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Balancing inside and outside strategies: Understanding why and

when COPA uses certain lobbying strategies to influence EU

regulatory outcome.

Master thesis, 31 August 2018

Master of Sciences Public Administration

International and European Governance

AUTHOR

Emmanuel Nkundabantu (s2082977)

SUPERVISOR

Adrià Albareda

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Abstract

There is a broad consensus in the literature that interest groups exert significant influence in the European Union (EU) policymaking process. The aim of this study is to investigate how interest group balances a set of different strategies to influence regulatory outcome. The study particularly focuses on COPA, which is a prominent interest group, and assesses when and why they use one or another strategy or combine them to influence regulatory outcome. To achieve that goal, the study aims to answer the following research question: How does COPA balances inside and outside strategies to influence EU regulatory outcome? The research question is answered by making an analysis through different documents to uncover how COPA balances different strategies to influence the outcome of the EU regulations on direct payments to farmers and protective measures against pest of plants. The study found that as a prominent interest group, COPA applies both inside and outside strategies in the attempt to influence regulatory outcome. Due to resources they have, COPA uses inside strategies to interact directly with EU policymakers with the aim to affect regulatory outcome. Besides that, COPA also applies outside strategies and mostly it is to disagree with the position of policymakers on specific regulatory issues. This study contributes to the current body of the literature on interest group lobbying to understand how big interest groups combine strategies with the aim to influence EU policy outcome.

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Foreword

This thesis is the final work for the Master of Sciences Public Administration in International and European Governance, at Leiden University. The research was conducted on how prominent interest groups balance a set of different strategies to influence regulatory outcome. The study focused on COPA, which is a business farm interest group. The choice of this topic came from my interest to understand the role of non-state actors in the EU policy-making. I decided to study COPA because I thought it will provide me with a deep and general understanding of how non-state actors get involved in the EU policy-making, and because this prominent interest group has been around for many years. Although I was not familiar with the topic of interest group strategies in the beginning, this research provided me with intense understanding on when interest group decides to apply one or another strategy in the attempt to influence regulatory outcome. In order to complete this study, different people offered to me enormous contribution in one way or another whom I am grateful for their support. Special thanks are extended to my supervisor Adrià Albareda for being tireless to guide me in all steps to write my thesis and he provided me with constructive feedback to complete the thesis. He understood my personal circumstances that could have prevented me to go further in the wring process. Also, I thank the entire team of Capstone for fruitful discussions that helped to refine my topic. Finally, I thank my family for encouragement and support during the entire period of my studies.

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CONTENTS

1. INTRODUCTION ... 5

1.2 Problem definition and Research question ... 7

2. DEFINING INTEREST GROUPS ... 11

3. THEORETICAL APPROACH TO UNDERSTANDING INTEREST GROUP LOBBYING ... 14

3.1 Interest Group Strategies ... 14

3.2 Theoretical Expectations ... 17

4. RESEARCH DESIGN ... 19

4.1 Case selection ... 19

4.2 Research and Methods. ... 20

4.3 Operationalization of the main Concepts ... 23

4.3.1. Lobbying strategies ... 23

4.3.2 Level of conflict ... 24

5. RESULTS ... 25

5.1 Direct Payments to farmers ... 25

5.1.1 Preferences of the Commission ... 25

5.1.2 Preferences of COPA ... 26

5.1.3 Strategies of COPA ... 28

5.2 Protective measures against pests of plants ... 31

5.2.1 Preferences of the Commission ... 31

5.2.2 Preferences of COPA ... 32

5.2.3 Strategies of COPA ... 33

6. DISCUSSION ... 36

6.1 Theoretical explanations ... 36

6.2 Contribution of the study results ... 38

6.3 Study limitations ... 39

7. CONCLUSION ... 41

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1. INTRODUCTION

In the studies of policy-making process, a significant influence is attributed to non-state actors that represent various interests. Over the past decades, EU interest groups have grabbed the attention of EU scholars on the role these groups in the EU making process. Several scholars have shown that the EU policy-making is characterized by a complexity of interest groups which pursue to influence policy outcomes (Dür &Mateo, 2014). Interest groups articulate demands for which they ask EU decision makers to consider them in the policy-making process. This makes Brussels to be perceived as one of the capital cities in the world to accommodate a large number of diverse and complex interest groups which seek to lobby EU policymakers. By engaging in the policy-making of the EU, interest groups strive to shape policy outcome in line with their preferences (Klüver, 2010).

The increasing number of interest groups at the EU level is an indication that the EU policy-making plays significant role in the national politics. Since its creation and more after the expansion towards new countries, EU has been important in developing policies that guide activities in almost every sector of the economy in the EU member states. A recent study has shown the relevance of EU policies to have an impact on national politics in many ways (Skjærset, 2018). Skjærset shows that the implementation of EU policies at domestic level can affect the position of interest groups by strengthening or weakening their political influence. Furthermore, it is worth mentioning that EU policies have supremacy over national policies. As Hooghe and Marks (2001) put it, EU policy making has resulted in the diminishing power of state to the advantage of supranational institutions and a growing influence of ‘transnational non-state actors’. Policies that are developed at the EU must be implemented at national level within all the EU member states. Therefore, governments are required to undertake various programmes and activities in accordance with the EU directives (Baratta, 2014). The relevance of the EU policy-making in directing activities at national level clearly illustrates why interest groups attempt to lobby EU policymakers in order to shape the policy outcomes to reflect their demands.

Today, the EU policy-making vary across many policy areas and some are more subject to this process than others. A research indicates that over decades, policies that impact the lives of citizens come from the EU, and this is due to the competences it has acquired following the growing integration (Chari &Kritzinger, 2006). In this view, areas such Single Market, Competition and Economic and Monetary policies are subject to EU policy making (ibid). Furthermore, the agricultural sector is one of policy areas that have been centralized to the EU policy-making because of the the central role it plays in the economy. A recent study has revealed that the EU agricultural policy constitutes a pillar of the European integration (Henke et al., 2018). The centrality of the agricultural sector is signalled through the budget which is allocated in this

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area. In the current EU budget, it emerges that the EU has directed 40 percent of its budget to the agricultural policy to support different programmes (Henke et al., 2018). In that context, farmers obtain EU supports in the framework of the Common agricultural policy in order to carry out a number of activities (European Parliament, n.d).

Given the central role of the agriculture in citizen lives, the EU has gained competences to develop regulatory policies that are related to the EU support for farmers and measures to protect plants and plant products against pests from outside the EU. These two policies are relevant to a sustainable agriculture. EU support help farmers to ensure the sustainability of agricultural products that are needed by EU society and help them to meet several requirements in the production process such as environmental standards and food quality. Moreover, the policy on measures to protect the EU against plant deceases is relevant also to the agriculture. It fixes a number of rules and actions that must be followed in order to protect the EU from the introduction and dissemination of plant diseases from outside the EU. These pests constitute risks for farming because they have a negative impact on the agricultural production by affecting plants which are considered essential for food production.

