Public Participation at the early stage of drawing up the Common Agricultural Policy National Strategic Plans
Summary
The document asserts that CAP National Strategic Plans fall under the scope of the Strategic Environmental Assessment (SEA) Directive, meaning Member States must conduct scoping, public consultation, and reporting regardless of whether the specific CAP SP Regulation has been formally adopted. It provides a legal framework for environmental NGOs to demand meaningful participation, including early access to draft plans and environmental reports, and the requirement that stakeholder opinions be integrated or justified if rejected.
Key insights
- ClientEarth concludes that the Strategic Environmental Assessment (SEA) Directive is applicable to the preparation of CAP Strategic Plans (SPs), requiring Member States to implement the full SEA process, including scoping, public consultation, and reporting.
- For public consultation to be considered meaningful and compliant with EU law, the public must be given an early and effective opportunity to express opinions on draft CAP SPs and accompanying environmental reports before adoption. A reasonable consultation period is suggested to be between 6 and 8 weeks.
- Member States are obligated to take stakeholder opinions into account during the preparation of the plans; they must either integrate these opinions or provide justifications for not doing so, and report on the decision-making process.
- The document argues that CAP SPs meet the four legal conditions for the SEA Directive's applicability: they are prepared by a Member State authority, are required by legislative provisions (even if the CAP SP Proposal is not yet in force), concern the agriculture sector, and set the framework for projects listed in the EIA Directive.
- CAP Strategic Plans cannot be classified as exempt 'financial or budget plans' because they perform broader functions, such as establishing an intervention strategy and steering the development of agriculture toward specific objectives.
- The requirement for SEA is supported by the CAP SP Proposal itself, which prescribes that ex-ante evaluations incorporate SEA Directive requirements, and by a Commission Staff Working Document linking CAP Reform to the Green Deal.
Cite the original document
- APA
- ClientEarth (2020). Public Participation at the early stage of drawing up the Common Agricultural Policy National Strategic Plans. https://www.clientearth.org/media/pqvnxwoq/2020-09-03-public-participation-at-the-early-stage-of-drafting-the-common-agricultural-policy-national-strategic-plans-coll-en.pdf
- Chicago
- ClientEarth. Public Participation at the early stage of drawing up the Common Agricultural Policy National Strategic Plans. 2020. https://www.clientearth.org/media/pqvnxwoq/2020-09-03-public-participation-at-the-early-stage-of-drafting-the-common-agricultural-policy-national-strategic-plans-coll-en.pdf.
- Wikipedia
- {{cite report |author=ClientEarth |title=Public Participation at the early stage of drawing up the Common Agricultural Policy National Strategic Plans |date=September 2020 |url=https://www.clientearth.org/media/pqvnxwoq/2020-09-03-public-participation-at-the-early-stage-of-drafting-the-common-agricultural-policy-national-strategic-plans-coll-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{clientearth2020public, author = {{ClientEarth}}, title = {{Public Participation at the early stage of drawing up the Common Agricultural Policy National Strategic Plans}}, institution = {ClientEarth}, year = {2020}, month = sep, url = {https://www.clientearth.org/media/pqvnxwoq/2020-09-03-public-participation-at-the-early-stage-of-drafting-the-common-agricultural-policy-national-strategic-plans-coll-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
Full text
Collected · Record updated