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Bringing Evaluation into the Policy Cycle

CAP Cross Compliance and the Defining and Re–defining of Objectives and Indicators

Published online by Cambridge University Press:  20 January 2017

Emanuela Bozzini  and
Jo Hunt
Emanuela Bozzini
Affiliation:
University of Trento
Jo Hunt
Affiliation:
University of Cardiff
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Abstract

This contribution seeks to overcome the isolation of evaluation studies fromthe broader field of public policy analysis. Using as a case study the hybrid regulatory tool of cross compliance under the Common Agricultural Policy, the article charts the ongoing incorporation of ex ante and ex post evaluation processes over a ten year period, during which three major legislative reforms were undertaken. Anchoring its approach in the public policy work of Kingdon, the article emphasises the significance of the plurality of actors involved in the evaluation processes, the importance of timing, as well as the challenge to models of policy processes based on assumptions of rational linearity. In particular, the article demonstrates how the dis–ordering which may be observed in the stages of the policy process may equally be seen in the stages of policy appraisal. A particular focus is placed on the way in which objectives and indicators are defined and re–defined over time. The case study demonstrates that through policy appraisal, policy makers may learn what is, and what is not capable of being measured, which feeds back into the re–setting of objectives.

Type
Symposium on Policy Evaluation in the EU
Information
European Journal of Risk Regulation , Volume 6 , Issue 1 , March 2015 , pp. 57 - 67
Copyright
Copyright © Cambridge University Press 2013

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References

1 For an overview, see Bradley, Dylan, Dwyer, Janet and Hill, Berkeley, ‘The Evaluation of Rural Development Policy’, 9 Eurochoices (2010), pp. 15–20 CrossRefGoogle Scholar; Hill, Berkeley, ‘Understanding the Assessment (Evaluation) of the CAP and Rural Policy’ in Berkeley Hill, Understanding the Common Agricultural Policy, (Oxford: Earthscan, 2012)Google Scholar. Evaluation practices have taken longer to incorporate into the larger and longer stablished of the two pillars of the CAP (centred on the system of financial support to farmers which grew from the original commodity regimes) than in the co–funded second pillar, on Rural Development policy. From 2014, a Common Monitoring and Evaluation Framework will apply across the CAP.

2 Hoerner, Julian and Stephenson, Paul, ‘Theoretical Perspectives on Approaches to Policy Evaluation in the EU: The Case of Cohesion Policy’, 90 Public Administration (2012), pp. 699–715.CrossRefGoogle Scholar

3 A notable exception is Hill, Understanding the CAP, supra note 1; compare with Garzon, Isabelle, Reforming the Common Agricultural Policy: History of a Paradigm Change (Houndsmill: Palgrave MacMillan, 2007)Google Scholar; Cunha, Arlindo and Swinbank, Alan, An Inside View of the CAP Reform Process (Oxford: OUP, 2011)CrossRefGoogle Scholar.

4 Hill, ibid., (this work explicitly connects the CAP and the policy process); Hoerner and Stephenson, ‘Theoretical Perspectives on Approaches to Policy Evaluation’, supra note 2.

5 Turnpenny, John, Adelle, Camilla and Jordan, Andrew, ‘Policy Appraisal’ in Araral, Eduardo et al, Routledge Handbook of Public Policy (Oxford and New York: Routledge, 2013), pp. 244 et sqq., at p. 247.Google Scholar

6 Ibid., at pp. 248-249.

7 Kingdon, John, Agendas, Alternatives, and Public Policies, 2nd ed. (New York: Longman, 2010).Google Scholar

8 Ibid.

9 Ibid.

10 Ferrer, Jorge Nunez and Kaditi, Eleni, The EU added value of agricultural expenditure – from market to multifunctionality – gathering criticism and success stories of the CAP (Brussels; European Parliament, 2007).Google Scholar

11 Which, of course, will necessarily draw directly on national experiences.

12 On the history of audit in the EU, see Harlow, inter alia Carol, Accountability in the EU (Oxford, OUP, 2000), Chapter 5Google Scholar; Laffan, Brigid, ‘Auditing and Accountability in the EU’, 10 Journal of European Public Policy (2003) pp. 762–777.CrossRefGoogle Scholar

13 Eg, Leeuw, Frans, ‘Auditing and Evaluation: Bridging a Gap, Worlds to Meet?’, 71 New Directions for Evaluation (1996), pp. 51–60.CrossRefGoogle Scholar

14 Paul Stephenson, ‘Reconciling audit and evaluation? The shift to performance and effectiveness at the European Court of Auditors’, this issue.

15 Regulation 1782/2003 establishing common rules for establishing direct support schemes under the CAP and establishing certain support schemes for farmers, OJ 2003 L 270/1.

16 Ibid., Annex III. The Food Safety and Animal Welfare requirements were phased in, during 2006 and 2007.

17 Commission Communication Mid Term Review of the CAP, COM(2002)394 final, at p.8.

18 Ibid., at p. 21.

19 Michael Cardwell, The European Model of Agriculture, (Oxford: OUP, 2004).

20 Regulation 1782/2003, at para. 2.

21 Supra note 17, COM(2002) 394 at p. 10.

22 Regulation 1782/2003, Article 7(1).

23 Council Regulation 1605/2002 on the Financial Regulation applicable to the general budget, requires the economy, efficiency and effectiveness of spending policies to be assessed, and ex ante and ex post evaluations to be conducted, OJ 2002 l 248/1, at para. 11.