Because of the power of the EU institutions in determining agricultural policies and the role of agriculture in the EU society, it is not surprising to see the number of interest groups that are active in this area. A study has shown that the EU agricultural policy-making is characterized by dominant interest groups that exert considerable influence on the policy outcome (Greer, 2017). It is mentioned that through the history, farm interest groups have been successful in shaping the EU agricultural policy in different reforms it has gone through (Germond, 2015; Greer, 2017). In that respect, interest groups working in the farming sector prevented the Commission to carry out the first major attempt to reform the agricultural policy in its early years (Germond, 2015). A study indicated that the EU agricultural policy was characterized by a lack of radical changes for many years, and this became possible due to the presence of powerful interest groups working in the agricultural sector that exerted significant influence on the policy-making process (Kay, 2003).

Among interest groups that operate in the agricultural area, COPA, which advocates for interests of farmers in the EU, is perceived as a prominent group that has wielded considerable influence on the EU policy-making over the history (Germond, 2015). This suggests that as an association, it has capabilities and means to shape the outcome of EU regulations in line with preferences of the membership base. The prominence of COPA is shown through resources it has for lobbying activities. COPA is one of the EU interest groups that have considerable budget and staff dedicated to lobbying activities. According to Integrity Watch, COPA is registered with the EU as a lobby group that has more than 1 million Euro and 18 lobbyists (EU Integrity Watch, 2018). In addition to that, Integrity Watch presents COPA as one of interest groups that

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has made many direct contacts with the EU. Integrity Watch indicates that since 2014 up to now COPA has been able to conduct 93 meetings aimed at lobbying the EU. It is important to mention that meetings that Integrity Watch recorded are the ones that are conducted in official way. This denotes that there might be other informal contacts that are made between COPA and EU policymakers in the attempt to influence EU regulatory outcome.

While interacting with the EU policymakers, COPA is considered to have significant influence on the policy outcome. A study found that COPA has a ‘privileged position’ in the EU policy-making process (Cunha & Swinbank, 2011). This suggests that COPA is offered with special advantages on the policy areas for which they seek to promote interests of the EU farmers. More importantly, Cunha and Swinbank (2011) said that COPA constitutes a powerful interest group with the ability to increase costs of any attempt to reform policies such as the EU agricultural policy from the path it has taken since their inception. Cunha and Swinbank mention that this puts the EU in a difficult situation to carry out radical changes to the policy that supports interests of farmers. The role of COPA and influence it has on the agricultural policy-making makes Greer to mention about ‘exceptionalism’ and persistence of ‘state-assisted’ policy, because of the special treatment accorded to farmers through this policy (Greer, 2017). Greer concluded that farmers, whose interests are defended by COPA, have continued to obtain EU financial supports in the framework of the EU agricultural policy, including even in the last reform that was made to that policy in 2013.

1.2 Problem definition and Research question

There is an agreement among scholars that one of the dominant aspects of the EU policymaking is the presence of interest groups that seek to influence the policy outcome (Bouwen, 2004; Dür, 2008; Dür &Mateo, 2013, 2014). From the existing literature, we know that big interest group such as COPA exert significant influence on the EU policy outcome and this becomes possible by implementing a set of strategies to lobby policymakers. In that respect, interest groups devote more efforts and undertake several activities while attempting to influence the policy outcome.

Despite being depicted as a prominent group that has exercised significant influence on the regulatory outcome, we do not have any study which systematically investigates how COPA attempt to influence EU policy-making by balancing different strategies. In order to be successful in achieving their goals, interest groups are expected to apply different strategies and tactics towards influencing policymakers. When endeavouring to influence policymakers, interest groups use several strategies. Literature that deals with interest group influence mention about ‘inside’ and ‘outside’ strategies to denotes a variety of tactics applied by interest groups to influence policymakers (Dür and Mateo, 2013; Hanegraaff, Beyers & De Bruycker,

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2016). On one hand, inside strategies are defined as ‘activities that are directly aimed at influencing decision makers’ (Dür& Mateo, 2013). These strategies are directed to policymakers but generally are not observable to the public (Hanegraaff et al., 2016). While lobbying policymakers through inside strategies, interest groups have options to choose among several activities that enable them to interact directly with policymakers. In this view, Dür and Mateo (2013) mention that among other activities, interest groups can meetings, position papers, direct contact with decision makers in order to influence policy outcome. They can also through making phone call and writing letters (Chalmers, 2012), providing policy expertise (Dellmuth & Tallberg, 2017). On the other side, outside strategies refers to lobbying activities that are intended to influence policymakers indirectly by mobilizing public opinion (Dür & Mateo, 2013). A set of tactics that interest groups use to influence policymakers indirectly could be the use of public media (Hanegraaff et al.,2016), conducting demonstrations, press releases, organizing press conferences, launching internet campaigns (Dür & Mateo, 2013). All these activities are performed with an intention to influence policymakers so that they can make decisions that are in line with demands of interest groups. As shown earlier, COPA is big interest group with considerable resources. Because of that, they can use a set of strategies to influence EU policy outcome. However, it emerges that less is known in the literature when such big interest groups decide to use one or another strategy or even combine them in the attempt to shape regulatory outcome.

Understanding why interest groups apply different strategies to lobby policymakers and the circumstances under which it is performed constitutes a critical step to uncover influence of interest groups. More specifically, as long as we still have a limited knowledge about why and when COPA uses a set of different strategies to influence EU regulatory policy, an important aspect to understand why it is considered as powerful interest group will remain a puzzle. Therefore, this research is an important endeavor because it can inform us about factors and circumstances that affect big interest group such COPA to implement a specific strategy to lobby policymakers in order to influence policy outcome.

Therefore, the goal of this research is to investigate when COPA decides to use one strategy instead of another or combines them at the same time to influence EU regulatory outcome. For that reason, the study answers the following research question: How does COPA balances inside and outside strategies to influence EU regulatory outcome?

