, the Commission can ask the Member State to submit an action plan with intended remedial actions and a timeframe. The performance bonus (actually a performance penalty) will be implemented by withholding in 2016 5% of each Member State’s pre-allocated Pillar 2 funding in 2017. This amount will be released to the Member State if the result indicators applied to the three specific environmental- and climate-related objectives in its CAP Strategic Plan have achieved at least 90% of their target value for the year 2025.

Recommendations of the European Parliament study by Erjavec et al. (2018)

The Erjavec et al. study welcomes in principle the shift to the NDM, pointing out that it is line with the principles of evidence-based policy making. It sees the greatest opportunity arising from the proposed approach in greater flexibility for Member States and efficiency for the EU. Risks are associated with the administrative burden of planning for Member States and lowering standards or ‘race to the bottom’ for the EU.

It suggests that the proposed new model of policy delivery draws on the established model of Rural Development programming and essentially the same governance system, and thus contains all the shortcomings of the current system. The study doubts that the proposed arrangements will lead to a genuine results-based policy. It sees limited incentives for Member States to make efforts for better policies, and highlights an “accountability gap” and a “systemic weakness in the intervention logic” in the new delivery model. It is too easy for Member States to draw up Strategic Plans that are mainly designed to minimise the hassle associated with the absorption and distribution of funds.

I distil seven main recommendations in the study designed to encourage and strengthen the results-based approach advocated by the Commission in its legislative proposal.

Make the specific objectives in the legislative proposal more concrete by setting quantified goals, drawing on related EU legislation where appropriate. The study accepts that, for CAP measures to contribute to the achievement of its specific objectives, these objectives should be sufficiently concrete and measurable so that quantified, measurable milestones and targets can then be established in Member States’ CAP plans and subsequently monitored. It notes that “The CAP policy objectives are relatively clear, what is missing is only their quantification”. Most of the discussion on quantified indicators at the EU level refers to the environmental and climate objectives. The study underlines that the need for quantification applies to all nine specific objectives. It recognises that for some of the other objectives, notably farm viability and resilience, the process of quantification could lead to considerable political and economic tensions.

Strengthen the commitment to greater environmental and climate ambition. An important foundation for the greater level of environmental and climate ambition desired by the Commission for the CAP post 2020 is set out in Article 92, which sets out that there should be no backsliding with regard to environmental and climate-related objectives in the current period (I have previously discussed Article 92 in this post):

“Member States shall aim to make, through their CAP Strategic Plans and in particular through the elements of the intervention … a greater overall contribution to the achievement of the specific environmental- and climate-related objectives … in comparison to the overall contribution made to the achievement of the objective … in the period 2014 to 2020.”

The study points out that implementing this commitment depends on the evaluation of the current state and goals and fails to instruct on how to define the situation and goals. It suggests strengthening the principle of ‘no backsliding’ with the requirement to maintain at least the absolute and relative share of support for climate and environmental objectives.

Improve accountability through a more comprehensive reporting system. As noted previously, the performance framework will require Member States to report only on output and result indicators in their annual performance reports. This study suggests this should be expanded to also include changes in the impact and contextual indicators. Specifically, better quantification of CAP objectives and indicators at the EU level could drive the monitoring of these objectives at the national level. Here the study raises but leaves open the question of how the EU-level objectives can be transmitted to Member States. It suggests it could be helpful to draw on independent quantitative and qualitative public assessment of experts and groups at the EU and national level.

Strengthen rules to ensure genuine consultation in Plan preparation.
The study notes the current experiences with Rural Development programming, where the level of stakeholder consultation and engagement vary significantly from one country to another – even if the rules are common and fall under the European Code of Conduct on Partnership. In the future, the CAP Strategic Plans will no longer fall under this Code set out in the Common Provisions Regulation. The study concludes that it will be even more important that a strong framework on partnership and common rules be inserted into the CAP proposals. As it stands, while there is a requirement for Member States to consult adequately with “relevant” stakeholders, the annex on consultation will not be part of the approval process of the Plans.

