Interest Groups’ Influence in the CAP 2020 Reform: Environmental Policy Integration in light of a Paradigm Shift

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Interest Groups’ Influence in

the CAP 2020 Reform

Environmental Policy Integration in light of

a Paradigm Shift

Author: Jan Hauser Polzer (12772984)

Supervisor: Dr Robin Pistorius

Second Reader: Dr Philip Schleifer

Master Thesis Political Science

European Politics and External Relations

June, 2020

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Abstract

The Common Agricultural Policy (CAP) is the EU’s most extensive policy with the main task to distribute income support to European farmers. The current reform of the CAP involves a large number of interest groups that lobby to attain their preferences in the policy outcome. The farmers’ representatives have been facing increasing counter-lobbying efforts from environmentalist NGOs that perceive the CAP as fundamental for the achieving of the European climate targets. The agri-cultural sector, on the other side, had to comply with an increased amount of regulations and re-duced funding by the EU since the last CAP reform. Under this changed environment, this thesis analyses which interest groups prevail over their rivals. A special focus is set on environmental issues. Although the analysis cannot prove a clear dominance of either side, it illustrates that dif-ferent interest groups prevail in difdif-ferent policy areas of the CAP. The thesis concludes that the EU policy-making system prioritises preferences supporting the status-quo over preferences de-manding additional regulations. Consequently, environmental policy integration in the CAP re-mains limited.

Key Words: CAP, environmental policy integration, interest group influence, strategic

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Acknowledgment

First of all, I would like to thank my supervisor Dr Robin Pistorius for his continuous support and advice throughout the process of writing my thesis. The style of mentoring with several friendly inquiries during this, at times, very challenging period, were highly appreciated and did in the end guarantee the finalising of my thesis. Furthermore, I want to thank Mia Bivered for her methodological support and Jan Jakubov from the European Parliament for his expertise about the CAP policy-making process that exceeded the information found online. Last but not least, I thank my two good friends Basil Hürzeler and Sara Belgeri for proofreading my thesis and providing me valuable comments.

Table of Figures and Tables

Figure 1: Ordinary Legislative Procedure ... 15

Figure 2: Public Consultation ... 20

Figure 3: Percentage by Categrory of Lobby Organisation ... 21

Table 1: Preference by Main Players... 32

Figure 4: PA for main Issues ... 33

Table 2: PA of EPI-promoters and -opposers ... 36

Figure 5: Average PA per Interest Group in the EC ... 37

Table 3: PA per Policy Clusters ... 38

Table 4: PA per Policy-making Phase ... 42

Figure 6: PA in main Areas ... 43

Table 5: Coding of Copa-Cogeca's preferences ... 65

Table 6: Survey Questions for Preferences ... 65

Table 7: Preferences of general Groups ... 67

Table 8: Survey Questions for Salience and Public Opinion ... 69

Figure 9: PA by EPI-groups ... 71

Figure 7: Average PA by Interest Groups ... 71

Figure 8: PA per Advocate and Sector Type ... 72

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List of Abbreviations

ANC Area of natural or other specific constraints CAP Common Agricultural Policy

CSO Civil society organisation

COM AGRI Committee on Agriculture and Rural Development

COM ENVI Committee on Environment, Public Health and Food Safety DG Directorate-General

DG AGRI Directorate-General for Agriculture and Rural Development DG ENVI Directorate-General for the Environment

EC European Commission

EEB European Environmental Bureau EP European Parliament

EPI Environmental policy Integration MFF Multiannual Financial Framework NGO Non-governmental organisation PA Preference Attainment

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1. Introduction

The Common Agricultural Policy (CAP) is the EU’s financially most extensive and most integrated European policy (Détang-Dessendre et al. 2018). It amounts for 37.8 percent of the entire EU budget and is one of the biggest subsidy programs worldwide, distributing more than 40 billion euros in direct income support (Apuzzo and Gebrekidan 2019, Massot 2020a). The CAP’s current framework ends in 2020 and is therefore due to be revised. The policy outcome of this reform is exemplary for the path the EU wants to take in achieving its environmental targets. Sustainable regulations define the cleavages in the CAP’s policy making process stronger than ever before (Alons 2017). This is true for the EU party factions, the involved institutions as well as the non-institutional actors.

This thesis therefore analyses and assesses the different interest groups and their impacts on the decision-making of the CAP 2020 thus acknowledging the significant impact of non-institutional actors in the policy-making process of the CAP reform. The focus lies on environmental policy integration (EPI) in the CAP, respectively vertical EPI in differentiation to horizontal EPI. Vertical EPI “indicates the extent to which a particular governmental sector has adopted and sought to implement environmental objectives as central in the portfolio of objectives that the governmental body continuously pursues” (Lafferty and Hovden 2003: 12), whereas horizontal EPI “focuses on environmental co-ordination across policy sectors” (Alons 2017: 1606). This thesis focuses on ver-tical EPI within the agricultural sector which will henceforth simply be called EPI.1_{The interest} groups involved in the CAP 2020 reform have different means and methods and most importantly various preferences in the different policy areas of the CAP. The thesis analyses the impact these interest groups have on the EPI in the current reform. The research question therefore states fol-lowing:

Which interest groups are the most successful in attaining their preferences regarding EPI in the CAP 2020 reform?

As one of the first European common policies the CAP has undergone several reforms in the past (EC 2018a) concomitant with several paradigm shifts for policy-makers and the broader public

1 _{The thesis is not limited to EPI but will analyse the various contested policy areas in the CAP reform. The focus}

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(Erjavec et al. 2015, Alons 2017).2_{To cope with the newly identified challenges, the European} Commission (EC) has proposed a shift in the CAP’s objectives which for the first time officially recognises concerns about the environment (EP 2019a, EP n.d.a, Massot 2020b). The Commission has described the targets of the CAP 2020 as following: “A modernised Common Agricultural Policy will need to support the transition towards a fully sustainable agricultural sector and the development of vibrant rural areas” (EC 2018b: 12). Acknowledging the major significance of both the topics of sustainability and rural development, this thesis focuses on the former one because environmental issues are increasingly dividing the political sphere (Alons 2017) and highly influen-tial advocates can be found on both competing sides.

The subject of analysis is therefore the environmental policy integration. EPI refers to the imple-mentation of environmental objectives in policies (Lafferty and Hovden 2003, Alons 2017).3 Whereas the EU has established a reputation as “an environmental policy setter” in general (Conelly 2012: 303), the CAP’s significant impact for the EU on achieving its climate change targets has still largely been neglected (Alons 2017, EEB et al. 2018, Robijns 2018). Environmental con-cerns have already been influential in the construction of the CAP 2013 framework. The settings for the 2020 reform, however, have changed again. Environmental matters are receiving an in-creased focus worldwide and have become a priority in the EU’s agenda with the signing of the Paris agreement in 2015 and more recently the inauguration of the new Commission in 2019 (Apuzzo and Gebrekidan 2019, Matthews 2018a, Von der Leyen 2019).

The increased environmental concerns in the public were most exemplary seen in the 2019 Euro-pean Parliament (EP) election where the faction of the Greens gained several seats.This perceived shift in power has led to the resumption of demands for enhanced conditionality in farmers’ income support (EEB et al. 2018, Robijns 2018). Though the CAP is not a focus of the general public, environmental actors are increasingly focusing on it, since it manages 75 percent of the EU territory and is therefore fundamental for achieving the European climate targets (Eurobarometer 2017, Eurostat 2020, IEEP 2019a, Potočnik 2015).