Studying COPA represents an interesting case study to examine how prominent interest groups balance strategies to influence EU regulatory outcome. It is judged as an important case study because it has many options to choose strategies to lobby EU policymakers. COPA has been around for many years to defend interests of millions of EU farmers. Currently, it is formed by 60 organizations from EU members states

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and is in partnership with other organizations form non-EU countries (Copa, n.d). It is worth mentioning that these organizations affiliated to COPA have also their members at national. This makes COPA to be regarded as one of largest EU associations that have large membership base. Therefore, by having such large community of membership, it represents an advantage for an interest group to choose strategies. Membership of COPA can serve as a basis or source to generate information that might be relevant for policy officials to draft regulations. In additional to that, COPA can count to such large membership base in the situation it becomes necessary to influence EU policymakers through the mobilization of the public because it is deemed to be significant to have an impact on the policy outcome. Apart from having a large membership, COPA possesses additional resources that are devoted for lobbying activities. As mentioned before, COPA employs a large number of lobbyists who regularly interact with the EU policymakers in the attempt to influence policy outcome. Besides that, it has sufficient budget which can be used to conduct lobbying activities in the EU. All these resources give to COPA options to choose among many strategies to influence EU regulatory outcome. For instance, by having staff who are based in Brussels, COPA may influence outcome through meetings with policymakers. Similarly, they can participate in debates on different policy issues that regularly happen at the EU. By having sufficient financial resources, COPA also can be in good position to influence EU regulatory outcome through media and even conduct campaigns to lobby aimed at influencing regulatory outcome. Therefore, it is worth saying that all these resources in hands of an interest group make COPA to be perceived as relevant case because they have many options to balance strategies to influence EU regulatory outcome.

By studying how COPA balances strategies, this study aims to investigate whether they use inside or outside strategies or combine both at the same time. In order to achieve to achieve that goal, the study focuses on two regulatory policies in which COPA actively participated in the process to develop them. The first regulation examined is the EU regulation that establishes rules on ‘direct payments to farmers’. It is a critical regulation because it provides guidelines and conditions on the EU financial support which is offered to farmers in the framework of the EU agricultural policy. Besides the EU regulation on direct payments, this study assesses how COPA balances strategies to influence outcome on the EU regulation on ‘protective measures against pests of plants’. This regulation fixes a number of actions to ensure that EU plants and plant products are protected against potential diseases from third countries. The two regulations are of critical importance for the work of farmers whose interests are defended by COPA in the EU. They provide to farmers with necessary tools and resources that enable them to ensure food security and plant health.

To examine how COPA combines strategies to influence EU regulatory outcome of the two policy areas, this study bases the analysis on existing literature about interest group strategies. The main focus is to

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explain why COPA chooses to apply one strategy instead of another while trying to influence EU regulatory outcome on the two policy issues. Besides that, the analysis also looks at conditions under which a strategy to influence regulatory outcome is selected.

In order to carry out the analysis, the study is structured in the following way. In the next section, I define interest groups. Subsequently, I develop a theoretical approach to understand when and why interest groups uses certain strategies. Then, I describe the design of this research where the case selection, method used, and operationalization are described. After that, I present the results of the study. Finally, I discuss the results and made final conclusion.

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2. DEFINING INTEREST GROUPS

Before we move to the theoretical section, it is worth describing in detail how should we understand interest groups. The focus is put on how existing literature define interest group according to a couple of approaches. Additionally, an explanation of key factors to consider in order to describe an actor as interest group is presented.

The review of literature on interest group politics shows that scholars have defined interest groups differently (Beyers, Eising & Maloney, 2008; Bouwen, 2004; Dür & Mateo, 2012). In certain situation, scholars offer definitions of interest groups that are competing among themselves (Baroni et al., 2014). The presence of complexity of definitions can create difficulties to understanding what interest groups really entail among different studies. Scholars recognize that defining interest group is not an easy task and this can complicate to make a comparison of the results from different studies (Ibid).

Baroni et al. (2014) indicate that scholars define interest groups either in ‘behavioural’ or ‘organizational’ approaches. According to the behavioural approach, interest group is defined as any group that undertakes certain activities in order to influence policy outcome (ibid). However, Beyers et al. (2008) mention that by concentrating on interest group influence as behavioural approach suggests can complicate the delimitation between groups whose major goal is to influence policies and those that have irregular activities. On the other hand, scholars define interest groups within organizational approach by looking at lobbying strategies they use and their outcome (Binderkrantz & Kroyer, 2012; Helboe, 2013 cited in Baroni et al., 2014). When applying the organizational approach to define interest groups, scholars tend to focus on the benefits of interest group participation in the democratic promotion and enhancement of representation (Jordan et al., 2004; Jordan & Maloney, 2007). This denotes that besides exerting influence on policy outcome, interest groups’ involvement in the regulatory process is critical because it can help to view the outcome as resulting from inputs of various groups that advocate for interests of different of individuals. This aspect is important for the policy process. Once policy outcome is perceived as developed through a democratic procedure where several actors participate, it becomes easier to implement them because it is accepted by beneficiaries.

Scholars have identified key factors that help to define an actor as interest group. Beyers et al. (2008) mention about three factors that are relevant to consider in order to define an actor as interest group. These are ‘organization’, ‘political interest’ and ‘informality’. In the first place, ‘organization’ denotes individuals or other organized groups and excludes all types of movements or groups of public opinion that may also seek to influence decisionmakers. In this view, interest groups are perceived as ‘non-partisan organization’

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that attempts to influence policy outcome. With regard to ‘political interest’, it means that interest groups devote considerable efforts with the purpose to shape policy outcome in favour of the membership or general interest. In that respect, Beyers et al. (2008) indicate that this aspect makes interest groups to assume the role of representation. Finally, ‘informality’ implies that interest groups can accomplish their goal by means of undertaking informal interaction with decision makers. It can be mentioned that interest groups do not necessarily have to conduct their lobbying efforts in formal way only. A number of activities aimed at influencing policymakers can be carried through the channels that are not officially seen. But what account for interest groups is the achievement of their goals regardless how that process is conducted. As mention earlier, it is worth reiterating that interest groups are distinct from political parties. The former is ‘non-partisan organization’ that attempt to influence policy outcome (Kollman,1998). They do not belong to any political ideology, but their main goal is to gain influence. In contrast, political parties belong to a specific ideology, and they seek to hold offices and exercise a political power within a political system. Furthermore, it is important to highlight some other aspects that are relevant to understand interest groups. Defining interest groups requires to comprehend how they are organized. In this regard, interest groups are organized through their formal membership. Scholars indicate that groups that are engaged in lobbying activities are mostly formed by organizations that defend various interests (Dür & Mateo, 2013). Membership is a relevant feature in achieving their goals, because it enables groups to acquire more resources in order to wield influence on policymakers. Dür and Mateo said that interest groups are organizations whose survival is grounded on the support of the membership. However, membership of interest group can be either limited or open to a large constituency. A group can be established to defend interests of specific members working in particular area, or it can be open to encompass large membership such as the representation of interests of citizens (Beyers cited in Baroni et al., 2014). Klüver (2013) refers to a small ‘sectional groups’ and broad cause groups to mention how membership differ within interest groups. It is obvious that membership of interest groups is a decisive aspect to determine the scope of the activities of an interest group. Membership can serve as resources through which an interest group can rely on to carry out their lobbying to influence regulatory outcome.