The study recommends strengthening the stakeholder consultation process with more binding requirements concerning the composition of parties involved in the process, joint decision-making, monitoring and evaluation. These requirements could be drafted in line with the provisions put in place in cohesion policy and using the European Code of Conduct on Partnership as a basis. The objective should be to ensure that stakeholders’ opinions at national level are seriously taken into account.

Formalise more the approval process for Strategic Plans. The procedure related to the approval of the Strategic Plans is practically the only mechanism in the Commission’s power to ensure targeted and ambitious strategic planning. The study underlines the importance of ensuring that the Commission is empowered to make a proper qualitative assessment of the Strategic Plans. Here it proposes that the adoption procedure should be more formalised, with stakeholders’ opinions at national level taken into account. It believes this would improve the quality of the design as well as the legitimacy of the documents.

Make substantial investment in personnel, processes and analytical support for the preparation of Strategic Plans. The study underlines in various places the dramatic culture shift that the introduction of strategic planning will imply for those involved. While superficially there are similarities to the process used in drawing up Rural Development Programmes at present, the study suggests that the latter is more of a technical activity than a substantive, political task. To be implemented effectively, the strategic planning approach “demands competent human resources (e.g. strategic workgroups), effective coordination and organisation of the process, a well-established culture of democratic dialogue and learning that involves a broad spectrum of stakeholders, as well as sufficient external analytical and expert support”.

“Strategic planning is supposed to be a creative, intellectual and democratic endeavour, which requires excellent staff and a comprehensive approach. Will civil servants in Member States be up to the challenge? How to build a newly required culture of action and cooperation? In truth, probably in most Member States, civil servants are not sufficiently trained for quality strategic planning. Deficiencies also arise from the weak position of agricultural officials in society, inappropriate and narrow education, lack of training and practical experience, poor quality of management and politicized state administrations.”

The study notes that, for several Member States, the transition towards a strategically oriented and performance-based agricultural policy will prove to be a daunting task that will require increased efforts in terms of substantially upgrading strategic, analytical and administrative capacities, procedures and methods of work. Without serious investment in personnel, processes, analytical support and inclusive preparation of Strategic Plans, there may be considerable differences in policy implementation between individual countries.

The study emphasises the need for capacity building, and improvement of training and knowledge exchange in support of strategic planning. Among other suggestions, the study recommends establishing a common platform with open access to all Strategic Plans, progress and evaluation reports to assist in the process of mutual learning.

Make greater investment in data collection to support the results-based approach. The study underlines the importance of strengthening the data sources related to needs analyses, as well as making available appropriate data that will be employed as indicators for identifying and monitoring objectives. It sees the need for an upgraded system of data collection and data management in support of strategic planning. Both Member States and EU bodies (JRC, EEA, Eurostat) have a role to play here. The study proposes an enlarged technical assistance budget could be used to improve the depth and quality of data collection.

Additional issues

These recommendations are relevant and worth supporting. There are several other issues around the Strategic Plan instrument that would be worth exploring in more depth.

What role should the Parliament have? COMAGRI has raised concerns that the NDM implemented through the Strategic Plans reduces the role of the Parliament in the definition of the CAP and could even make the AGRI Committee of the Parliament redundant. AgraFocus (72-18) reported that the Committee in September had sought the advice of the Parliament’s legal services comparing the powers the Parliament currently has with those it would have under the Commission’s proposal, but I am not aware that this legal advice has been made public. It is not clear exactly where the Committee’s concerns arise, but one might speculate that the reversion of significant powers to Member States to define how the CAP is implemented in their countries could remove these decisions from the remit of the Parliament’s scrutiny.

The draft Regulation envisages a limited oversight role for the Parliament in the CAP after 2020. The Commission would carry out an interim evaluation by the end of the third year after the start of the CAP Strategic Plans based on the impact, result and output indicators set out in the Annex to the draft Regulation. An initial report based on first results of implementing the new CAP would then be forwarded to the Parliament and Council after this interim evaluation. A second report including an assessment of the performance of the CAP shall be presented by 31 December 2031. All in all, this does not suggest that COMAGRI will have a particularly busy agenda in the coming parliamentary period.