The farmers’ interests on the other hand are continuously becoming less relevant for the EU, with agriculture only accounting for 1 percent of the EU’s economy (Eurostat 2020). Many farmers however are highly reliant on the CAP’s direct income support. Over the last ten years, it repre-sented nearly half of their income (EC n.d.) and agricultural prices caused by “macroeconomic factors, geopolitical tensions and other forces” have continued to decrease substantially since the last CAP reform (EC 2018a: 1). In contrast to the increased importance of the CAP for both the

2_{See section 3.1. for an introduction of the most recent paradigm shifts in environmental and agricultural policies.} 3_{See subsequent section.}

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achievement of environmental and farmers preferences, the budget allocated by the EU to agricul-ture has continuously been reduced and both the farmers and the environmental non-governmental organisations (NGOs) fear a shortcoming. These circumstances make the CAP’s current reform a highly contested issue, particularly in the case of EPI.

This struggle about the policy outcome of the 2020 CAP reform is not only fought on an institu-tional level. Non-instituinstitu-tional actors also have a decisive impact on EU policy-making (Coen 2009, Klüver 2011, Kerneis 2019). Considering the financial extent of the CAP, it is not surprising that it is one of the EU projects with the largest number of actors involved. During the Juncker-Com-mission there were supposedly 1305 lobbyists from more than 300 organisations attempting to divert the decision-makers (Integrity Watch 2019). It has been evaluated that the EPI was signifi-cantly reduced during the CAP 2013 negotiating process (Erjavec 2015). It is thus evident that the analysis of interest groups in their attempts to affect “policy outcomes generates important insights into the overall EU policy-making process” (Bunea 2013: 553).

After the following brief outline of the thesis’ structure, the second chapter covers the theoretical framework of the thesis. Starting with the literature about the concept of interest groups, respec-tively lobbying, the main assumptions to explain lobbying success are elaborated. The following subsection introduces the theory of strategic constructivism as theoretical basis for the analysis. The last subsection justifies the choice of method to measure interest groups’ influence in compar-ison to other occasionally used approaches.

The third chapter introduces the context for the policy-making process of the CAP 2020 reform. Firstly, the ideational context with the recent shift in paradigm is introduced before, in the first subsection, the policy itself and some relevant research in this field are elaborated. The following subsections capture the most relevant institutional, the EC, the EP and the Council, as well as non-institutional actors, Copa-Cogeca and the environmental NGOs, and explains their role in the CAP reform.

Chapter four covers the methodology of the analysis. Building upon the hypotheses given in the first subsection, the used models are specified, followed by the elaboration and operationalisation of the dependent, independent and control variables and the justification for the data used. The analysis is subject to chapter five that is structured in three parts along the hypotheses. It illustrates the results of the regressions constructed. Based on these results, chapter six assesses the hypotheses and discusses the theoretical and methodological choices of this thesis as well as rec-ommendations for further research. Finally, in the last chapter, a conclusion is drawn and lastly a brief outlook on the future of the CAP and particularly EPI in the agricultural sector is offered.

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2. Theoretical Framework

This chapter introduces the relevant theories and concepts that are considered necessary for the analysis and the understanding of this thesis. First, the key concept of interest groups is introduced. Secondly, the preference attainment method as the appropriate approach to measure lobbying in-fluence is elaborated. And lastly, the theory of strategic constructivism is explained.

2.1 Interest Groups

The concept of interest groups (or lobbying) and the regulations related thereto are a well-re-searched field in political science. Recently, this topic has been receiving particular attention be-cause of the EU’s attempt to adopt a Joint Mandatory Transparency Register (European Commission 2019b) as an advancement of the current voluntary Transparency Register. The subject, however, is not new at all. Interest groups play a considerable role in the EU policy-making process (Coen 2007) and the establishment of the EU is closely connected with lobbying. Since the creation of the European Economic Community in 1957 with the Treaty of Rome (Mahoney 2007) numerous interest groups have been lobbying the EU.4_{In 2019 the total number of registered EU lobbyists} has increased to close to twelve thousand (EP 2019c).

Organisations are lobbying the EU in an attempt to gain pivotal influence on certain policy out-comes.5_{Decision-makers are willing to trade the possibility of access and institutional information} in exchange for resources relevant for them that can be supplied by the interest groups (Chari et al. 2007). Relevant resources for decision-makers can take the form of information, financial sup-port, knowledge, expertise or providing them with legitimacy (Kerneis 2019). The latter one is of particular interest to EU institutions that are not directly elected because public authorities are struggling to act effectively when public support is fragile, “and certainly public support and media attention on environmental issues is not entirely stable“ (Conelly 2012: 138).

4_{Two of the oldest European interest groups are the two agricultural umbrella organisations Copa and Cogeca that}

will be introduced in subsection 3.3.1.

5_{Contrary to Alons (2017) the policy outcome is understood as the final policy and the preferences attained in this.}

What he considers as the outcome, the achieving of the objectives in the final implementation and performance of the policy is not of interest for this thesis. Therefore, I follow most of the literature on lobbying (Beyers 2008b, Dür et al. 2015, Klüver 2011, Thomson 2009) in understanding the policy outcome as the final policy framework.

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The EC therefore has the biggest interest in this form of supranational legitimacy provided by transnational interest groups (Kohler-Koch 2013). Furthermore, the EC is particularly dependent on the resources provided by interest groups because of their broad policy agenda and their limited expertise (Beyers et al. 2008a, Coen and Katsaitis 2013, Klüver et al. 2015). Alongside interest groups' direct lobbying efforts, they are constantly framing issues in their attempt to convince pol-icy-makers and entail a paradigm shift (Alons 2017, Kluger Rasmussen 2015, Saurugger 2018). As implication of this significant role lobbying takes in EU policy-making, interest groups have been facing a large amount of critique in the public. The large public consultation concerning the CAP reform held by the EC in 2017showed that “participants have the perception that large in-dustry and lobbyists have a disproportionate impact on the decisions made related to the CAP” (EC 2017: 69).

The critique lobbying is confronted with concentrates mainly on two aspects. First, insufficient regulations lead to a lack of transparency which is supposed to improve with the reform of the Transparency Register. The second main critique point focuses on the decisive impact of elite-bargaining because of the privileged access to the EU institutions for certain supranational organ-isations and the importance of the legitimacy they can provide (Greenwood 2007, Harris 2007, Mulcahy 2015). For the analysis of policy-making it is therefore essential to look at the lobbying success of the rival interest groups (Klüver 2011).

Whether interests of businesses or civil society organisations’ (CSOs) are more successful, is con-tested in the literature. Many studies support the critique of EU elite-bargaining. Mahoney (2007: 35) concludes that lobbying success is “biased in favour of wealthier business interests”. Coen (2009: 163) supports this view and argues that, founded on the information dependency of the EU institutions, “a distinct European business-government model has evolved”. This advantage of business interests’ representation concerning influence is traced back to “a set of structural ad-vantages” (Bunea 2013: 555, Coen and Katsaitis 2013, Eising 2007).

Other studies identify advantages in access for big businesses, however, do not find evidence for elite pluralism in the EU (Eising 2007, Kluger Rasmussen 2015). As abovementioned, results in the research on the conflict between business and civil society interests is contested. Dür et al. (2015: 951) argue “that business actors are, overall, less successful than citizen groups in the Euro-pean policy process” and find no impact of better access and resources of business actors on the policy-outcome.