It is worth noting that there is a huge diversity of interest group. They can be business, citizen groups or unions. In addition, interest groups can be large or small, national or European. Our main focus in this research is about European interest groups. These are large interest groups that are regarded as prominent groups due to significant resources they have such as a large membership base.

Literature that deals with interest group recognize that large interest groups have abilities to shape policy outcome to their preferences. These big groups grasp the attention of the audience because of the power

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they have in the policy making process. Fraussen and Halpin describe them as ‘prominent’ interest groups (Halpin & Fraussen, 2017). The prominence of interest group may emanate from a variety of resources they control over a specific policy area (Bouwen, 2002, 2004).

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3. THEORETICAL APPROACH TO UNDERSTANDING

INTEREST GROUP LOBBYING

This chapter is about the theoretical framework that explains how interest group lobby policymakers in order to influence regulatory outcome. An emphasis is put on large interest groups and how they combine a set of different strategies in order to perform lobbying activities. For the sake of studying how COPA combines strategies to influence regulatory outcome, this study uses established theories on interest group strategies and how they are combined to ensure that regulatory outcome responds to demands that interest groups formulate.

3.1 Interest Group Strategies

Before discussing strategies in detail, it is important to describe how the interaction between interest groups and policymakers works. The core aspect to understand interest group lobbying is to conceive it as an activity that involves an interaction between two groups which depend on each other (Bouwen, 2002, 2004). Bouwen reminds us that in order to understand the influence of interest group on the policy making process, we need to conceive lobbying activities not as a unidirectional process that involves only private actors towards policymakers, but as a kind of an interaction through policymakers also need private actors in order to achieve their tasks.

Through that interaction interest groups offer ‘resources’ they control, and which are needed by policymakers to develop policies in exchange to grant them an access or entry to the policy making institutions (Bouwen, 2002, 2004). Halpin and Fraussen (2017) indicate that access that is sought by groups is to join a ‘political arena’ such as the parliament or the administrative body of an organization. This implies that interest groups seek interact not only with top officials but also lay civil servants who are in charge of drafting regulation. Halpin and Fraussen say that not all groups are able to secure an access to policymakers, but those that are considered ‘prominent’. It is important to say that resources that interest groups have are important element that make a group to be regarded as prominent.

It is worth mentioning that by engaging in lobbying activities, interest groups demonstrate their willingness to partake in the policymaking. In order to achieve that goal, they apply several strategies and tactics with the aim to influence policy outcome.

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Scholars who investigate interest group strategies to lobby policymakers refer to ‘inside’ and ‘outside’ strategies as the major concepts to describe different activities that groups conduct to affect policy outcome (Beyers, 2004; Chalmers, 2012; Dür & Mateo, 2013; Hanegraaff et. al, 2016).

On one hand, ‘inside’ strategies are defined as ‘lobbying activities that are directly aimed at policymakers, and these political activities are usually not visible to a broader audience’ (Hanegraaff et al., 2016, p. 569). By applying inside strategies, interest group seeks to shape policy outcome through direct contact with policymakers (Dellmuth & Tallberg, 2017). On the other side, ‘outside’ strategies concern the attempt to shape policy outcome by targeting policymakers indirectly through public opinion mobilization by using media (Beyers et al., 2008; Hanegraaff et. al, 2016). When they carry out outside strategies, interest groups seek to mobilize citizens from outside policy making community in order to put pressure on decision makers who are inside the policymaking community (Kollman, 1998).

Inside and outside strategies involve the use of many different tactics. As mentioned previously, inside strategy involves applying activities that enable interest groups to interact directly with decision makers. In that respect, interest groups quite often use meetings with policymakers in order to articulate demands of their members (Dür & Mateo, 2013). Meetings aimed at lobbying decision makers can be organized in formal or informal ways (Dellmuth & Tallberg, 2017). Whatever form they may take, meetings represent an efficient tactic through which interest groups attempt to influence policy outcome (Fabra & Rojas, 2015). Besides using meetings, interest groups provide information to policymakers in the attempt to shape content of the policy outcome. Dellmuth & Tallberg (2017) say that influence of interest groups on the policy outcome may result from ‘policy expertise’ and ‘technical knowledge’ they offer to policymakers in order to develop policies. Information that groups provide to policymakers encompasses preferences that former want to be reflected in the policy outcome.

When they lobby policymakers through inside strategies, interest groups also use tactics such as making phone call, writing letters to inform policymakers about preferences or they can even make face- to-face communication (Chalmers, 2012). Additionally, the attempt to influence policy outcome are conducted by sending ‘position papers’ to policymakers which contain satisfaction or dissatisfaction (Dür & Mateo, 2013). Dür and Mateo reiterate that position papers are used to inform policymakers about opinion of interest groups on the policy proposal.

Concerning outside strategies, interest groups apply different tactics that are intended to mobilize public opinion through news and social media in order to get their demands accepted (Brändli, 2015; Dellmuth & Tallberg, 2017). These tactics have the advantage of reaching a large audience (Fabra & Rojas, 2015). Dür

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and Mateo (2013) mention that outside strategies may include demonstrations, press releases, brochures, internet campaigns and press releases.

It is worth mentioning that the list of lobbying strategies to influence regulatory outcome directly or indirectly is endless because interest groups may lobby differently. However, tactics described above are the ones that are frequently mentioned in different studies that deal with how interest groups attempt to influence regulatory outcome.

The choice of strategy to lobby policymakers is dependent on ‘group type’ and ‘resources’ they have (Beyers, 2004, Chalmers, 2013, Dür & Mateo 2013, Hanegraaff et. al, 2016). Group type denotes whether interest groups defend diffuse citizen interests, or they represent economic interests. As explained before, membership of interest group is a key element in distinguishing a type of group. Some groups represent interests of larger members such as citizens within a specific policy domain, while others defend interests that are limited to a specific type of business or profession.

It is important to mention that there is a connection between resources in hands of interest groups and the strategies they use. Resources of interest groups can be expert knowledge or any kind of information that is needed by policymakers to draft policies. In addition to expertise, resources available to interest groups may also be money and staff (Dür & De Bievre, 2007). Moreover, they can be large membership base of an interest group. Dür and De Bievre indicated that these resources that interest group control affect the choice of strategies to lobby EU policymakers. Citizen groups that are considered to have fewer financial resources and large membership base tend to apply outside strategies (Beyers et al., 2008; Dür & Mateo, 2013, Hanegraaff et. al., 2016). However, groups such as business associations that are supposed to have significant resources (money) normally apply inside strategies because they allow them to interact directly with policymakers with an intention to influence policy outcomes.