Handling disagreement in the approval process. The study rightly highlights the crucial role of the approval process in ensuring that Member States deliver on the CAP’s EU objectives in their Strategic Plans. Compared to the current process for the approval of Rural Development Programmes, the approval of Strategic Plans will potentially be a more political process under a results-based strategic planning model. The Commission will not just be checking that the Plans comply with various requirements set out in legislation but will be required to evaluate whether the Plans make a sufficient contribution to meeting EU objectives.

The Plans will arrive on the Commission’s desk with considerable legitimacy behind them (an ex ante evaluation, a SWOT analysis, a stakeholder consultation process). It will take a brave desk officer to challenge the country’s priorities and choice of intervention strategy. But suppose the Commission does send observations that the Member State refuses to accept, and perhaps there are good grounds for this refusal. In this situation, the Commission can withhold its approval and thus delay the transfer of funds to the Member State. What procedures for arbitration will exist in cases where the two parties cannot reach agreement?

Changing the audit culture. An under-researched topic to date in the evaluation of the NDM is the role that the EU audit process will play. This process has come in for heavy criticism in recent years for its allegedly heavy-handed controls and its dampening effect on innovation (for a well-documented cri de coeur, see this submission from Freistaat Sachsen on how the audit process should be retooled in the CAP after 2020). The Parliament’s Budget Committee has also raised concerns that financial and performance control and audit functions of the CAP are performed to the same standard and under the same criteria across all Member States under the NDM. The mechanisms to ensure this in the draft legislation are not clear. Exactly the role that the EU audit function will play in the new results-driven model deserves much greater examination.

Where is the simplification? Simplification along with modernisation are the two over-arching objectives of the Commission’s CAP proposals. But initial reactions from Member States and farm groups suggest that many do not regard the proposals as a real simplification. Indeed, it should be recognised that strategic planning will result in a substantially greater administrative burden at the Member State level. The Commission proposals envisage considerable simplification at the beneficiary level (in part because Member States will now be able to design rules more appropriate to their farming circumstances, and in part through using new technologies to minimise the inputs required from farmers). Member States will be required to spell out, in one section of their Strategic Plans, the extent of this simplification at the level of beneficiaries. No doubt the Commission in its roadshow around the Member States to begin the process of strategic planning has identified ways in which the NDM also has advantages for the paying agencies and Member State administrations.

Maintaining a level playing field. One of the big concerns voiced by farm groups is that greater subsidiarity for Member States to design their own agricultural policies could lead to strong differences in the regulatory frameworks in different Member States (in the definition of conditionality standards and in the mix of support interventions that are employed). These groups fear that this ‘renationalisation of the CAP’ could lead to the fragmentation of the internal market and disrupt the level playing field for farmers in different Member States.

The significance of this objection is greatly overstated. Those groups who raise this objection against the NDM are usually the greatest proponents of the most trade-distorting CAP instrument, namely, coupled payments at the Member State level. The CAP has never been entirely uniform for a least a decade, with strong differences in the levels of direct payments per hectare and different payment models, and the single market has survived. More important, the conditions attached to the ‘licence to farm’ in Member States, in terms of regulation and taxation policies, remain very different.

Nonetheless, concerns over the disruption of the level playing field cannot be entirely dismissed. The single market is one of the greatest achievements of the European Union and should not be arbitrarily undermined. The Commission has recognised the issue and has stated that the level playing field will be ensured by using the Commission’s power to approve individual Strategic Plans “to ensure consistency and protection of the single market”. This has also been the position taken by Commissioner Hogan. But how the potential contradiction between giving Member States the power to design a results-based agricultural strategy while minimising different regulatory and support regimes across the EU can be avoided or minimised needs to be more clearly set out.

Conclusions

The Erjavec et al. study is the first systematic attempt to review and evaluate and suggest improvements to the Strategic Plan instrument which will be the centrepiece of the NDM in the CAP post 2020. It makes a valuable contribution and its recommendations must be seriously considered by the co-legislature when adopting the new legislation.