Notwithstanding, a general consensus can be found about business organisations trying to prevent policy-change. Even though Dür et al. (2015) find CSOs to be lobbying more successfully, they

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recognise that businesses manage to maintain the preferred status-quo which is supported by other studies (Beyers et al. 2008a, Erjavec 2015).6

The success of interest groups to exert influence on the decision-makers highly depends on the policy context (Klüver 2011, Mahoney 2007 and 2008). “The relative size of lobbying coalitions, the salience, the complexity and the degree of conflict [of a particular policy] largely shape the ability of interest groups to succeed in shifting policy outcomes towards their ideal points” (Klüver 2011: 484, Bunea 2013, Dür 2008a, Kluger Rasmussen 2015, Mahoney 2007). The complexity of a policy issue affects the impact interest groups can have in shaping the policy-outcome. When the policy issue is highly complex the EU’s dependency on expertise is high and the policy-makers are more willing to include interest groups’ in the policy-making process, allowing them to influence it. When the policy issue is less complex on the other hand, the lobbying success is hampered (Bunea 2013).

Having median positions as preferences, makes it more likely for interest groups to attain their preferences in the policy outcome (Thomson 2009). This effect is closely related to the building of coalitions because interest groups with less median preferences are dependent on the creation of coalitions around common interests (Saurugger 2013). The correlation of salience, once again, relies on the coalition component. Salience has a positive effect if interest groups are part of the relatively larger coalition, whereas it has a negative impact if interest groups belong to a less powerful coali-tion (Klüver 2011). Bunea (2013) furthermore observed a positive correlacoali-tion between salience and the preference attainment of environmentalist interests.

Organisational characteristics, however, are mentioned as important factors too (Eising 2007, Bunea 2013, Junk 2016). Bunea (2013) in addition shows the importance of the group’s advocate type as an explanatory factor. Thus, business groups prevail when “European business federations are internally united, they lobby on highly technical issues […] and mainstream committees exam-ine proposals” whereas diffuse interests win when “European busexam-iness federations are divided, they lobby on highly salient and politicized issues, and they are faced with periphery committees with little co-decision experience” (Kluger Rasmussen 2015: 380).

Furthermore, a distinction between insider and outsider strategies can be made (Maloney et al. 1994). Whereas lobbyists pursuing an insider strategy are directly working together with the legis-lator, interest groups being more dependent on outsider strategies are mainly trying to shift the public opinion with campaigns (Ibid.). Business organisations limit themselves to insider strategy

6_{The EU’s co-legislation principle allows elucidation of the success in maintaining the status-quo as illustrated in}

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whilst, as shown by Gulbrandsen and Andresen’s study (2004), environmental NGOs rely more on a dual strategy approach, including both insider and outsider strategies. Many researchers ana-lysing lobbying influence have concentrated on either one of those. This thesis does not distinguish between outsider or insider lobbying but only how the combined lobbying efforts have shifted the policy outcome as similarly done by Beyers (2008b), Bivered (2019) and Junk (2016). This holistic approach allows to capture the broader picture of lobbying success.

Whereas interest groups’ influence in general as well as in EPI (Bivered 2019, Skodovin et al. 2010, Junk 2016) is well-researched the agricultural sector has barely been the focus of researchers. There are several studies focusing on stakeholders’ influence in the CAP (Alons 2017, Daugbjerg and Feindt 2017, Greer 2015, Henning 2009). However, no research has been conducted with a focus on interest groups, assessing their influence in comparison to each other in the context of the CAP. The current policy-making environment for the 2020 reform constitutes a further research gap which this thesis aims to fill.

2.2 Measuring Lobbying Influence

Several methods can be used to measure the influence of interest groups. The different approaches have advantages and disadvantages and should be well-chosen in relation to the findings sought to receive. The use of these different methods can partly explain why different studies result in dif-ferent results. Firstly, a definition of influence, respectively lobbying influence has to be decided on. The understanding of influence in this thesis follows Dür (2008: 661) and is thus understood as “an actor’s ability to shape a decision in line with her preferences.” Lobbying success is therefore understood as preference attainment which follows the definition of key researchers in the litera-ture on interest groups (Bunea 2013, Dür 2008a, Mahoney 2007). The concepts lobbying success,

influence and preference attainment are used interchangeably in this thesis.

Dür (2008a: 661) determines three challenges for the measurement of influence: “the existence of different channels of influence, the occurrence of counteractive lobbying and the fact that influence can be wielded at different stages of the policy process”. The three main methods for the analysis of interest group influence are: ‘assessing attributed influence’, ‘process-tracing’ and the ‘preference attainment method’ (Ibid.).

The assessment of attributed influence is considered unsuited because it “assesses perceptions of influence, rather than actual influence” (Ibid.: 566) which is particularly in the case of lobbying

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influence a significant disadvantage. Process-tracing has been the most frequently used approach in the literature with preference attainment gaining increasing popularity.

Process-tracing is an appropriate method because it respects rival explanations in its argumentation for process-causality and entails the opportunity to consider interviews to receive insights that are not accessible through other sources. Nevertheless, there are several problems with process-tracing as a method (Dür 2008a: 563): “The difficulties connected with collecting empirical evidence that is precise enough to cover all steps of a causal process; cross-checking evidence gained from inter-views against other sources; identifying a yardstick to assess what ‘influential’ means; avoiding in-ferences about influence from the level of interest group activity; and generalizing from small-N studies.” Furthermore, is process-tracing often considered too descriptive (Collier 2011).

This is why researchers have recently switched to the use of the preference attainment method which “has monopolised the research in the literature” (Vannoni and Dür 2017: 369). This is a positive development and clearly improves the comparability of studies. The preference attainment method assesses interest groups’ degree of preference attainment. This approach implies compar-ing the outcomes of political processes with the ideal points of the actors. Therefore, the degree of influence is calculated as “the difference between two absolute differences: between a group’s ideal position and the initial position of the lead ministry in the country, and between a group’s ideal position and the final national position” (Dür 2008a: 567). One of the main advantages of this method compared to the other two is the possibility to detect influence although nothing visible had taken place. As it would for example be the case when all lobbying efforts are secret.

However, there are two problems arising with this approach too. For one, the accuracy of the results may decrease if the interest groups do not honestly disclose their preferences. Secondly, the method struggles when other forces influence the policy outcome significantly. Such forces can lead to both an under- as well as an overestimation of interest groups’ influence. Former, in the case of counter-lobbying which leads to an assumption that the interest group was not able to exert influence whereas it actually avoided a policy-shift in an unfavoured direction. The overestimation of influence can happen when the interest group’s preference is backed by the general public opin-ion. It is therefore important to control for these other forces influencing the policy-making pro-cess. (Dür 2008a) The operationalisations and justifications of variables are given in chapter 4.