Inside strategies are thought to be superior than outside strategies in terms of affecting policy outcome (Beyers, 2004; Chalmers, 2012). They are more suitable to provide technical expertise and a variety of information that policymakers need to draft policies. Besides that, Beyers (2004) indicates that using inside strategies appear to carry a reputation than applying outside strategies because the later may tarnish public image of decision makers.

Although inside strategies are judged to be more valuable than outside strategies, interest group may choose to lobby policymakers through outside strategies for other reasons. Groups are aware of the effect of using inside strategies on policy outcome, but often they prefer outside strategies because they offer them with publicity to the audience (Dür & Mateo,2013). When they use outside strategies, interest groups want to show to the membership base that they are actively working to defend their interests. The same reasoning

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is espoused by Dellmuth and Tallberg (2017) who mentioned that interest groups usually combine both inside and outside strategies. However, they added that since in most cases these interest groups depend on funds of their members, they choose to lobby policymakers by applying outside strategies to enable their supporters to stay mobilized. However, Dellmuth and Tallberg added that interest groups which do not rely on funds of membership prefer to apply inside strategies.

We have seen in the previous sections how interest groups endeavour to influence policy outcome by using either inside or outside strategies. The ideal aim of large interest groups that attempt to influence regulatory outcome in the political arena such the EU is to balance both inside and outside strategies while lobbying policymakers. This denotes that interest groups make a combination of different strategies in their lobbying efforts. As Baumgartner & Leech (1998) put it, using different strategies is better than focusing on one strategy, because it gives opportunities to maximize the chances of being successful to shape policy outcome. Chalmers (2012) also supplements by saying that EU interest groups frequently balance strategies to lobby policymakers. It is worth arguing that in the context of the EU, large interest groups represent interests of their members who are scattered in different countries. For that reason, these groups may combine both inside and outside strategies not only to influence outcome, but also as a way of showing the membership base that they are active in defending their interests. In addition to that, some groups might also combine inside and outside strategies in order to influence policy outcome and at the same time to mobilize outside community such as citizens. For instance, a group might hold a meeting with the Commission on specific policy issue and also go through the media to mobilize public opinion so that the issue may get the attention of a large audience. Therefore, it is important to conclude by saying that large interest groups do not rely on a single strategy. However, they balance between different types of strategies in order to increase their success and also ensure their survival which is grounded on the support of the membership.

3.2 Theoretical Expectations

The theoretical framework has provided us with insights on how interest groups influence policy outcome by using a set of different strategies. Based on theoretical explanations, it is important to draw some expectations about when and why prominent interest groups such as COPA will use inside and outside strategies to influence EU regulatory outcome.

The first expectation is that prominent business interest groups will tend to use inside strategies to influence EU regulatory outcome. First, this assumption is based on the fact that prominent interest groups are able to have good contacts with policy makers because they possess a lot of resources they can use to interact

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directly with policymakers (Dür & Mateo, 2013). Due to a particular position they occupy in the policy arena, they might be able to gain more contacts with policymakers, thus attempting to influence policy outcome though the implementation of tactics such meetings or other forms of direct contact. In addition to that, business interest groups have permanent staff who are regularly engaged in lobbying activities, and this become easier for them to use direct lobbying than interest groups which do not have permanent lobbyists. Moreover, by having staff who undertake lobbying activities, prominent interest group can take advantage of this by drafting position papers in order to influence regulatory outcome. Also, it become easier for prominent groups that have lobbyists to monitor the process through which a policy issue goes in on daily basis. Prominent interest groups possess valuable information and expertise that are needed by officials who are in charge of drafting policies. Since prominent groups have technical knowledge and useful information on a particular policy area, it becomes obvious that they can use them to shape the content of the regulations.

The second expectation is that prominent interest groups will use outside strategies when they disagree with policymakers on specific policy issues. It is noticeable that prominent groups defend interests of the membership. However, it is important to assume that when there is conflict over policy issues between policymakers and interest groups, the later will implement outside strategies to show to their members that they fight for them. Even though interest groups know that they have not been able to persuade decisionmakers about their preferences, they will tend to use outside strategies so that their members can keep trusting them. Additionally, when there is an agreement on a policy issue, prominent groups do not want to expand the conflict, they prefer to keep it under the radar of public audience. Instead, when interest groups disagree with the position of policymakers in particular regulation, they will try to expand the conflict and mobilize citizens to make the issues to be salient, and thus put more pressure on policymakers. Once a policy issue is more salient and attract the attention of large audience, policymakers favor interests of citizens in order to avoid subsequent consequences. Interest groups can expand the conflict by using outside strategies. Kollman (1998) mention that outside strategies are effective in exerting a pressure on policymakers.

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4. RESEARCH DESIGN

The present chapter discusses about the design of this research. First, a discussion of COPA, which is the case selected for analysis is presented. Next, to that the justification of the policy areas selected for analysis is discussed. Lastly, a discussion of the methods that were used to collect and analyse data are explained.

4.1 Case selection

COPA is a French acronym which stands for ‘Committee of Professional Agricultural Organizations’. It was created by European farmers in 1959 to represent their interests in the EU (Copa, n.d). Currently, 60 organizations from the EU countries form the membership of COPA and also it is in partnership with other organizations from non-EU countries of Norway, Switzerland, Iceland, and Turkey (Ibid). This makes it to become one of the largest EU associations that represents interests of millions of farmers, because these organizations affiliated to COPA have also their own members at national levels.

COPA was selected as a single case study to investigate how prominent interest group balance different strategies to influence EU regulatory outcome. COPA is an interesting case because it is a large association that regularly interacts with the EU policymakers in all issues relating to the development of the EU agricultural policy to defend interests of farmers (Copa, n.d). According to Integrity Watch, a database that records information relating to lobbying activities of groups in the EU, COPA is depicted as an interest group at the top of the list of interest groups that has organized several high-level meetings to lobby the Commission on the agricultural policy (EU Integrity Watch, 2018). In that regard, Integrity Watch shows that between 2014 and 2018, COPA has already secured 93 meetings aimed at influencing policy outcome. In addition to that, Integrity Watch reports that COPA spends more than 1 million Euro on lobbying activities, and it pursues interests in more than 30 policy areas with 18 lobbyists who are registered with the EU.