One of the main messages of the study is that the period 2021-2027 should be seen as a ‘deployment’ period for CAP strategic planning where no major adjustment of the measures nor particularly improved results can be expected.

The range of changes is so profound that a more long-term view should be taken, stressing the importance of collective learning and system building, to be able to implement better in the future.

Indeed, the Commission’s timetable for drawing up these Plans is ridiculously tight. According to the date in the draft legislation, Plans should be submitted to the Commission for approval by 1 January 2020, less than 15 months away.

During this period, Member States are expected to conduct a SWOT analysis, a multi-stakeholder consultation exercise, prepare a draft Strategic Plan, conduct an ex ante evaluation on this draft, revise the Plan and then submit it to Brussels.

And all this while the draft legislation itself has not yet been approved!

Given the magnitude of the changes implied by the NDM and the need to get it right (bearing in mind the difficulties around introducing greening without full analysis and piloting of the proposals) it is hard to defend this rushed timetable, however much we see a need for CAP reform. However, the Commission is unlikely to shift its position until it becomes clearer that the timetable for adopting the new CAP legislation prior to the European Parliament elections in May 2019 itself cannot be met.

The Erjavec et al. study on the CAP Strategic Plans is one of three studies commissioned by the Parliament that will be presented at a COMAGRI workshop on 15 October next “The Common Agricultural Policy beyond 2020: appraisal of the EC legislative proposals” (draft programme here). The other two studies are by Roel Jongeneel on assessing the future structure of direct payments and the rural development interventions in the light of the EU agricultural and environmental challenges and by Tomas Garcia Azcárate on possible options to improve the EU food value chain.

This post was written by Alan Matthews

Photo credit: Near Montpellier, own photo.

CAP strategic planning: scope and implications

We are pleased to welcome this guest post by Emil Erjavec, Professor of Agricultural Economics, Policy and Law at the University of Ljubljana, Slovenia. It is a version of his keynote speech to be delivered at the “The future of the CAP – L’avenir de la PAC” conference organised by Société Française d’Économie Rurale at Montpellier Supagro on 22 June 2018.

In December 2017, the European Commission published a Communication announcing a new round of important changes to the CAP post-2020; its legislative proposals, published June 1st 2018, have officially initiated it. Whether these changes are truly far-reaching and whether they contribute to a more efficient, effective and less controversial policy, will largely depend on the result of inter-institutional negotiations and later national implementation.

Nevertheless, the basic building blocks of reform are known. I agree with those who point out that this reform is primarily about changes in the institutional approach and responsibility of agricultural policy and less about changes in available policy instruments.

The public debate over the past six months in social media, at numerous conferences, as well as reactions in the Council and European Parliament, show that the key issues of the future CAP are: i) the reduction of resources (significantly larger for rural development than for direct payments), ii) the further stronger inclusion of societal considerations with a more pronounced environmental orientation, iii) the introduction of degressivity and capping of direct payments for larger farms, and of course iv) the new CAP implementation model, which has become known as “CAP strategic planning” for EU-funded agricultural policy measures.

Considering the first reactions to these issues (Agra-Facts, 2018/45), it is becoming clear that the key points of negotiation in EU institutions will be the amount of funds, the capping for agricultural holdings and the environmental focus of future policy. Given past experience and the farm interest-based nature of decision-making in the European Parliament COMAGRI and Council of the EU, the final outcome of the negotiations can be expected to be a weakening of the Commission’s proposals, which will nevertheless preserve the indicated direction.

Strategic planning – a serious evolutionary shift in the CAP?

Many commentators see comprehensive strategic planning at the Member State (MS) level as the crucial element of the proposal. Due to its technical nature, the current proposal does not directly favour anybody. While it can be expected that the political process will morph it significantly, the new fundamental principle and shift in policymaking will likely remain the same. The legislative proposals are clear: while previously strategic planning was a requirement at the EU level, though frankly more a justification of political decisions made beforehand and toothless in the case of policy failure, its transfer to MSs turns a new page in CAP history.

