Inadequate involvement of stakeholders in consultations on the Strategic Plan of the Common Agricultural Policy
The CAP Strategic Plan was adopted without quality consultations, and so it lacks the measures that would have been included if opinions of all relevant stakeholders were taken into account while drafting it.
The European Union implements around a dozen common policies at the level of the whole Union, and among them is the Common Agricultural Policy. For each six-year program period, these policies are evaluated and adjusted in order to better respond to the needs and demands placed before them. This year, the Common Agricultural Policy celebrated the sixtieth anniversary since its initial adoption, and agriculture as a strategic branch, not only of the EU but also of each of the member state, is a very sensitive area that is important in many respects. Thus, it is not surprising that when harmonizing attitudes and determining the direction in which agriculture will develop in each subsequent program period, numerous challenges arise.
Given that the Common Agricultural Policy directly or indirectly affects the lives of almost all residents of the EU, it is understandable that various interest groups are represented in the planning process – small or large agricultural producers, manufacturers of mechanization, fertilizers or pesticides, nature conservationists, ecological producers, public health sector, and many others. All joint policies and strategies adopted at the level of the Union should also be coordinated with each other in order to ensure a focused strategic approach at all levels. The common agricultural policy is at the very top of the financial resources allocated for its implementation at the EU level, and so it impacts the lives of an extremely large number of people.
The Strategic plan within the framework of the Common Agricultural Policy (CAP) for the period 2023-2027 is a strategic program document and the basis for using the European agricultural funds (EAGGF and EAFRD) and the application of CAP tools and instruments (direct payments, rural development, sectoral interventions). Every member state (or in some cases a region), including Croatia, joined its drafting. The needs and priorities of agriculture and rural areas in Croatia were determined on the basis of analysis carried out for nine specific objectives of the CAP and an intersectoral (horizontal) objective that should modernize the agricultural sector by encouraging and exchanging knowledge, innovation and digitization in agriculture and rural areas.
The Ministry of Agriculture started creating the first version of the Strategic Plan in 2021 behind closed doors, with the inclusion of whom they considered the key stakeholders. Two rounds of consultations with stakeholders were conducted, and based on these inputs, Croatia created the first version of the Strategic Plan of the Common Agricultural Policy, which it sent to Brussels for evaluation. At the beginning of April 2022, the Commission submitted 417 comments on the first version of the Strategic Plan. Comments with numerous recommendations on how to make this strategic document more aligned with EU strategies and policies were supposed to ensure that the next version of the document is improved on many levels. At the end of May 2022, the Ministry of Agriculture launched the third round of consultations, which were now open to the public and were divided into several segments according to the topics they were supposed to cover. During May and June, consultations were held on the topics of direct payments, green architecture, digitization, local development (LEADER, smart villages), youth, the forestry sector, sustainable livestock and karst pastures and AKIS, information and education of farmers.
Unfortunately, this step was not done properly, and in the end came down to box ticking. The basic draft of the Strategic Plan is a large document of over 800 pages, the understanding of which requires in-depth study since many determinants are interconnected and affect each other at different levels. In order to make coherent comments and suggestions for improvement, it is not enough to take a cursory look at those 800 pages; a detailed analysis is necessary. The deadlines for the document review and preparation for the discussion were sometimes shorter than 24 hours, and that was during the season of intensive agricultural work and deadlines for applications for the use of incentives in 2022. Within these short deadlines, even without the above-mentioned additional aggravating circumstances, the representatives of the networks and interest groups should have consulted among themselves so that the next day, at the discussion that followed the presentation, they could present the common positions of the organizations they represent. The representatives of the Green Forum, of which Biom is a member, had to consult with about forty associations in more than inappropriate deadlines. The Croatian association for organic food producers and the Croatian Federation of Heavy Draft Horse Breeders Association should have acted in the same way. All this resulted in a low turnout because, among other things, the consultations were held live in Zagreb, which made it even more difficult for numerous individuals and associations on whom the strategic plan’s determinants will have a direct impact in the coming years, to attend.
Weed removal – exclusively with a tractor!?
Although the response was very weak, there was at least one short discussion among the gathered stakeholders and representatives of the Ministry of Agriculture during each of the consultations, and some of them were covered by the media. The representatives of the Ministry had the difficult task of defending their own decisions about who can or cannot receive funds for the measure 10.1.16. Mechanical destruction of weeds within the rows of perennial plantations in the amount of 373.33 EUR/ha, seing that some users of the measure were unpleasantly surprised when their payment was stopped because they were removing weeds by hand, that is with a hoe, instead of mechanically with a tractor. The calculation of the amount the users of the measure should receive was made based on the price of a tractor operation, so the Ministry’s position was that weeds cannot be destroyed manually, although the point of this measure was to eliminate the use of herbicides to remove weeds, and encourage their mechanical removal. This practice is much better for the soil, groundwater, human health (less pesticide residues in agricultural products) and biodiversity, so restricting the usage on tractors use only is in no way justified.
