Original publication: October 2018
Authors: Emil Erjavec, Marko Lovec, Luka Juvančič, Tanja Šumrada and Ilona Rac (Ljubljana University)
Short link to this post: http://bit.ly/2O9222C
The proposed EC Regulation (COM (2018) 392) is introducing comprehensive strategic planning at the MS level as one of the key new elements of the future CAP. The goal of this study is to assess the design of the new CAP Strategic Plans with a specific focus on Title V of the proposal COM (2018) 392. The analysis is based on a qualitative assessment of the CAP new delivery model, detecting possible risks at both, EU national levels in pursuing the CAP specific objectives and elaborating suggestions for improvements. The study draws on the complementary use of three main sources of information: i) meta-analysis, i.e. an in-depth review of available primary and secondary resources; ii) primary data-gathering to additionally explore positions and opinions of stakeholders; iii) qualitative assessment based on the Evidence-based decision making (EBDM) theoretical framework.
General assessment of the proposed Strategic planning governance
The new delivery model is seen as a step in the right direction, as this is the foundation of modern public policy governance. There will be also greater acceptance of the legitimacy of these policies.
The proposal draws on the established model of strategic planning of Rural Development policy. The proposal gives some prospects for simplification, but essentially the governance system is not changed and contains all the shortcomings of the previous arrangements. The key question should therefore be how the proposed Strategic plans will be applied in the real world and whether it will bring about a more effective policy.
Necessary accountability mechanism for strategic planning is weak
Limited accountability and ability to establish efficient intervention logic are serious gaps of the new delivery model. The current legal proposal does not frame the proposed CAP specific objectives in a results-oriented manner. Three objectives relevant to the environment and their relating indicators are not directly linked to existing environmental legislation. The current proposals are also not clear on to the method of quantifying the baseline situation. The study also questions the proposed exemption of background documents and analyses envisaged in the annexes of national Strategic plans from the evaluation process.
The process of strategic planning is left to the capacities and ingenuity of the Member States, without guarantees that the performance at the EU level will be measurable as the national priorities emerge from SWOT analysis and may not necessarily reflect the EU-level priorities. There are limited compelling incentives for Member states to make efforts for better policies. The procedure related to the approval of the Strategic plan is practically the only mechanism in the EC’s power for ensuring targeted and ambitious strategic planning. Therefore, it is of importance the Commission is empowered to make a proper qualitative assessment of the Strategic plans. CAP strategic plans should contain a satisfactory and balanced level of consultation between stakeholders and involvement of other public authorities, and that the Commission is well equipped to assess the plan within a reasonable period’s length. The adoption procedure should be more formalized, with the stakeholders’ opinions at national level taken into account. This can improve the quality of the design, as well as the legitimacy of the document. Additionally, effective cooperation between different public authorities will be essential to ensure the successful drafting and implementation of the strategic plans.
Clearer objectives and division between EU and national levels
Objectives should be quantified at the EU level and if associated legislation and objectives exist in other EU policies, these should be incorporated into the quantified definition of objectives in the CAP legal proposals. The legislative proposal requires a better demarcation of common EU and national objectives. In principle, commonly defined should be those objectives that add value when implemented on a common scale, while the objectives where the principle of subsidiarity is more salient should remain at the national level.
The current system in designing measures is restrictive: Member states can only choose measures and adapt them. Moreover, some measures are compulsory in order to prevent renationalisation of policies and to achieve societal goals.
Flexibility and quality of strategic planning at Member states level
Striking a right balance between flexibility, subsidiarity, a level playing field at the EU level and policy control is a very complex task. Given that CAP funds have historically been based on a ‘measure by measure’ approach, Member states have little experience in programming various CAP instruments in an integrated way. Developing planning and implementation capacities will be a major challenge for all Member States, especially for small ones and those acceding EU after 2004. Empowering Member states with greater subsidiarity may result in substantial administrative burden at MS level. Within chapter V of the proposed regulation, the section on simplification is empty and left completely to MSs, which means that the Commission is leaving this at their discretion.
The risks derive also from the varying capacity of actors in different Member States. Flexibility may also be associated with risks of a departure from the pursuit of common goals at the EU level. Therefore, the CAP proposals need to be accompanied by safeguards at the EU and MS level, in particular by ensuring the effective engagement with civil society both in contributing to the design and in monitoring the progress of Strategic plans. 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. This could conceivably cause falling standards and negative trends in individual MS, which would in turn result in further weakening of the common policy. An enlarged “technical assistance” budget could be used to improve the depth and quality of data collection. This budget should be extended to Pillar 1 of the CAP.
Improved monitoring of agricultural policy
The monitoring and evaluation procedures need to be defined more precisely and their quality improved in both parts of the policy cycle. The period 2021-2027 is a period of learning, in which the quality of data sources must be significantly increased, with systematic monitoring of the measures and their effects. Both Member States and EU bodies (JRC, EEA, Eurostat) have a role to play here. They see the utmost importance of strengthening the data sources related to needs analyses, and in particular, it is necessary to thoroughly reflect the appropriate data that will be employed as indicators for identifying and monitoring objectives.
We explicitly emphasize the role of data, indicators, knowledge and analyzes for more effective strategic planning and therefore a better agricultural policy. European Commission and Member states need to be required to provide reputable and independent scientific and technical evidence to support their choices. This will require establishment of a common platform with an open access to all strategic plans, progress and evaluation reports.
Proposed amendments to the regulation
Proposals for amending the draft regulation are the following:
- Strengthening the principle ‘no backsliding’ with the requirement to maintain at least absolute and relative share of support for climate and environmental objectives (art. 92);
- Strengthen the requirement to include the quantified objectives of the Strategic Plans resulting from environmental legislation and commitments;
- Strengthen the stakeholder consultation process with more binding requirements concerning the composition of parties involved in the process, joint decision-making, monitoring and evaluation. (Annex III);
- Include the criterion (Article 106) about “ambition and reachability of national targets in line with needs and the consistent use of intervention logic on the basis of available data”;
- Strengthen the Governance and Coordination System section with the contents of Annex III (or alternatively include the annexes for evaluation);
- In the Simplification section of the draft regulation, specify the reasons and relevance of the EU objectives;
- Include the mandatory annexes to the plan for the training and education of civil servants and stakeholders for the implementation of the Strategic Plans;
- Inclusion of impact and contextual indicators in the reporting and monitoring system, and reporting on their changes;
- The obligatory part of the report is also independent quantitative and qualitative public assessment of independent experts and groups at the EU and national level; and
- Compulsory share of technical assistance should be devoted to establishing databases and analytical support for strategic planning.
The period 2021-2027 will have to be 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 to be taken, stressing out the importance of collective learning and system building, in order to be able to implement better in the future.
The co-legislators should determine what the new delivery model is expected to achieve in political sense. If the aim is to provide more flexibility and political responsibility, we must act accordingly: to enable transparency, stakeholder involvement and positive competition between countries. Strategic plans should therefore be seen as a step towards strengthened capability and accountability of the policy on the long run.
Link to the full study: http://bit.ly/617-501
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