The proposed Regulation (COM (2018) 392) unequivocally states that policy will have to be formed following a comprehensive intervention logic; this includes programming of measures and a more rigorous application of the policy cycle concept. This entails founding policy on societally identified and recognised needs for intervention, deriving objectives and indicators (at all levels of evaluation) from these, and selecting the best available measures that can effectively contribute towards reaching the set targets. If effects are insufficient and there are no other known objective causes for this, measures should be accordingly modified.

This logic is not in itself under question, as it is supposedly the foundation of modern public policy governance; the key question is how consequentially it will be applied in the real world and whether it will bring about a more effective policy. There are fears that, similarly to ‘Greening’ in the previous reform, strategic planning is simply a new pretext to preserve the redistribution approach of the CAP, with at best marginal changes in its functioning and effects.

From the political economy point of view that takes into account the interconnectedness of vested interests in agricultural policy decision making, one of the key questions for representatives of mainstream agricultural governmental and non-governmental organisations is the amount of funding that will still be available for the CAP, coupled with how many ‘new’ demands will be placed on farming.

From an analytical point of view, as well as in the view of numerous environmental interest groups, however, applying national strategic planning to the entire CAP (this was already done for Rural Development policy in previous periods) certainly represents the greatest novelty and merits careful consideration and debate. Will there be minimal requirements for Member States for real CAP reform changes? What kind of obstacles and risks can be expected when implementing the strategic logic at national level?

In this post, we attempt to elucidate the substantive part of strategic planning given the current array of measures and indicators, i.e. analyse to which extent institutional structures, actors and procedural rules allow for quality strategic planning resulting in a more efficient (in terms of the effect/resource ratio) and effective (in terms of achieving goals) agricultural policy.

Defining needs is the policy’s weakest link

The proposed concept of strategic planning is based on the policy intervention framework at the EU level and CAP Strategic Plans at the level of individual MSs. There are 9 specific objectives that are derived from the three pillars of sustainability (see figure). They in turn are the basis from which derive indicators and broadly defined interventions, i.e., general descriptions of measures to achieve the objectives.

MSs will have to identify and determine their own needs for intervention and, in accordance with targets set out at the EU level, select, justify and elaborate measures from the given set of instruments. The European Commission will approve the CAP plans and monitor their results in accordance with the set objectives and indicators.

The essence of any strategic planning is defining needs (problem state) and policy objectives (desired state) based on those needs. The performance of policy management depends on how well this is done. The definition of needs should also determine and reflect the priorities of the decision-maker. We claim that it is precisely this element that is the weakest link of the CAP (and all agricultural policies). It originates primarily in the interest-based nature of the policy.

Agricultural policy has long since solved Europe’s post-WWII problems with food security (even famine), which was the original reason for its existence; ever since, it has largely been an income policy, solving the question of farmers’ economic situation. Yet it is not at all clear which groups of agricultural holdings are being targeted (all/large/small), what their sources of income are supposed to be and which production and economic activity they are supposed to be engaged in. At least at the EU level, policy documents have never allowed for a precise definition of these elements for different reasons, ranging from objective problems with fragmented farm ownership and specificities in agricultural taxation to political charades.

Anybody engaged in thorough agricultural policy analysis knows that in the majority of MSs, there is a lack of precise information regarding the economic and income status of rural households. Thus, the image of the economic situation and the influence of agricultural policy on this situation is quite blurred, as are agricultural policy priorities. How can there be clear goals and targeted measures if there is no clear image regarding the crucial question that they are addressing?

For decades, support mechanisms have been changed, adjusted and renamed, yet still the majority of budgetary transfers reach the same type and size of producers. Caught in a clinch of particular interests of individual MSs and interest groups, policymakers at the EU level have not been able to untangle this Gordian knot. Will is lacking, as is (not unrelatedly) factual information regarding the situation; meanwhile, structural change is treading a path of its own, while the majority of support is handed to those who should not receive it if objective economic criteria were applied. We can therefore no longer speak of an income policy, but of one of societal redistribution; one that, due to its mainly area-based measures, favours the largest, and as a rule most influential and organized beneficiaries.