24 European Commission, CAP Mid Term Review Proposals, Impact Analyses, February 2003, at p. 36, see http://ec.europa.eu/agriculture/policy-perspectives/impact-assessment/mid-term-review/rep_en.pdf.

25 Meri Juntti, ‘Riding the Green Wave in the European agriculture sector? A discourse analysis of the new cross compliance mechanism’, CSERGE Working Paper EDM 06-15, ceserge.ac.uk.

26 Ibid.

27 Regulation 1782/2003, Article 8.

28 Report from Commission to Council on the application of the system of cross compliance, COM(2007)147.

29 Ibid., at para 1.

30 Ibid.

31 This report led to a minor legislative revision in 2008, Council Regulation 146/2008, inter alia allowing for exclusion of ‘minor’ infringements.

32 A Partnership between the Institute for European Environmental Policy (UK) and Oréade–Brèche Sarl (France).

33 Allience Environnement, Evaluation of the Application of Cross Compliance as Foreseen Under Regulation 1782/2003, Prepared for DG Agri, July 2007.

34 Ibid., Part I, Descriptive Report, p. 4.

35 Ibid., Part II, Replies to Evaluation Questions, p. 4.

36 Ibid., at p. 5.

37 Ibid.

38 Ibid., at p. 64.

39 Ibid., Part I, at p. 4.

40 Court of Auditors Special Report No 8/2008, Is Cross Compliance an Effective Policy?, The Commission's reply to the Court's concerns draws on certain findings from the AE report, for example, to demonstrate that clear objectives were identifiable.

41 The Commission's failure to follow the requirements of the Financial Regulation and a range of DG Budget guidance documents are highlighted in this regard, Court of Auditors Report, p. 35.

42 Court of Auditors Report, at para. 84.

43 Ibid., at para. 16.

44 COM(2005)509.

45 See for example, October 2006, Rolling Simplification Action Plan; November 2007 Evaluations of administrative burdens; COM(2009) 128, A simplified CAP for Europe – A success for all; and SEC(2009) 1601, the list of 39 simplification suggestions made by delegations to Council, ‘about one third of the 39 proposals concerned the matter of cross compliance’, at p. 7.

46 Council Regulation establishing common rules for direct support schemes under CAP, OJ 2009 L30/16.

47 SEC(2008)1885, 20.5.2008, Section c.2.

48 SEC(2008)1885, at p. 36.

49 The Commission additionally cites its clearance of accounts procedure as a source of information.

50 COM(2007)147.

51 Nilsson, et al, ‘The Use and Non–Use of Policy Appraisal Tools in Public Policy Making’ 41 Policy Choices (2008), pp. 335 et sqq.Google Scholar

52 SEC(2008)1885, at para 5.

53 IA 2, SEC(2008)1886.

54 On file with authors.

55 Special Eurobarometer, ‘European Agriculture and the CAP’, 2007, next scheduled for 2014; approval ratings of over 80 % apply to cross compliance for food quality (86 %), animal welfare (84 %) and environmental protection (83 %).

56 Evaluation of the Implementation of the Farm Advisory Service, conducted by ADE (Belgium), in collaboration with ADAS, Agrotec and Evaluators.eu, December 2009.

57 Regulation 73/2009. OJ 2009 L 30/16; A Commission Report followed the external report, COM(2010)665 final.

58 Evaluation of the FAS, Supra note 56, Final Report, Evaluation Part.

59 Ibid., at p.48.

60 Polakova, Jana et al, Addressing Biodiversity and Habitat Preservation through measures applied under the CAP, Prepared for DG Agri, Contract No.30-CE-0388497/00-44 (IEEP; London, 2011).Google Scholar

61 In particular, through the inclusion of the Birds and Habitats Directives, and relevant GAEC.

62 Supra note 59, at p.84.

63 COM(2010)672.

64 Regulation 1306/2013.

65 Main Report, SEC(2011)1153 final/2.

66 Ibid., Annex 11B.

67 Ibid., at p. 5.

68 Ibid., at p. 6.

69 Ibid., at p. 6.

70 SEC(2011)1153 final/2, Annex 2E on cross compliance.

71 Ibid., at p. 2.

72 Ibid., at p. 2.

73 Regulation 1306/2013, on the financing, management and monitoring of the CAP OJ 2013 L 347/549. Following the move to co–legislation in this area, the impact of the relevant EP Committee is notable.

74 The ‘greening’ dimension, and with it the prospects for enhanced contributions to environmentalsustainability was also undermined in the final version.

75 SEC(2011)1153 final/2, Annex 2E, at p.1.

76 Regulation 1306/2013, preamble, at para. 54.

77 As is now an expectation: see Commission Communication on Regulatory Fitness, COM(2012) 746.

78 Regulation 1306/2013, Article 110.