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2.3 Strategic Constructivism

A key factor in policy-making are the norms (or visions) actors formulate and pursue. “These vi-sions provide them with a sense of direction, but they rarely spell out rigid ideological or material goals” (Jabko 2006: 26) which entails compromises in policy-outcomes. Jabko (2006: 27) gives the example of the building of the EU market as a compromise between actors pursuing the long-term goal of a united free market economy and actors pursuing a socially oriented market economy. This shows how actors have different, even contradictory, objectives which results in an intermediate objective. Regarding EPI, Alons (2017: 1618) shows that “as long as institutional changes are not accompanied by a change in policy ideas, environmentally oriented policies will remain unstable and their effectiveness limited.” The analysis of norms however is challenging. Saurugger (2018) specifies that agents’ interests are influenced by various ideas and values and that they develop in different simultaneous subsystems. Although considering the importance of values, Saurugger (2018: 896) criticises the classical constructivist approaches of only paying secondary attention to “power relations and the strategic behaviour of policy agents”. She summarises it as follows (Ibid.: 888):

[..] in order to understand how actors think and how their ideas count in policy-making, one must take into account the way actors use ideas strategically. […] [T]his perspective allows us to reach beyond the dichotomy opposing rational choice and more interpretative approaches and helps us to best understand how ideas influence policy processes.

This is an attempt to overcome the struggle over whether stakeholders in policy-making are mainly driven by expressing their identity or by more strategic concerns about winning (see Finnemore and Sikkink 2001). A theory that combines these two aspects and therefore pays respect to Saurug-ger’s (2018) critique is strategic constructivism. Strategic constructivism is “primarily about political strategy as a causal factor of institutional change and only secondarily about the power of ideas” (Jabko 2006: 26). The goal of this adaptation of the constructivist theory is to determine in how far ideas and cognitive frames play a significant role in policy-making. Furthermore, it assumes that ideas are malleable objects that can be used for strategic purposes (Saurugger 2018). Whilst sup-porting the general constructivist assumptions that individual ideas and beliefs of actors are con-structed, strategic constructivism pays respect to the many actors with varying interests that affect the policy-making process (Saurugger 2013). It therefore attempts to highlight “the complex moti-vations of the political strategy” that leads to a particular outcome (Jabko 2006: 26) and is thus a well-suited theoretical framework for the understanding of lobbying impact in EU policy-making. Using strategic constructivism has advantages in dealing with the complexity of policy-making pro-cesses (Baird 2018) as well as with legitimation issues (Saurugger 2018), which are specific

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characteristics of EU policy-making and the CAP in particular. The use of strategic constructivism makes it possible to analyse “how the norms of business actors and the EU decision-making

insti-tutions have become aligned in policy” (Baird 2018: 120) and also takes into account “the parallel

emergence of intergovernmental economic governance, and the strengthening of powers at Euro-pean level” (Saurugger 2018: 29, also see Conelly 2012). Changes in policies are explained through conflicts amongst relevant actors, both institutional and non-institutional ones, which are assumed to occur constantly (Saurugger 2018).

Although strategic constructivism is still not widely used in interest group research, recent studies

have shown its appropriateness for the explanation of EU policy-making processes (see Baird 2018, Saurugger 2010) and it thus serves as theoretical framework for this thesis too.7

An important facet of strategic constructivism is its implication that the emergence of a norm does not necessarily lead to its acceptance and internalisation in a policy outcome and that the actors competing for influence through power struggles use normative framing of a policy as one of their most relevant lobbying strategies.

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3. Context of the Reform

This section elaborates on the paradigm shifts in EU agricultural politics in which the EPI in the CAP is taking place. Agricultural policies generally have a special status because the agricultural sector is treated significantly different from other economic sectors. The connected belief system to justify and legitimise this special treatment is called agricultural exceptionalism (Daugbjerg and Feindt 2017). The therewith coupled paradigm is the state-assisted policy paradigm. This agricul-tural paradigm has a productivist (or protectionist) focus, implying that the farming sector must be supported to ensure the food supply. It is argued that the agricultural sector is exceptional because of unstable natural conditions and the flawed price mechanisms for agricultural goods which is why income stability as well as productivity should be secured (Alons 2017, Erjavec 2015). Disagreeing with the exceptionality of the agricultural sector is the competitive (or neoliberal) par-adigm which implies that “markets provide for optimal allocation of resources and maximise over-all welfare, which is why the state should refrain from interfering with markets.“ (Erjavec 2015: 220-221). It is argued that agriculture just like every other field is an economic sector and farmers should be treated as normal entrepreneurs (Alons 2017). Whereas the competitive paradigm used to be the main rival paradigm for the state-assisted one, it is hardly influential anymore in the EU. However, a new paradigm emerged that, even though building upon the concept of agricultural exceptionality, competes with the state-assisted paradigm. The multifunctionality paradigm is char-acterised by the idea that the agricultural sector should be supported by the state because the farmer “performs certain quality-intensive functions” such as environmental and social services, which are not sufficiently compensated through the market (Erjavec 2015: 221, Alons 2017). Beyers and Kerremans (2004) make a comparable comparison in dividing EU policy-making in a pro-growth and a pro-sustainability coalition.

This divide of EU policy-making explains the power struggles in the CAP reform since the last reform in 2013 to a large extent (Erjavec 2015). Since the 2013 reform, agricultural issues are not limited to productivity maximisation anymore. New conflicts in the areas of environmental, trade and food safety have entered the debate on the CAP and mobilised new policy actors with new preferences (Alons 2017). The rivalry between the state-assisted and multifunctionality paradigm can be observed in the current CAP reform where struggles between environmental and produc-tivist interests represent an elementary component for the distinction of preferences. The multi-functionality paradigm thereby resonates with the values underlying EPI, focusing on

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environmental concerns, whereas the farmers interests align with the productivist paradigm (Ibid.). Thus, a paradigm shift towards the multifunctionality paradigm can be understood as prerequisite for EPI in the CAP. Daugbjerg and Feindt (2017) align the emergence of the multifunctionality paradigm with a new kind of post-exceptionalism8_{that however did not fully develop yet since} agri-cultural exceptionalism remains dominant in the decisive EU policy arenas (Alons 2017). This in-complete shift from exceptionalism to post-exceptionalism explains why environmentally friendly values have not fully or stably been reframed into agricultural policies and that EPI thus remains limited in the current CAP framework (Alons 2017, EEB et al. 2018, Robijns 2018).

Nonetheless, with the realisation that nation states are not always able to solve their problems on their own (Conelly 2012), the EU has developed a reputation as “an environmental policy setter” with the establishment of the Directorate-General (DG) for Climate Action in 2010 (Ibid.: 303). The adoption of effective environmental policies, though, is an ongoing process. Conelly (2012: 254) sets forth that “states remain the fundamental actors within global environmental politics” because they are the only ones with decision-making authority. Although the EU is not a state, it has acquired the decision-making right from its MS to regulate the environment with the MS still being represented through the Council of the EU, respectively the European Council. Thus, envi-ronmental politics has been transformed “to one of the most enduring and publicly endearing features of political activity at the EU level” and therefore giving an example of the multi-level nature of environmental governance (Ibid.: 288).