Naturally, the Commission recognizes this problem and is attempting to address it with its proposals (capping, complementary redistributive income payment, attention to small farms), but it does not do away with agricultural policy’s original sin of the mainly non-targeted income support favouring larger land owners and producers. The legislative proposal throws this hot coal in MS’s laps, where heterogeneity in clarity of vision regarding priorities and quality of data sources for policy planning and monitoring is even bigger. Considering the conditions in individual countries, it is likely that an important share of member states will not know where to put this Commission ‘gift’ and will probably attempt to maintain the status quo, adapting only to compulsory new demands.

The European Commission has played its part in obstructing serious strategic thinking. Due to internal (path dependency mentality) and international (WTO rules) political and administrative reasons, the two-pillar structure lingers; yet the form and amount of direct payments (per area payments with top-ups and very open conditionality) leave little room, if any, for serious income, let alone social, policy to take place.

Naturally, the key question is actually how to clearly define needs without incurring the wrath of some interest groups. In a period of rampant populism and pragmatism, including that of European governments, no decisive moves are to be expected in the majority of MSs, as such moves bring no political points. On the contrary, they introduce additional conflict into a political field that is, in the end, not that important in the general political context; it is simply about who gets how much money and for what.

Heretical suggestions, like a universal basic income for workers in agriculture that could improve the economic situation of the most vulnerable and have both territorial and social effects in rural areas, are of course out of the question. Better to adhere to area-based politics supporting everything from “income stability” to “competitiveness”. Even discussing different income policy measures would be a loud and clear statement that the agricultural policy of the past few decades has been little more than a thinly veiled, poorly executed substitute for a serious social policy, its good intentions additionally twisted by particular interests; and clear statements seem outside of the remit of current agricultural policy discourse.

Agricultural policy for whom?

Another fundamental field where the deficiencies of the CAP’s strategic logic become prominent is of course environmental protection and conservation. The increasing inclusion of environmental considerations into agricultural policy is a reflection of its attempts to be more societally relevant. This is in stark opposition to its scope in the past, when agricultural policy was strictly sectoral, in the domain of agricultural ministries and interest representatives.

At the EU level, environmental concerns are clearly stated. Many commentators, especially representatives of environmental organizations, criticize the policy for exploiting this (legitimate) societal concern to maintain the size of the agricultural budget and thus the political power of the agricultural sector. The Commission is forced to navigate the waters between the Scylla of agricultural income politics and the Charybdis of environmentalists’ invocation of widespread destruction of nature due to agricultural practices. Perhaps the European Commission could be more decisive: it is a large ship it is steering towards change, not a rubber boat.

Unfortunately, environmental protection is not exempt from a lack of clear identification of needs. While perhaps in this field the quality of indicators exceeds that of the field income needs, the main challenge of this policy lies in deficiencies knowing the real situation and in understanding agriculture’s concrete effects on nature and the environment, and especially in setting environmental priorities in agriculture.

In a considerable number, if not in all MSs, decision-makers and agricultural pressure groups consider environmental priorities to be a necessary evil, imposed by Brussels under the influence of (irrational) environmentalists. Most agricultural administration and decision-making is, at least in the East and South, still permeated by productivist logic; they are not convinced by such arguments, but view them as superfluous administrative constraints.

This conflict will likely not be resolved with strategic planning at the national level, at least in most administrations. Rather, the rift will deepen. In many countries, incentives to conduct a serious environmental policy will be weakened with the transfer of strategic planning to the national level. This pitfall is apparently recognized by the Commission, likely due to the influence of DG Environment, as it is introducing safeguards, such as minimal compulsory percentages of funds allocated to environmental protection and a new green architecture (the eco-scheme). Naturally, this is opposed by some MSs, who demand less stringent environmental conditioning. To be frank, this does significantly constrain strategic planning and enforces Brussels’ dictate.