At the end of the third round of consultations, a refined version of the Strategic Plan was drawn up and placed for a one-month public consultation in mid-August 2022 through the e-Consultation portal, which is available to wider public. Biom tried to make its contribution by commenting on the parts of the Strategic Plan that related to topics of the preservation of biodiversity in a direct or indirect way. We commented on the uneven representation of the sector in the Committee for monitoring the implementation of the Common Agricultural Policy, the inadequate compliance of operations with the objectives of the EU Biodiversity Strategy for 2030, as well as other green policies, and the excessive encouragement of burning wood biomass for the purposes of energy production instead of encouraging the use of burning the biomass that cannot be used in any other way. We also proposed improvements in the management of grasslands of high natural value, improvement in the quality and possibilities of using the advisory service, improvement in measures for non-productive investments in agriculture, and so on. A total of 13 reasoned comments. The responses of the Ministry to the comments submitted to them through the e-Consultation portal, were devastating: one comment was accepted (related to the representation of all sectors in the Monitoring committee), one was partially accepted (related to LIFE projects and co-financing), 3 were rejected and 8 of them were taken into account. We hope that the 8 comments will be taken into account when the existing Strategic Plan is modified or when a new Strategic Plan of the Common Agricultural Policy will begin to be drawn up in a few years. The final version of the Strategic Plan was finally sent to Brussels and was adopted by the European Commission at the end of October 2022, and from January 1, 2023, its application began.
We didn’t give up, so we joined the working group for drafting the Ordinance on the implementation of direct support to agriculture and IAKS rural development measures for 2023. The working group started well, but unfortunately soon turned into a farce, and instead of holding the next planned meeting of the working group, the ordinance simply appeared on the e-Consultation site for a period of only two weeks, instead of the minimum of 30 days. The ordinance has 123 pages, and together with the appendices, the number rises to 342 pages. Still, despite the fact that the working group didn’t even finish its work, and the fact that neither the members of the working group nor the members of the Committee for monitoring the Strategic Plan of the Common Agricultural Policy were informed about the public consultation, 205 comments were received on the ordinance. Biom commented on a total of 14 articles related to extensive management of pastures, intensive maintenance of ecologically significant areas, preservation of lawns of great natural value, grassing of permanent plantations, maintenance of dry walls, maintenance of hedges, improved maintenance of inter-row space in perennial plantations, mechanical destruction of weeds within rows of perennial plantations and animal welfare payments.
Of all the proposed changes, only two minimal interventions in the text were accepted. Those included the addition of the term puddles next to ponds and lakes, which are one of the elements of ecologically significant areas eligible for financing, and addition to the measurement of the width of drywall related to the same intervention. Other comments were not accepted with the explanation that the Strategic Plan must first be changed in order for the proposed changes to be possible, or were placed in the acknowledged category with a similar explanation. It should be noted that we did not post any comments related to the protection of the Corn crake bird (Crex crex) and the protection of butterflies on permanent grasslands through the e-Consultation, since we made numerous comments on those issues while being part of the Commission for the drafting of the ordinance on the implementation of direct support to agriculture and IAKS rural development measures for the year 2023. While the Strategic Plan was still in the early stages of development, based on the request of the Ministry of Agriculture, Biom made recommendations for improving the intervention for the protection of the Corn crake bird based on a study of the impact assessment of the pilot measure for the protection of the Corn crake bird (Crex crex) which is part of the Rural development program of the Republic of Croatia for the period 2014 – 2020. Despite this, none of the proposals made it into the Strategic Plan, and now the Ministry of Agriculture claims that the Strategic Plan must first be changed in order to be able to change the Ordinance.
Unfortunately, the consultations carried out by the Ministry of Agriculture for the development of important programs and regulations clearly show that there is still a long way to go before stakeholders are perceived as partners who can contribute to better policy and its implementation. The consultations for the CAP Strategic Plan were done in late spring and early summer, in the midst of agricultural work, the communication was inadequate and the deadlines were too short. Therefore, the contribution of the stakeholders was very limited. The example of the Ordinance which was adopted during the winter when farmers had more time on their hands clearly shows that although the deadline for commenting is very short, the stakeholders are very interested and have something to say. However, precisely because the CAP Strategic Plan was adopted without quality consultations, it lacks the measures that would have been included in the Ordinance if it had been drafted taking into account the opinions of all relevant stakeholders.
We will certainly not give up, but will continue to make our suggestions for improvement. We will also monitor the implementation of the adopted Strategic Plan to ensure that the interventions and operations in our focus are available to potential users. And in the end, to make sure that the taxpayers’ money intended for preservation of biodiversity and reduction of the negative impacts of agriculture is indeed used for these purposes.