3.1 The Common Agricultural Policy

Agricultural governance, in comparison to environmental governance is an even more integrated policy field for the EU (Daugbjerg and Feindt 2017).EPI however has been rather limited in the CAP (Alons 2017, EEB et al. 2018, Robijns 2018).Whereas the Treaty of Rome had already con-tained framework provisions for the agricultural sector in 1957, the environment was not men-tioned at all. The first time environmental protection became an objective of the CAP was in 1992 with the so-called MacSharry reform (Brouwer and Lowe 2000, Lenschow 1995). The CAP has experienced a shift through more recent reforms: From a policy emphasising price and market intervention since its launch in 1962, it has obtained a focus on direct payments and rural develop-ment since the reform in 1992 and the concurrent foundation of the EU (Alons 2017, Matthews 2013). This reflects the paradigm shift from a purely productivist focus to an increasingly

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multifunctional paradigm. The last five reforms, namely the 1992 MacSharry, 1999 Agenda 2000, 2003 Fischler, 2008 Health Check and the most recent 2013 CAP reform, can be considered envi-ronmentally friendly in the sense that they did increase the environmental focus of the CAP (Alons 2017). Erjavec (2015) assesses the 2013 reform as a further shift in paradigm because of the imple-mentation of the so-called greening component of the CAP and other changes in both instruments and objectives. However, he admits that this paradigm shift mainly took place in the EC and was therefore watered down in the subsequent policy-making process. EPI in the 2013 EC proposal was mainly pursued through coupling the farmers’ income support to environmental conditions (also called cross compliance or enhanced conditionality) (Matthews 2013: 1). During the negotia-tion process only a few parts of the greening components remained. Although the 2013 reform brought some improvements, many actors agreed that it did not go far enough (Ibid., EEB et al. 2018, Robijns 2018). Alons (2017: 1616) concluded that “the 2013 reform even brought a decrease in agri-environment spending in real terms.“

Academia distinguishes between distributive, redistributive and regulatory policies. In the EU, dis-tributive policies are distributing resources from the EU to the society, redisdis-tributive policies are dispensing resources between societal groups and regulatory policies set rules (Klüver et al. 2015). The CAP is first of all a distributive policy by distributing direct income support to farmers. In addition, it includes many regulatory policies and some redistributive components too (Coen and Katsaitis 2013). The CAP framework itself consists of three reports: the ‘Financing and Manage-ment’ regulation, the ‘Single Common Market Organisation’ regulation and the ‘CAP Strategic Plans’ regulation. Even though the two former ones are highly relevant, the regulation on the stra-tegic plans is both the most relevant and also contested one. It is divided into two pillars. The first pillar, funded through the European agricultural guarantee fund (EAGF), supports farmers’ in-come through direct payments and market measures. The second pillar, only accounting for about a quarter of the CAP budget, consists of support for rural areas and the management of economic, environmental and societal challenges (Grethe 2018, EP 2020).Simultaneous to the CAP negotia-tions, the negotiations on a new multiannual financial framework (MFF) for the period of 2021 to 2027 occurred. This financial framework is elementary for the CAP because it also sets the budg-etary limits for the agricultural sector (EC 2018a). With the current MFF proposal, farmers fear significant income losses.9_{Whereas the CAP currently accounts for 37.8 percent of the EU budget} (Massot 2020a), the EC’s proposal for the 2021-2027 MFF assigns less than 30 percent to agricul-ture (EC 2019a). In 2020, the net balance available to the EAGF for direct payments accounts for 40’953 million euros whereas in 2021 only 37’393 million are estimated to be allocated to the direct

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payments, resulting in a loss of 3’560 million euros in one year (EC 2018c). The EP’s agriculture committee (COM AGRI) only calculated a reduction of 1.1% in funds for the EAGF, whereas they expect the funds for the European Agricultural Fund for Rural Development (EAFRD), funding pillar 2, to decrease by 15.3% (EP 2018a).

These significantly different percentages of reduction in the two funds stand in contrast to the increased multifunctionality of the CAP responsibilities. The EC (2018a) summarises the objectives for the CAP 2021-2027 framework as: “Securing an adequate level of support and thus farm in-come remains a key element for the future, in order to ensure food security, environmental and climate ambition, as well as rural vitality.”

The most relevant policy areas of the current process of policy-making besides the support for the environment are the allocations for pillar 1 and 2, the capping of payments, a reduced administra-tive burden, an improved performance monitoring and the transfer of competencies to MS. These policy areas and others receiving less attention are introduced and specified in chapter 4.3.

3.2 The Institutional Setting

To be able to analyse the lobbying influence in the CAP 2020 reform, a proper understanding of the institutional setting is required. The Treaty on the Functioning of the European Union (TFEU) defines that the competence for the European agriculture is shared between the EU and its MS. Thus, making agricultural governance, such as environmental governance, a multi-level system (Conelly 2012). The CAP will be relying even more on the MS in the 2020 framework because of the implementation of national strategic plans as proposed by the EC (EC 2018a). In accordance with the ordinary legislative procedure, as visualised in figure 1,the EP and the Council of Ministers establish the provisions for the CAP (TFEU 2016). Since the Treaty of Lisbon in 2009 and for the first time in the 2013 reform, the EP enjoys legislative powers (Greer and Hind 2012). This co-decision procedure is based on the principle of parity, which means that neither the EP nor the Council can adopt legislation without the other’s consent, making them both veto-powers(Greer 2015; Greer and Hind 2012, Erjavec 2015). Because of this pluralist actor environment and the changing preferences and coalitions among actors and policy issues, the EU is considered to be highly consensus-oriented (Thomson 2009). In the case that the EP and Council do not agree on a position in the first reading the procedure can be prolonged until a third reading. The chances of adoption in the first reading has, however, continuously been increased in recent years (EP n.d.b).

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Figure 1: Ordinary Legislative Procedure 10

The main institutional actors are therefore the EC as agenda-setter and both the EP and the Coun-cil as co-decision makers.

3.2.1 The European Commission

The EC’s main role in the CAP’s policy-making process is initiating the policy proposal. This how-ever is a very powerful position as it makes the EC the agenda-setter (Conelly 2012, Skodovin et al. 2010). The EC is therefore mostly influential at the beginning of the policy-making process with its DG’s designing drafts for the policies (Bunea 2013, Klüver et al. 2015). It is often considered that the early stages offer the best opportunities for interest groups to exert influence on policy-making procedures because stakeholders are formally invited to share join their view and opinions during the drafting phase (Bouwen 2009). This is for example done through large public consulta-tions (Bunea 2013, EC 2017). Responsible for the CAP reform is the DG AGRI with its current commissioner Janusz Wojciechowski. However, during the EC’s main task, commissioner Phil Hogan and Director-General Jerzy Bogdan Plewa were still in office.11_{The EC has proposed to} increase the percentage of the entire EU budget expenditure spent on climate related targets from currently 20% to 25% for the 2021-2027 period (EC 2019c). This shows that the EC is often considered having a higher environmental focus than the other institutions and is made responsible for the horizontal EPI from the environmental policy to other policy sectors (Conelly 2012, Erjavec 2015). On 1st_{of June 2018, the EC presented three legislative proposals for the three regulation}

10_{Figure from EP (n.d.b).}

11_{Other targets for lobbying attempt in regards of EPI in DG AGRI could be Ignazio Seoane, responsible for}

“Envi-ronment, forestry and climate change”, Kerstin Rosenow, responsible for “Sustainable Resources for Food Security and Growth” and Richard Etievant, responsible for “Greening, cross-compliance and POSEI”.

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reports and thus initiated the second step of the ordinary legislative procedure for the CAP 2020 reform.