We could also discuss other priorities of agricultural policy highlighted in the proposals and point out the weaknesses in the explanation of needs, choice of mechanisms and thus potential for serious application of intervention logic in MS strategic plans. Risk management, rural employment and poverty, the role of knowledge and the increasingly societally relevant issue of agriculture and food, are more touched upon than strategically determined, as opposed to the two fundamental fields mentioned above. Moreover, in most of these fields, the evidence base available for planning and evaluation is quite weak. The extent to which MSs consider these priorities is left to them, but they are certainly fated to be marginal topics.

With perhaps some exceptions, MSs are not likely to address these societally relevant topics (food, employment, poverty), nor to apply systemic tools (knowledge, risk management) to bring about change; most countries neglect these topics due to their entanglement in redistribution logic. It is difficult to ignore the impression that the Commission only addressed these topics to free itself of responsibility for them in the sense of ‘We know these are important topics, here are some tools, now you deal with them.’ MSs will probably follow suit: invoke these issues and their importance to justify the policy and then blame a lack of (and even decreased) funding for their ‘inability’ to address them. In some MSs, this is already taking place. Hopefully this kind of behaviour will not be applied by all states; perhaps there will be a breakthrough for some topics.

The concealed conflict in discourses

There are additional obstacles to future strategic planning of the CAP. We may expect the new approach to widen the East(South)/West(North) divide. Agricultural policy discourses and their understanding are quite different. They are influenced by objective historical, structural and economic differences in the agriculture and rural areas in different parts of the Union. These differences have not yet been adequately recognized by the EU decision makers.

Measures to compensate for the lagging economic development of the agriculture of the East(South) states behind the West(North) have only been partially successful. Moreover, the CAP is unable to address rural (un)employment, depopulation and poverty in the East(South). The developmental needs here are different and the implementation of the CAP so far has been administratively and financially too demanding to benefit the majority of the rural population, with the exception of rural elites with the capacity to acquire extensive EU funding. This is of course a harsh statement based on the author’s personal experience and difficult to prove, owing to a lack of good records.

While tackling strategic planning will not be a simple task for any administration, agricultural policy-makers in the East (South) of Europe could have difficulty recognizing the nature and causes of the issues they face and addressing complexity to change the situation. And while there may be good intentions on the Commission’s part to allow MSs as those best acquainted with their own needs to deal with them in their own way, the involvement of political elites in interest-based redistribution is too obvious for the author to be optimistic about the results of this process.

Risks in policymaking wear a human visage

The scope of strategic planning is also crucially dependent on the programmers and administrators of agricultural policy. Implementation is in the hands of state and regional bureaucracies, which have until now been strongly engaged in meeting Brussels’ demands, living in fear of audits and low absorption of funds.

Though differences between parts of the EU in the quality and functioning of administrations are enormous, certain challenges are common. Even a quick review of Rural Development Programmes, which must already now be planned using strategic thinking, indicate not only large differences in quality, but ensnarement in a bureaucratic, emulating logic, path dependency and a distribution of funds based on political interests.

Strategic planning is supposed to be a creative, intellectual and democratic endeavour, which requires excellent staff and a comprehensive approach. Will civil servants in MSs be up to the challenge? The common, populistic practice of asking stakeholders what kind of measures they might prefer certainly does not contribute to a clear intervention logic. It is neither proper nor democratic to ask someone who depends on the public purse for his or her survival, how much funding and under which conditions they should receive it.

The complexity of modern agricultural policy, as reflected in the European Commission’s proposal, requires multi-disciplinarity, good analytical bases, creative solutions and, of course, a democratic exchange of views on the various options and effects of the proposals. The proposal for a European Network for Agricultural Policy, which would upgrade the existing Rural Development Network, should support the exchange of opinions and democratic decision-making, but it will not in itself provide a higher quality of planning. More radical moves are needed, and above all, more investment in human resources and modes of operation of the responsible ministries.

As in other parts of modern society, we should rediscover “professionalism” and assign it the same, if not higher, importance as apparent “democracy”, which all too quickly becomes interest-based and populistic. In truth, probably in most Member States, civil servants are not sufficiently trained for quality strategic planning. The deficiencies also arise from the position of agricultural officials in society, inappropriate and narrow education and lack of training, poor quality of management and politicized state administrations.

