‘Simplification of the CAP is not simple’

Simplification of the CAP is not simple, according to Professor Alan Matthews, who says that while EU Agriculture Commissioner Phil Hogan has promised to simplify the CAP, it may be so easy.

Prof. Matthews says simplification of the CAP is anything but simple, and this is the case for a number of reasons.

“One is that there are various stakeholders involved, and what may be a simplification for one can imply additional burdens for others. For example, it may make life simpler for the EU Commission if there is a single, uniform scheme across the 28 EU member states, without exceptions and without flexibilities.

“But this does not necessarily mean a lower administrative burden for national administrations or farmers – the initial proposal to abolish the SAPS scheme in 2014 is a case in point.”

He goes on to say that the EU Commissioner’s plan is, intriguingly, called a simplification and subsidiarity strategy, suggesting that he sees giving member states greater flexibility in implementing the CAP as a route to lower administrative burdens.

“Indeed, allowing member states and farmers flexibility to find the most appropriate way to achieve given targets and objectives can lead to simpler and less burdensome regulations, because they are not imposed from outside without regard to local needs and circumstances.

“But they may also make it more difficult for the Commission to monitor their effectiveness (as the hostile reaction from the environmental NGOs to the proposal that Member States could substitute equivalent schemes for the three greening obligations seemed to suggest).”

Good Policies

Good policies should be targeted policies, he says.

“However, more targeted policies despite their better outcomes often have higher administrative costs as a result of implementing more complex policy designs.

“Armsworth and colleagues, in a 2012 paper entitled ‘The cost of policy simplification in conservation incentive programs’ noted that the overall biodiversity benefits (in this paper, measured as the density and species richness of the bird population) of more complex policies were potentially so great that they could justify additional administrative costs of up to 70% of the payments that would otherwise be given to farmers. Does simplification make sense in that context?”

The EU Commissioner’s CAP agenda would seem to extend to policy simplification as well as technical simplification, particularly in the case of the new system of direct payments, he says.

“Although he was careful to state that any changes should ‘not re-open the basic policy decisions of the 2013 reform in this area’, it seems inevitable that policy simplification will be associated with at least a perceived shift in policy focus. This is more likely given that sufficient time will not have elapsed to assemble enough evidence on what is working and what is not.”

Depending on the ambition of the proposals when they see the light of day, we may well see a re-run of some of the battles started in the debate on the 2013 CAP reform, particularly between those seeking to maximise the opportunities for production and those concerned with reinforcing the idea that direct payments should be directed to the production of public goods, he says.

“Overall, a careful reading of the commitments suggests that what we can expect by the end of this year is a new version of the DG AGRI rolling simplification action plan, with perhaps a few specific legislative initiatives where work is well advanced.”

Professor Alan Matthews and a number of other European experts write a CAP reform blog with news, views and analysis on the CAP. This is an abbreviated version of Matthews’ original ‘Simplification as a top priority in 2015‘ piece.