Scholars present COPA as a powerful interest group that has shaped the EU policy over the history (Chambers, 2016; Germond, 2015; Kay, 2003). For instance, a research indicates that during the first major attempt by the Commission to reform the EU agricultural policy in 1986, COPA opposed to the Commission proposal and that has resulted in the failure to reform the policy for many years (Germond, 2015). In addition to that, the influence of COPA is manifested through the agricultural policy which grants farmers financial support. A study conducted in that domain described COPA as an effective interest group with considerable influence in lobbying EU decision makers (Chambers, 2016). Similarly, Kay (2003) mentions that COPA is a powerful interest group that has capabilities to make difficult any attempt of the EU to

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reform the policy that may undermine interests of farmers. More specifically in the recent reform to the EU agricultural policy that was carried out in 2013, the EU allocated 40 percent of the budget to the agricultural policy and most of the money was spent to support farmers through direct payments (European Commission, 2018; Henke and al., 2018).

Given the influence of COPA on the EU policy making process, it is worth studying how they use different strategies to influence regulatory outcome. Studying COPA strategies is conducted on two regulations. These are the regulation on direct payments to farmers and the regulation on protective measures against pests of plants. They are critical regulations due to the role they have in the work of farmers. Although they are considered to have impact of farmers’ activities, these regulations are not comparable. They are most different cases and address different issues.

The regulation on direct payments to farmers fixes the rules on the EU financial supports that are given to farmers (European Commission, 2018). To receive payments farmers are required to follow a number of requirements such as respecting environmental standards. The selection of this regulation is based on several reasons. First, this regulation constitutes a cornerstone for the income of farmers whose interests are represented by COPA. It has several components of support that are offered to farmers. More importantly, it is apparent that COPA participated actively in the process to draft that regulation.

The regulation on measures against pests of plants is fundamental to ensure that EU plants and plant products are safe. This regulation set up several actions to undertake in order to protect the EU against foreign diseases that may affect plants (European Commission, 2016). Moreover, the regulation also sets guidelines about movement of plants in order to minimize risks to introduce plant diseases in the EU. Since this regulation affects activities of EU farmers, it emerged that COPA was also actively involved in the policy process to develop it.

Therefore, it is important to say that the selection of these two regulations is a unique opportunity to understand how COPA balances a set of strategies to influence outcome of the regulations that are considered important for profit and work of farmers.

4.2 Research and Methods.

The present research applies a single case study design to investigate how COPA balances strategies to influence regulatory outcome in the two policy areas just discussed in the previous section. According to Toshkov (2016), single case study is an appropriate type of design, because it helps a researcher to explain the outcome of an individual case by collecting several variables pertaining to it. Therefore, given that this

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research examines COPA, this type of design helps to gather a wealth of data on how this prominent interest group combined strategies made of different tactics to influence EU regulatory outcome on direct payments to farmers and protective measures against pests of plants.

In order to answer the research question, data were collected by reviewing different documents pertaining to the two regulations. Given that the EU procedure to develop regulations goes through a long process and can take a many year, the analysis considered only the documents that were produced one year before the Commission proposals were published until the regulations were adopted. It was judged important to consider that timeframe because it emerged that attempts to influence regulatory outcome started before the Commission communicated officially the proposals. Another reason the study considered that timeframe was based on the assumption that within once year, contents of the regulatory proposals were already known to COPA given the efforts they made to influence regulatory outcomes during that period, even though the proposals were not officially published. It is important to mention that documents that describe initial proposals of direct payments to farmers and protective measures against pests of plants were published in 2010 and 2012 respectively and the final regulations were adopted in 2013 and 2016 respectively. The description of the documents reviewed is presented in more details below.

Commission proposals: The analysis considered initial proposals of the EU Commission that were

published to establish the regulations. The Commission sent them to the European Parliament and the Council to communicate about plans and how they want to deal with different regulatory issues. The proposals were selected for analysis in order to retrieve information about the preferences of the Commission and how they suggested to address the issues in the two policy areas. The proposals were obtained from a website of the European Parliament.

Consultative meetings: The study assessed documents that were issued about meetings with different

stakeholders on the regulations. These are consisted of direct meetings, seminars and workshops. The analysis of these documents was relevant to obtain information about positions of different stakeholders who participated in the policy making process. More specifically, the documents indicate positions and suggestions of COPA regarding issues in the regulation on measures against pests of plants. These documents are available to the website of COPA.

Position papers, reactions, contribution: The analysis looked at position papers of COPA about the

proposals. These documents provided more details preferences of COPA of the regulatory proposals and how the EU should proceed to deal with issues that are considered critical. In addition to that, the analysis examined documents that COPA issued in reaction to the Commission proposals. By examining the reaction, it helped to obtain information whether COPA was satisfied or not about the plans of the

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Commission. These documents were obtained from the online archive on COPA website. In addition, the contribution is also available to the website of the Commission. This document specifically contains information on expertise or technical information that COPA offered to the Commission document to draft the regulatory proposal.

Press releases, media presence: The other documents that were analysed are the press releases that COPA

distributed in the attempt to influence regulatory outcome. The analysis of press releases was aimed to obtain information about how COPA tried to mobilize the general public. Press releases were selected through a quick search on COPA website and google. They are easily accessible because they are published under the same rubric.

Next to press releases, the analysis looked at COPA presence in the media to understand how they used this strategy to mobilize public opinion in favour of COPA preferences. Media articles were obtained through google search by using search terms ‘Copa-Cogeca direct payment to active farmers’ and ‘Copa-Cogeca measures against pests of plants’. The search generated one article from Euractiv network. This newspaper reports information on the EU policy debate. Information we found was related to direct payments to farmers.

After the data collection, the study used the process tracing to analyse them. It consisted to gather evidence relating to how COPA used different strategies in the attempt to influence regulatory outcome. Process tracing is a crucial method to assess causality. It helps to explain the outcome by examining ‘pieces of evidence’ within a single case (Beach & Pedersen, 2013). Dür (2008) mentions that process tracing is the most used method to capture the influence of interest groups on the EU policy making process. In the present study about COPA strategies, process tracing helped to collect pieces of evidence about how this interest group balances different strategies to influence EU regulatory outcome in line with their preferences.

Conducting the analysis was made in three main stages. First, the process consisted to study the preferences of the Commission. This was primarily done to assess the issues of the regulations and how the Commission wanted to address them in the final regulation. Secondly, the analysis moved to examine preferences of COPA. This involved to spot what COPA suggested in order to deal with issues of the two regulations. In addition, it helped to uncover whether there were agreements or disagreements between the preferences of COPA and the Commission. Lastly, the study analysed strategies that COPA used to influence regulatory outcome. By studying strategies, an emphasis was put on when one strategy or another was use and why in different policy issues to influence regulatory outcome of both regulations.

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4.3 Operationalization of the main Concepts

The main concepts used in this research were measured by applying established definitions from the literature in order to capture them empirically. Operationalization consists of clarification of ‘abstract concepts’ which are converted into concrete ones that can be empirically identified or detected (Toshkov, 2016). An outline of how the main concepts applied in this research were operationalized is presented below.