There is no other way but forward

CAP strategic planning introduced by the European Commission exhibits many flaws and faces many limitations. Its problems range from being caught in the logic of past measures, weak evidence bases, fixed shares allocated to specific purposes, lack of innovation, conflicting priorities, to deficiencies in planning and implementing structures; the list goes on. Does this mean we should oppose the Commission’s proposal? No, this would be very unwise.

The EU political system (unfortunately) allows for no other way of achieving changes other than through a trial-and-error process. Openly criticising policy in a constructive manner will allow us to introduce changes more easily and to achieve a more modern policy that meets society’s requirements, rather than serving smaller groups of farmers. Therefore, introducing CAP strategic plans is a first, necessary, but not sufficient step towards a more efficient and effective policy. For one who believes in the EU project, a Common agricultural policy that could develop into a Food, environmental and rural policy, is a necessity.

So the question is not how to get rid of this pesky strategic planning, but how to execute it better and mitigate the risks that come with its enactment. This requires serious consideration. We offer some suggestions for its improvement.

The first is certainly improving evidence bases and really using them as indicators of state and of the effects of policy. This does not mean only the improvement of income and environmental indicators, but also of those pertaining to social issues (e.g., indicators for rural poverty, quality of knowledge creation and transfers), where the data framework is relatively poor and incomplete. These indicators should also be given a much higher level of importance, like macro-economic indicators, which are used in public debates and are the basis of decision-making. Naturally, this is a long road, but we should embark upon it as soon as possible, and force policy to address them.

Secondly, more innovation should be allowed in designing measures. The current system is restrictive: states can only choose measures and adapt them; some measures are compulsory. In a way, this is understandable and intended to prevent renationalisation of policies and to achieve environmental goals. On the other hand, it limits strategic planning and flexibility of MSs in adapting to their situations. In an appropriate framework, proposals could be bolder and allow for innovative concepts (e.g. cooperation for addressing environmental issues or for strengthening agri-food chains). The crucial constraint here is income policy, which is frozen into per-area payment thinking.

Thirdly, quality of functioning demands substantially more work with staff, institutions and decision-making structures. Being from a New MS, I have had the insight of personally witnessing the strengthening of the administration through training and twinning, and even of the quality of high-level politicians, in the pre-accession period. All this more or less stopped after accession, and the process of European integration, as well as the improvement of administration, has been halted. There are trainings, workshops, exchanges etc., but apparently they are not enough; they should be strengthened and improved. It is encouraging that Commissioner Hogan announced several times that the Commission intends to fund the preparation of the Strategic Plans and to provide technical assistance to this end.

This touches upon the fourth issue, i.e. better strategic planning at the EU level. Approving, monitoring and evaluating programmes demands highly qualified, professional and cross-disciplinary staff. Without belittling their important contribution, I believe that this goes beyond the purview of the competent desk officers, who have so far been an important, if not the key, element in assessing Rural Development Programmes. The Commission also needs to raise the level and quality of operation. Is it really so unacceptable to formally invite independent assessors from outside official structures as referees?

Strengthening the internal and external think-tank apparatus is a prerequisite for better governance with strategic planning.

We conclude that the introduction of strategic planning presents a special challenge for both agricultural economists and other professional profiles (from both natural and social sciences) engaged in this kind of work. If strategic planning is and should be the way forward in agricultural policy, it should be included in university education. A system of specialist training should be developed. Support should be offered to institutions at both the national and Union level that will intensively work on data sources, evaluation, impact assessment and other forms of analytical support to planning. In truth, these institutions and human resources are seriously lacking at both levels and this probably also represents a threat to the success of (the attempt at) strategic planning. If the Commission’s proposals speak of necessary investment into knowledge, this also includes skills and capacities that can support quality CAP strategic planning in the future.

This post was written by Emil Erjavec, University of Ljubljana

Update 23 June 2018. The slides accompanying this presentation can be downloaded.