3.2.2 The European Parliament

Since the Treaty of Lisbon and the establishment of the co-decision procedure, the EP has signif-icantly enhanced its role from only giving its opinion on the CAP reform to a veto-power. This new role of the EP in the policy-making of the CAP has only been seen in the most recent 2013 reform (Alons 2017, De Castro and Di Mambro 2015, Greer 2015). Consequently, the EP has also been an increased target for lobbyists. The goal of interest groups lobbying the EP is to either ensure the preferences already attained in the previous legislation procedure step or to try again to influence policy-makers in the case of lacking success during the drafting period (Kluger Rasmus-sen 2015). The extension of co-decision power to the EP led to an increased inter-institutional bargaining in agricultural policies (Greer and Hind 2012, Greer 2015). However, it was argued that this new feature also reduced the possibility of reform because, in addition to the Council, the EP, being more status quo-oriented than the Council, was now able to block the CAP reform legislation (Erjavec 2015). Greer (2015) also calls this the codecision-trap.

Whereas the EP is generally considered to be an environmentally conscious EU institution with an influential Committee on Environment, Public Health and Food Safety (COM ENVI) (Conelly 2012), this does not seem to be the case for agricultural policies. It has been shown that the envi-ronmentally friendly policies in the CAP 2013 framework were weakened during the phases of the readings in both the Council and the EP (Potočnik 2015) and that the latter was able to hinder the reform and maintain the preferred status-quo (Erjavec 2015). However, the Greens(/EFA) as the most environmentally friendly EU-faction increased their seats in the 2019 election from 7.5- to 11.7 percent whereas the arguably most farmer friendly faction the EPP decreased from 36 to 21 percent of the seats (EP 2019d). The most influential actor in the EP is COM AGRI who was designated as being responsible for the CAP reform. Since the members of EP committees repre-sent the general seat share of their factions, this shift can be observed in the COM AGRI too. However, the increase in seats from 3 to 5 for the Greens is supposed to have a modest impact and the factions of the EPP and the S&D, not known to be particularly willing to reform the CAP, maintain a seat-share which is only 3 seats below the absolute majority. Although they have lost the majority, it might not be hard to achieve one with other like-minded members (Matthews 2019a). Even though all major factions consider climate change in their manifestos, “most refer-ences to CAP reform though remain unspecific” (IEEP 2019b).

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The key players regarding the CAP reform are all members of COM AGRI, Peter Jahr as the rap-porteur for the most relevant report about the CAP strategic plans12_{(EP 2018a), Ulkrike Müller,} rapporteur for financing, management and monitoring (EP 2018b) and Eric Andrieu, rapporteur for the common organisation of the markets (EP 2018c). The committees that gave their opinion on the EC’s proposal are the committees for Development, Budgets, Budgetary Control, Regional Development, Women’s Rights and Gender Equality and, most importantly both for the CAP in general and more in particular for the interest of this paper, the COM ENVI. COM AGRI has been criticised of being biased in favour of farm interests and therefore not particularly environ-mentally friendly (Alons 2017, Greer 2015). This aligns with the accusations of COM AGRI mem-bers having a conflict of interests. Newspapers have revealed that several COM AGRI memmem-bers have “personal or business connections to the farming sector” (Neslen 2018, Apuzzo and Gebre-kidan 2019). Although the members of the EP have to comply with the code of conduct of the Parliament and are thus not allowed to put their personal preferences above the general interests, it is doubtful that this is always put into practise (Ibid.).13

The first reading in the EP was postponed due to the special situation that has arisen because of the COVID-19 pandemic and only the opinions of the two powerful committees AGRI and ENVI are evaluated.

3.2.3 The Council of the EU and the EU Council

A further key institution is the Council of the EU including the Special Committee on Agriculture that prepares the work of the Councils on Agriculture and Fisheries and therefore all the files related to the CAP (Council 2020). The Council’s legislative procedure has changed with the last reform. The Treaty of Lisbon has implemented the qualitative majority vote instead of a unanimous vote. This does principally enhance the possibility for reforms (Erjavec 2015). The Council of Min-sters directly represents the MS. One minister from each MS, depending on the issue, attends the meetings of the Council. Studies show that agricultural ministers are more open to farm interest groups’ lobbying efforts than to environmental groups (Alons 2017, Greer and Hind 2012).

12_{Maria Noichl, Martin Hlaváček, Gilles Lebreton, Martin Häusling, Bert-Jan Ruissen and Luke Ming Flanagan as}

shadow rapporteurs are influential actors too.

13_A_{ccording to Grad and Frischhut (2019: 315) the EP defines conflict of interest as “where [a MEP] has a personal}

interest that could improperly influence the performance of his or her duties as a Member.” It is not an issue “where a member benefits only as a member of the general public or of a broad class of persons” (Ibid.). Considering this definition, it is difficult to clearly identify where this is the case both for observers and for MEPs themselves.

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However, it can be assumed that Council members are barely lobbied by EU-level interest groups but primarily on a national level (Beyers 2008a).

Although the European Council, being comprised of the head of states or governments, has no direct impact on the CAP negotiations, it is powerful because of the simultaneity with the negoti-ations on the MFF (EC 2018a).Due to the unanimous vote on the MFF, the probability to maintain the status-quo in the CAP is further increased (Erjavec 2015). The struggles for the MFF divide the EU in several alliances. One alliance of countries constituted by net contributors is pursuing the interest of reducing the EU budget to one percent of the EU’s Gross National Income, whereas another powerful alliance of primarily eastern and southern MS fights to maintain the budget at the current level, mainly in support for regional development. Furthermore, there is an alliance called “Friends of the Farmers” that partly overlaps with the two previous ones. This alliance of 19 MS fears the demise of their agricultural sectors and therefore supports the maintenance of the current CAP budget (Bayer 2019).

As in the EP, there has also been harsh critique facing this level of MS representation at the EU. It has been revealed that both the prime ministers of Hungary and of the Czech Republic receive millions of direct payments from the EU (Apuzzo et al. 2019, Apuzzo and Gebrekidan 2019).14 Both Mr Orbán and Mr Babiš are members of the EU Council and do therefore indirectly, through the MFF negotiations and their agricultural ministers in the Council of the EU, decide how much money they receive from the EU.

3.2.4 Further Institutional Actors

Aside from the EC, the EP, the Council and the lobbyists Conelly (2012) deems the European Court of Justice to be one of the five significant actors in EU EPI. The Court of Justice does both establish the limits of the EU’s environmental powers and ensures that the measures are imple-mented correctly (Ibid.).

The Economic and Social Committee is a further player in the ordinary legislative procedure. The TFEU establishes that the committee must be consulted by the EP and the Council with regard to the establishment of the CAP (TFEU Art. 43.2). Copa-Cogeca itself mentions that some of their members participate simultaneously in the Economic and Social Committee (Copa-Cogeca n.d.).

14_{According to The New York Times Mr Babiš’ “companies in the Czech Republic collected at least $42 million in}

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For the sake of completeness, the European Court of Auditors and the European Committee of the Regions should be named as advisory bodies (EP 2018c).

3.3 The non-institutional Actors

The last of the five significant actors in EPI defined by Conelly (2012) are the lobbyists. “EU environmental politics is subject to intense lobbying and consultation with outside interests, pri-marily industry groupings and NGOs.” (Ibid.: 292) The same is true for agricultural policies. Ac-cording to the NGO Integrity Watch (2019) 408 lobbyists from 68 organisations have been lobbying EU policy-makers on the CAP only since the inauguration of Ursula von der Leyen as president of the EC in 2019. During the 5-year period of the Juncker Commission, 1305 lobbyists from more than 300 organisations were registered with the Transparency Register (Ibid.).