4.3.1. Lobbying strategies

Lobbying strategies are the independent variable of this study. The strategies are divided into two: inside and outside. Inside lobbying strategies are any activities to influence policy makers directly. These include direct face to face meetings with policy makers. They are direct interaction with policy makers. On the other hand, outside lobbying strategies are indirect activities intended to influence policy makers such as press release and demonstrations.

The measurement of lobbying strategies consisted of capturing in an empirical way any action that COPA undertook with an intention to influence the outcome of the regulations on direct payment to farmers and measures against pests of plants so that they can reflect preferences that COPA favoured. In that view, the study considered activities such as meetings, position papers, press releases, use of media, expertise, or any other activity implemented.

The Council of Europe defines lobbying as ‘concerted effort to influence policy formulation and decision-making with a view to obtaining some designated result from government authorities and elected representatives’ (European Parliament, 2013, p.1). Dür and Mateo (2013) mentions that lobbying strategies can be ‘direct contact with decision-makers’ or ‘launching campaign’. By performing these activities, interest groups believe they will influence policymakers. The lobbying strategies may include activities of using media or mobilization by which tactics such as ‘issuing press releases’ and ‘demonstrations’ are carried out in order to influence policy makers (Binderkrantz, 2008).

Inside strategies were operationalized by considering all activities that COPA made to influence regulatory outcome by means of interacting with policymakers directly. They included activities such position papers, meetings and direct contacts with EU policymakers, position papers submitted and expertise. Concerning outside strategies, the study captured all the attempts that COPA made to influence regulatory outcome indirectly. These are press releases, use of media, press conferences.

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Here it should be noted that depending on the context, position papers can be considered to be both inside and outside lobbying strategies. Position papers are inside lobbying strategies when interest groups (in this case COPA) directly sends them to the Commission. On the contrary, when position papers are just published on the websites of interest groups for public consumption, they can be considered to be an outside lobbying strategy intended to indirectly influence policy makers.

4.3.2 Level of conflict

The level of conflict is the dependent variable. This variable was operationalized by looking at whether the preferences of the Commission and COPA are aligned or not. There is conflict (disagreement) when the positions of the Commission and COPA are not aligned together. They do not have similar preferences regarding a specific policy area. This level of conflict can be high, medium, or low. There is high conflict when the preferences of the Commission and COPA are totally different. However, when their preferences are partially different (there is similarity but some differences) the level of conflict is medium. Low level of conflict is when the preferences are totally similar. It means their positions are fully aligned with each other and no disagreement exists.

Empirically, this research examined the level of conflict by analyzing the positions of the Commission and COPA and establish whether or not there are disagreements on the two policy issues of direct payments to farmers and protective measures against pests of plants.

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5. RESULTS

This chapter presents the findings of the study. In order to achieve this goal, first the study presents the main issues of the EU regulations on direct payments to farmers and protective measures against pests of plants. After that, a description of preferences of the Commission on regulatory issues is made. Thirdly, preferences of COPA are also presented. Finally, the analysis of COPA strategies to influence regulatory outcome of the two regulatory policies is conducted.

5.1 Direct Payments to farmers

The regulation on direct payments to farmers was initiated following the last reform that was made to the EU agricultural policy in 2013 (European Commission, 2016). The EU indicate that they established the arrangement of direct payments to farmers as way to deal with a number of challenges that affect the agricultural sector such as food security and environmental issues (European Commission, 2010).

Considering the complexity of issues that affect the agricultural sector, the study found that direct payments to farmers were established and designated to be attributed to EU farmers based on principles to deal with three main issues: ‘basic payment’, ‘greening payment’ and ‘small farmers payment’ (European Commission, 2010, pp.8-9).

Basic payment is a component of the EU support which is offered to all farmers based on the areas they have for practicing farming activities. It means that financial support which is distributed to farmers under this arrangement is made without conditions as long as farmers are undertaking some productive activities on their lands. With regard to ‘greening payment’, the European Commission (2010) indicates that farmers are granted with this type of payment under condition that they have to make some activities which are beneficial such observing environmental requirements while they undertake farming activities. Finally, small farmers payment, is given to farmers in order to help them to compete and maintain their services in rural areas (Ibid).

5.1.1 Preferences of the Commission

The Preferences of the Commission on direct payments to farmers are contained in the proposal submitted to the European Parliament and the Council in 2010 to reform the agricultural policy (European Commission, 2010). The analysis of the proposal shows that it has several suggestions that the Commission advanced in order to deal with the issues just described above and challenges faced by EU farmers.

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Concerning the basic payment, the study found that the Commission offered a suggestion that support to farmers must pursue an ‘economic criteria’. In this view, the Commission wanted that a part of the EU support has to accomplish an ‘income function’ (European Commission, 2010, p. 8). This implies that financial support that farmers receive under the basic payment have to be considered as an additional income distributed to farmers.

Besides that, the Commission suggested to implement ‘equal distribution’ of direct payments. The Commission argued that in order deal with challenges faced by EU farmers, there is a necessity that funds they receive have to be distributed equally in all countries (European Commission, 2010). Moreover, the study found that the Commission proposed that payments must be only distributed to ‘active farmers’. Here the Commission said that in order to be regarded as an active farmer, the condition should be linked to the activity of generating products and ‘goods of social interests’.

Moreover, the Commission proposed that there should be an ‘upper ceiling’ of payments offered to large farmers. This suggestion was made based on the argument that it will help to enhance allocation of financial support between farmers. Additionally, the Commission mentioned that putting a limit to the amount of money paid to large farmers will help to alleviate disproportionate consequence because large farmers have considerable employment opportunity.

Concerning ‘greening payments’, the study found that the Commission suggested that payments which are offered to farmers under this scheme should be linked to the condition that farmers have to respect environmental aspects (European Commission, 2010). More importantly, the Commission said that greening payments must be linked to the provision of ‘mandatory’ greening activities.

Finally, regarding small farmers, the current study found that the Commission suggested to establish an arrangement to help small farmers (European Commission, 2010). The Commission indicated that this arrangement will help farmers to compete and contribute to the continuity of provision of services in rural areas.

5.1.2 Preferences of COPA

The study found that COPA expressed their preferences on direct payments to farmers on different occasions. This is just before and after the Commission published the proposal. Shortly before the publication of the proposal, COPA suggested the EU to uphold payments to farmers in order to allow them to be in the position to offer various beneficial services to the society (Copa Cogeca, 2010). In their preferences, COPA suggested that an emphasis be put on strengthening the role of famers in the production.

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The analysis of preferences shows that on some issues COPA expressed satisfaction on the Commission while other there is a disagreement.

Regarding the basic payment, the study found that COPA applauded the Commission proposal to support farmers while ensuring equal distribution of funds. COPA said that there is a necessity to guarantee ‘‘fair and equal treatment of all farmers by taking into account differences in conditions’’ (Copa Cogeca, 2010, p.7). Besides equal distribution, COPA suggested also that direct payment be offered only to active farmers. They added that there is necessity for people to understand why farmers need direct payments. Furthermore, COPA suggested that there should be harmonization in the distribution of direct payments to farmers in all EU countries.

Moreover, the study found that COPA disagreed on how the Commission described payments to farmers as income. In the respect COPA said that ‘‘justifying direct payments as an income aid to farmers is not adequate. The justification for... payments is the only way to achieve the type of agriculture European citizens want’’ (Copa Cogeca, 2010, p. 7). COPA claimed that payments are the only way that farmers can ensure sustainable production and employment. It is obvious to argue that the disagreement about how the payment should be qualified raises additional question regarding the doubt that COPA might have on how general public would perceive and reacted to the financial support offered to EU farmers. This is even substantiated by what COPA said in the reaction to the proposal as mentioned previously that people need to understand why farmers deserve the payments.

Additionally, COPA articulated a preference that there should not be ‘upper ceiling’ to the payments allocated to large farmers (Copa Cogeca, 2010). COPA opposed to the Commission by arguing that limiting the payments would put farm in difficult situation such weakening the ability to compete.

Turning to the ‘greening payments’, COPA disagreed with the Commission suggestion and said that farmers should undertake greening services on ‘voluntary basis’ and not mandatory as the Commission suggested (Copa Cogeca, 2010, p.4). COPA argued that farmers have been respecting environmental rules and their production already met the standards.

Regarding ‘small farmers payments’, the study found that COPA was supportive to the Commission suggestion and said that more efforts have to be made to ensure that small farmers such as ‘family farmers’ are preserved (Copa Cogeca, 2010). In addition, COPA proposed that the EU establish an arrangement to support ‘young farmers’ and said that it would be an appropriate way to encourage young people to join the farming sector.

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5.1.3 Strategies of COPA

The study found that COPA implemented different tactics in the attempt to influence the outcome of the EU regulation on direct payments to farmers.

As far as the ‘basic payment’ is concerned as a support to ensure food production, the study found that COPA used press releases to lobby EU policymakers. Evidence shows that after a meeting of farmers which took place in Brussels, COPA issued a press release (Copa Cogeca, 2010). The analysis of that press release shows that COPA lobbied EU decisionmakers to keep the payments for farmers in order to ensure that they continue producing products which are needed by society. Through that press release, COPA argued that payments will help farmers to undertake different services which are intended to promote rural areas. In that regard, COPA said that once farmers receive EU support, they can contribute to create employments in rural areas. In addition, the study found that COPA issued another press release to influence policymakers to offer payments to farmers (Copa Cogeca, 2012). COPA reiterated that payments will enable farmers to continue producing. Interestingly, the study findings show that COPA distributed that press release in line with a high-level meeting between the President of COPA and the President of the EU Farm Council (Ibid). As shown in the previous section, it is important to argue that by emphasizing on food production and providing services which are needed by society while defending why farmers need to receive direct payments, it is a clear indication that COPA wanted the EU and more specifically public opinion to perceive direct payments not as a part of income distributed to farmers, but a necessary support to enable farmers to keep producing goods that are beneficial for society. This is further demonstrated in the reaction of COPA to the Commission proposal, where it said that people need to understand why farmers need to receive payments (Copa Cogeca, 2010).

If we now turn to the preference of COPA about not limiting (ceiling) the payments that big farmers can receive, the study found that, in a similar way, COPA applied press releases to disagree with the Commission suggestion about ceiling the payments (Copa Cogeca, 2010, 2011). The press releases indicate that COPA defended their position by arguing that limiting the payments will contribute to undermine farmers capability to compete and prevent them to ensure sustainable production for society. Afterward, result shows that COPA applied an additional press release in the attempt to influence EU policymakers about not limiting payments to farmers (Copa Cogeca, 2012). In that press release, COPA reiterated what they said was a concern raised by the President of the EU Farm Council in his meeting with the President of COPA. The press release mentioned that the President of the EU Farm Council said that limiting payments would increase ‘bureaucracy’ in the EU.

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Regarding payments to active farmers, the study found that COPA attempted to influence regulatory outcome by using the media. Evidence shows that the Secretary-General of COPA gave an interview to Euractiv Network, which is one of the leading newspapers that covers news on the EU policy-making (Euractiv, 2010). The interview of the Secretary-General was published in Euractiv newspaper with the title: ‘‘CAP money must benefit active farmers’’ (Euractiv, 2010, p.1). COPA insisted that payments to farmers must be maintained and given only to those farmers who are actively engaged in food production and services so that they can be able compete on market with third countries. In addition to that, he said that that cutting direct payments will force farmers to abandon lands in rural areas, and this would have an impact on EU citizens. To emphasis more clearly about who should receive the EU support, COPA stated that the criteria to receive the payment must be connected to activities on the farm. In the similar way, COPA said that operators such as landowners must be excluded from getting direct payments if they do not undertake any activity on their lands. Interestingly, COPA said that support to farmers is also a support to buyers. This denotes that by supporting EU farmers it allows consumers to buy products on the market at low prices.

Concerning ‘greening payment’, the study found that COPA used press releases and meeting to lobby EU policymakers. Evidence shows that shortly before the Commission published the proposal, COPA issued a press release inviting journalists to a press conference on the day of the official publication of the proposal itself (Copa Cogeca, 2010). The press release indicates that Copa was concerned about additional ‘greening’ and said that the requirement of mandatory greening services will jeopardize farmers effectiveness, thus preventing them to compete on market with non-EU countries.

In the similar way, the study found that after the Commission published the proposal, another press release was published in which COPA warned the Commission about introducing mandatory environmental services (Copa Cogeca, 2012). COPA said that it would have an impact on food security and weaken farmers’ capability to deal with upcoming issues in the farming sector. Additionally, COPA indicated that mandatory greening will make farmers to incur additional costs in their activities.

Next to press releases, COPA lobbied policymakers on greening payment by applying the meeting. The study found that COPA organized a two-day workshop dedicated to discussion about the future of the EU agriculture (Copa Cogeca, 2011). The analysis of document about the meeting shows that several EU Members of Parliament were present on the invitation of COPA. COPA informed participants during the meeting that the Commission plans to link a component of direct payments under condition of complying with environmental conditions would cause negative consequences to farming activities. Therefore, COPA asked them that to grant payments to farmers without difficulties. More importantly, COPA reiterated

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