The EC has attempted to involve a broader group of stakeholders in the discussion of the current CAP reform. An open public consultation with the title “The CAP: Have your say” was held by the EC in July 2017 and received more than 320’000 submissions (EC 2017). This most relevant consultation was combined with further contributions from the REFIT platform, the European Economic and Social Committee, the Committee of the Regions and national parliaments (McEldowney 2018). The summary of the results gained from these consultations “identified higher environmental and climate action ambition, the better targeting of support and the stronger reliance on the virtuous Research-Innovation-Advice nexus as top priorities of the post-2020 CAP” (EC 2017: 2). Figure 1 shows the key elements identified in the position papers submitted by stake-holders. It shows figuratively the different preferences of farmers, respectively Copa-Cogeca, and other citizens, respectively environmental NGOs. The figure itself can be found in the EP’s asso-ciated summary (McEldowney 2018).

The division between farmers’ and other citizens’ preferences is elementary in the CAP 2020 policy-making. The interest groups representing these preferences, Copa-Cogeca and the united environ-mental NGOs, are the main rivals and are therefore elaborated more in-depth in the following subsections. In addition, these two groups reflect the opposites of EPI in the CAP and can be seen as representative for the state-assisted paradigm, respectively the multifunctionality paradigm. Both, Copa-Cogeca and the environmental NGOs should be seen as a broader coalition of prefer-ences. Copa-Cogeca does primarily ignore particular national interests and the environmentalist NGOs are an alliance of various national and supranational organisations, whose preferences do not entirely overlap either. Klüver (2011: 502) has stated that for the appropriate analysis of interest

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groups’ lobbying success “the issue-specific grouping of interest groups into lobbying coalitions” has to be considered, which is thus fulfilled with the more or less diverse interests of these two competing interest groups.

Figure 2: Public Consultation: Key elements identified for farmers and other citizens

Furthermore, the EU is giving funding to some interest groups. The goal thereof is to support groups’ interests that would otherwise be excluded (Sanchez Salgado 2014). Whereas, Copa-Cogeca does not receive any funding, its main opposition in the CAP receives financial assistance from the EU institutions of a total of 3.7 million15_{(Transparency Register 2019). That Copa-Cogeca is not} receiving any support by the EU might however be a choice of their own to maintain their credi-bility among their members (Sanchez Salgado 2014), especially considering that they did receive EU funding in the past (Lobby Facts 2019).

There are various different types of organisations with different interests lobbying the EU. During both the previous and the recent commission, 1713 lobbyists have been active on the CAP. Figure 3 shows that three-quarter of the meetings with EC officials were held by corporations in compar-ison to other types of interest groups.

Due to this thesis’ format and the high number of lobbyists, it is not possible to consider every single interest group and its objectives in the CAP reform. However, the appendix does provide an overview of further interest groups involved in the process of decision-making regarding EPI in the CAP 2020 reform.

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Figure 3: Percentage by Categrory of Lobby Organisation

16

3.3.1 Copa-Cogeca

Two of the first interest groups on European level were Copa and Cogeca. They were founded in 1958 and in 1959, respectively (Copa-Cogeca n.d.), as a reaction to the creation of the European Economic Community in 1957 with the Treaty of Rome that had already contained framework provisions for the agricultural sector (Mahoney 2007). In 1962, the two interest groups built a union, achieving an extraordinary business-unity in the agricultural sector since (Copa-Cogeca n.d., Rasmussen 2015). Even though Copa-Cogeca has been accompanied by various other interest groups lobbying the EU on diverse policy fields, they maintained their special position in the EU policy-making process and “have historically [been] treated not as mere recipients of government money, but as partners in policymaking” (Apuzzo and Gebrekidan 2019). Copa-Cogeca is per-ceived as a reliable policy-making partner (Coen 2009) due to a long and successful partnership with the EU, making them a preferred provider of expertise. The foundation of their success is its extensive membership and their supranational character. With their 60 national member organisa-tions from all EU MS except Bulgaria and Rumania17_{(Copa-Cogeca n.d.), Copa-Cogeca can} pro-vide the EU and particularly the EC with a unique supranational legitimacy (Klüver et al. 2015) and is the uncontested representative of European farmers’ interest. Such alliances let interest groups achieve greater access to the EU institutions (Gulbrandsen and Andresen 2004). On the foundation of their unique position, Copa-Cogeca pursues a straight insider strategy with often not particularly

16_{Data form Integrity Watch (2019).}

17_{Copa-Cogeca is furthermore representing national members from a few non-EU MS too.}

75% 13%

6% 4% 2%

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transparent meetings with EU officials (Apuzzo and Gebrekidan 2019). The EU has been accused of giving the farmers’ lobbyists exclusive, closed-door access to policy-makers such as getting the opportunity for a private audience before meetings of the Council of Ministers that nobody else receives (Ibid.). It has been detected that access in the EU is generally restricted to a few particularly well-suited interest groups (Coen and Katsaitis 2013).

Copa-Cogeca is one of the most influential interest groups. Officially lobbying separately, Copa has had 121 EC meetings, being ranked 14th_{, and Cogeca 100, making them 19}th_{, since December} 2014 (Lobby Facts 2019, Transparency Register 2019). A large number of these meetings was how-ever held together. In addition, Copa-Cogeca is represented in a total of 39 EC commission expert groups (Transparency Register 2019). On their official website (Copa-Cogeca n.d.) it is disclosed that they are regularly meeting with the commissioner for agriculture and sometimes with other commissioners as well as the EC president. They clarify that they lobby the EC with various ap-proaches, specifying that “positions [are] put forward by COPA delegates at the Commission’s Advisory Groups, personal contact at staff level, attendance of Commission officials at COPA meetings, transmission of letters and written positions” (Copa-Cogeca n.d.). At this point, however, it has to be mentioned that only considering EC meetings on all EU issues, Copa-Cogeca’s envi-ronmentalist opposition had actually had even more EC meetings (Transparency Register 2019). The lobbying efforts of Copa-Cogeca are not restricted to the EC. The interest group mentions to have regular contact with the EP, the Council, the Committee of the Regions and the Economic and Social Committee, whereas the COM AGRI remains one of their preferred targets (Ibid.). The generally versatile objectives of Copa-Cogeca can be reduced to the main argument that “farm-ers are expected to hold down food prices, keep quality high and fight climate change - all while dealing with a panoply of regulations and a shrinking farm budget” (Apuzzo and Gebrekidan 2019, Copa-Cogeca 2018a). This opposition to further regulations shows Copa-Cogeca’s support for the status-quo, as it is expected by an interest group representing business interests (Ibid., Dür et al. 2015). In the 2013 reform, the preferences of Copa-Cogeca were attained when it comes to main-taining the status-quo and in particular to the issue of enhanced conditionality of the direct pay-ments. However, the key objective of maintaining the CAP budget at the same level has not been achieved and Copa-Cogeca had to acquiesce the continuous reduction of the CAP budget (Grethe 2018).

With the emergence of more influential rival interest groups, Copa-Cogeca had to face more cri-tique. The main allegation of the critics focuses on Copa-Cogeca prioritising the interests of big farmers over the smaller ones (Matthews 2018c). Because of the direct income support being con-nected with the farm size in the current CAP framework, the biggest 20 percent of farmers receive

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80% of the total direct payments (Apuzzo et al. 2019). Whereas the biggest share of national farmer association members are small and middle sized famers, Copa-Cogeca does not focus on changing the approach of distributing the EU farmer’s income support (Matthews 2018c). This potential misrepresentation of their members stands in contrast to their function as supranational legitimacy provider (Kohler-Koch 2013).

3.3.2 Environmentalist NGOs

In opposition to the farmers’ interests of Copa-Cogeca stands a coalition of environmentalist NGOs. The first environmental groups were establishing a presence on an EU level in 1974. Being aware of the positive impact of coalition lobbying (Klüver 2011, Kluger Rasmussen 2015)the na-tional groups built an alliance to lobby for their interests, the European Environmental Bureau (EEB). The EEB remained as one of the most influential environmentalist actors in EU policy-making (Conelly 2012). Alons (2017) assessed them, with the NGO Bird Life and the DG ENVI, to be the decisive players that initiated the greening component in the last CAP reform. However, the impact of environmental NGOs is still evaluated to be rather restricted (Ibid.). Apart of the EEB not being satisfied at all with the final greening component in the current framework, it has been assessed in general that environmental actors’ lobbying influence is still significantly smaller than the farmers’ organisations’ (Erjavec 2015). This is explained with the extensive informal access of Copa-Cogeca (Alons 2017). Environmental NGOs such as the EEB have attempted to build coalitions to improve their impact. This is largely achieved for environmental interests with such groups as the EEB, including 140 member organisations, and belonging again to a broader coalition the Green 10 (G-10) (Conelly 2012). Latter however is not of particular importance regarding the CAP reform (Integrity Watch 2019). However, in the past and especially for the early stages of EPI in the CAP, broader reform coalitions were necessary to compete with the powerful farmers’ in-terest. Lenschow (1995) has shown that in regard of the 1992 MacSharry reform, environmental reformers did lobby in cooperation with rural development interest groups to attain their prefer-ences to the smallest degree. In light of this challenging environment, different NGOs have drawn on different lobbying strategies.

NGOs use both inside lobbying, directly addressing the policy-makers, and outside lobbying, ad-dressing the electorate (Beyers 2008b, Junk 2006). This can be observed by comparing two of the most influential environmental NGOs, Greenpeace and the EEB. Greenpeace is enjoying a high visibility in the broader public and is often perceived as too radical in its preferences by the EU institution to accept them as a reliable partner (Beyers 2008b). To achieve a maximal degree of

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autonomy and flexibility, Greenpeace is furthermore not accepting any EU funding. Therefore, Greenpeace is primarily relying on outsider lobbying, influencing the public opinion with promi-nent media appearances. The EEB in contrast is not particularly visible to the general public and receives an elementary amount of its budget from the EU. By promoting dialogue with the policy-makers and exchanging information for policy changes, they rely on insider lobbying and aim to build an image of a preferred policy-making partner. (Beyers 2008b, Transparency register 2019) Outside lobbying is considered to be particularly influential when the policy issue is characterised with a high salience and a low complexity (Junk 2016). However, in the current reform both NGOs do have the same main objectives and are therefore considered as a coalition, also including WWF and BirdLife.

The main objective of this environmental NGOs coalition is an increased EPI in the CAP 2020 reform and thus a renunciation of the current flat rate land subsidies (Grethe 2018, EEB et al. 2018,Robijns 2018). Whereas the appropriateness of environmental measures in the CAP reform is debatable, the current state of EPI undoubtedly does not align with the commissioner president Von der Leyen’s rhetoric on curbing climate change (Von der Leyen 2019). Many NGOs have consequently expressed their concerns about the upcoming CAP 2020 framework (Alons 2017, EEB et al. 2018).

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4. Research Methodology

This chapter provides an explanation and justification of the methodological choices and intro-duces the chosen policy areas and data used in this thesis. The first subsection elaborates the hy-potheses used to answer the research question. Building on the hyhy-potheses, section 4.2 specifies the regressions conducted in Stata. The final subsection explains the operationalisation of the de-pendent, independent and control variables and discusses the origin of the data used.

4.1 Hypotheses

To answer the research question four hypotheses are tested that are based upon the literature elab-orated in the chapters 2 and 3. The first hypothesis directly addresses the research question and consists of three arguments. The first argument is that EPI in the CAP was difficult to achieve and therefore remains limited until today (Alons 2017, EEB et al. 2018, Robijns 2018). This is especially the case in comparison to other EU policies where actors such as the DG for Climate Change have become influential players (Conelly 2012).

The second argument states that interest groups that conduct lobbying to maintain the status-quo are often successful in preventing further regulations (Dür et al. 2015). Additionally, certain com-mittee and Council members prefer to maintain the status-quo (Apuzzo and Gebrekidan 2019), making a lobbying success with the same intention more likely.

The third argument is based on the characteristics of the two main rivals in the CAP and in EPI in particular. Copa-Cogeca has achieved an extraordinary business-unity in the agricultural sector (Copa-Cogeca n.d., Rasmussen 2015), which has made them a particularly attractive partner for policy-makers (Klüver et al. 2015). Furthermore, they have proven themselves as reliable partners for policy-makers during a long period of time (Chalmers 2011). This has led to a special treatment of Copa-Cogeca and provided them with greater access to EU institutions (Apuzzo and Gebre-kidan 2019, Coen 2009, Gulbrandsen and Andresen 2004).

Therefore, the first hypothesis suggests the following:

Hypothesis 1: Interest groups with preferences to increase EPI in the CAP are less likely to attain

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The second hypothesis builds on the argumentation that interest groups representing business preferences lobby more successfully than CSOs. This assumption is based on the stakeholders’ perception (EC 2017) and the majority of the literature (Bunea 2013, Coen 2009, Eising 2007, Mahoney 2007), although, there are exceptions (Dür et al. 2015). However, it has been specified that it is unlikely that business groups dominate across all policy areas (Coen and Katsaitis 2013). Therefore, the CAP was separated into four clusters of policy areas that are tested separately, as will be further elaborated.

Hypothesis 2.1 expects businesses to achieve a higher percentage of lobbying success overall.

Hypothesis 2.2 further analyses the preference attainment by the interest group’s sector. Farmers’ preferences are expected to be more likely to achieve their goals than diffuse preferences because they are more united and enjoy special inclusion into many committees and consultations, repre-senting the people most affected (Kluger Rasmussen 2015).

Bunea (2013: 567) additionally recommends analysing preference attainment “over time, across different policy-making events in the same policy area”. This approach allows to make statements about short- and long-term lobbying success. The EC is often considered having a higher focus on environmental concerns than the later policy-making stages (Conelly 2012, Erjavec 2015). How-ever, the salience of an issue is still rather low during the drafting phase which is considered an unfavourable factor for environmentalist interest groups (Bunea 2013, Junk 2016). Based on the decisive dependency of the EC on resources best provided by Copa-Cogeca (Klüver et al. 2015, Kohler-Koch 2013) and their particular inclusion in the policy-making process, Copa-Cogeca is expected to be more successful in the early stages compared to their environmentalist rivals who partly rely on outsider strategies which are only influential after the drafting period in the EC (Gulbrandsen and Andresen 2004). Thus, analysing the preference attainment of interest groups in

Hypothesis 2.1: Interest groups advocating business interests are more likely to achieve lobbying

success in the CAP reform than interest groups representing civil society interests.

Hypothesis 2.2: Interest groups representing farmers are more likely to attain their preferences in

Interest Groups’ Influence in the CAP 2020 Reform: Environmental Policy Integration in light of a Paradigm Shift