CrossGov

Coherence between policies

Introduction

Assessing external coherence means assessing whether there are any conflicting objectives and/or measures between policies. The assessment of external coherence involves at least two policies. The choice of which (and how many) policies to include in an assessment depends on the scope of the analysis. Due to the fragmentation of policies and policy areas, an assessment often involves many policies that are directly or indirectly relevant.

Recommendation: For the selection of policies, some sort of overlap is needed for making an assessment of coherence relevant. Examples of such overlaps can be the targeted problem, geographical area, or stakeholders or actors affected, such as industries, farmers, fishers, or municipalities.

Coherence of objectives

The policies involved in an external coherence assessment have multiple objectives, goals and targets. It is important to assess their level of coherence. In case of similar types of policies, such as two EU-level directives, this assessment may be rather straightforward (Figure 5).

Figure 9 Simple external coherence assessment between two policies
Figure 9 Simple external coherence assessment between two policies

However, reality is often more complex. The relevant policies are often of a different nature, encompassing directives, regulations, strategies, plans, and other types of policies. Some are directly relevant for the assessment, while others are more indirectly relevant, perhaps even belonging to separate policy areas (Figure 6). Some have clear and specific objectives, others more general policy visions. In such situations, it is often difficult to fully understand the overall coherence of the group of policies.

Figure 10 Complexity of external coherence assessments. Often, relevant policies come from the same as well as different policy areas
Figure 10 Complexity of external coherence assessments. Often, relevant policies come from the same as well as different policy areas

To begin the assessment, we recommend exploring the following questions first:

1 - What are the objectives of the policies?
  • Are the objectives of the policies supporting each other?
2 - To what extent are the objectives aligned with overarching ambitions
  • Which policies are key in relation to the overarching ambitions?
  • How are these policies affected by the objectives of other selected policies?

Recommendation: Often a coherence assessment is carried out in light of some overarching ambition or research question. For example, to what extent do the selected policies together contribute to the EU’s climate neutrality target, or the UN’s poverty reduction vision? For understanding how a group of policies contributes an overarching ambition, we recommend a two-step approach. The first step is to assess how each individual policy contributes the ambition. The second step is to understand which policies are key in the context of the overarching ambition, and how these policies are affected by the objectives (and measures) of other policies.

Do you want to go more in depth? Consider exploring the following questions:

1 - Are the policy objectives aligned with objectives from the other policies

  • Are the policy objectives aligned substantively, i.e. in terms of subject matter?
  • Are the policy objectives aligned geographically, i.e. in terms of spatial application?
  • Are the policy objectives aligned ‘temporally’, i.e. in terms of timeframes for their achievement?

Examples

  • In the Archipelago Sea, the objective of good environmental status is largely aligned between different policies in relation to nutrient loading. To illustrate, the Marine Strategy uses indicators and status class boundaries for eutrophication that are coherent with those for freshwater environments. The Marine Spatial Plan refers to the good environmental status specified within the River Basin Management Plan and the Marine Strategy. The Baltic Sea Action Plan includes independent nutrient reduction objectives, but it also refers to the Marine Strategy Framework Directive in this regard.
  • The EU Nitrates Directive aims to reduce nitrate pollution from agricultural sources, while the Common Agricultural Policy can encourage intensive farming practices, which may increase nitrate pollution.
  • The EU Water Framework Directive sets ambitious water quality targets, while the Pesticides Directive allows for the use of certain chemicals that can negatively impact water quality, creating a conflict between the two directives.
  • The EU Marine Strategy Framework Directive and its objectives apply across all EU marine waters, ensuring that its spatial application aligns with other instruments like the Maritime Spatial Planning Directive and the Zero Pollution Action Plan, facilitating geographical coherence in protecting marine ecosystems.
  • The EU Water Framework Directive and the Marine Strategy Framework Directive partly overlap spatially in the coastal areas, but authorities need to produce separate assessments on the same coastal waters in different timeframes. The Habitats Directive assessments and Natura 2000 management plans also operate on a different timeline. This temporal misalignment results in the constant production of new Programs of Measures, adding considerable strain on environmental authorities and challenges in making sure that all relevant measures are included in all Programs of Measures and up to date.
  • The Barcelona Convention's post-2020 Strategic Action Plan for Biodiversity and General Fishery Commission for the Mediterranean and the Black Sea 2030 Strategy are temporally aligned.
2 - Do the policy objectives within the group of policies have the same status and power to put into effect action?
  • Are there differences in how legally binding different objectives are? Are there differences in the enforcement opportunities they encompass?
  • Do the various objectives entail the same requirements for authorities to take action? Compare, for example, whether the authorities are expected to accomplish the objectives (=obligation of results), or are only obliged to make sufficient efforts to work towards them (=obligations of best effort)?

Example

In the EU, the policy objectives regarding the achievement of offshore wind energy are quantitative and allow no discretion on the authorities. Member States need to develop tendering procedures to achieve the decided output. On the other hand, the qualitative objective to achieve a Good Environmental Status under the Marine Strategy Framework Directive is mainly considered to be an obligation of best effort, and has therefore less power to ensure achievement of the objectives.

3 - Does the policy allow for exemptions from certain objectives? How does the use of these exemptions affect the level of coherence within the policy?
  • How do potential exemptions from some policy objectives affect the overall policy direction of the group of policies?

Example

  • The Renewable Energy Directive III aims to accelerate the production of renewable energy, including offshore wind energy. To facilitate the acceleration, several exemptions are allowed from the Habitats Directive, the Marine Strategy Framework Directive and the Nature Restoration Regulation, especially to simplify the approval of offshore energy projects that can impact biodiversity. As such, the exemptions may negatively impact biodiversity and conflict with the objectives of the biodiversity-related policies.
  • The Water Framework Directive (WFD) aims to achieve good ecological status of water bodies, amongst other things, through implementing measures to reduce pollution from various sources, including agriculture. Certain agricultural practices (e.g., use of specific pesticides or fertilizers) are however exempted to support agricultural productivity. The exemptions for agricultural practices can lead to increased pollution of water bodies, undermining the ecological status objectives of the WFD.
4 - Are the policy objectives cross-referencing objectives of the other selected policies?

Example

The Nature Restoration Regulation refers to and is highly complementary to the Habitats Directive and Birds Directive. The policy imposes restoration obligations in relation to habitat types protected by the Habitat and Birds Directives, and non-deterioration obligations for such areas for which good condition already has been reached. The Nature Restoration Regulation further refers to the EU Climate Law and Renewable Energy Directive III.

Coherence of measures towards the objectives

Whether a policy’s objectives are achieved depends not only on the measures of that specific policy, but also on the measures that are in place in other policies.

Policies that are interrelated are therefore often affected by one another’s measures. The success of measures within one policy can have positive spillover effects on other policies. However, trade-offs are also possible. This interplay is important to assess and understand in the external coherence assessment.

Figure 11 Measures affect other policies' objectives and measures
Figure 11 Measures affect other policies' objectives and measures

To begin the assessment, we recommend exploring the following questions:

1 - How do the measures of policy A support the objectives and measures of policy B, and vice versa? (pair-wise mapping and comparison)
2 - How do the measures in combination support the objectives of the policies included in the assessment?
3 - Does the combination of measures contribute to achieving overarching ambitions, such as those within the European Green Deal, the Sustainable Development Goals, or the Oceans Pact?

Examples

  • Marine Protected Areas (MPAs) often aim to conserve marine biodiversity by restricting human activities in designated areas. This can be achieved through establishing MPAs where fishing and other extractive activities are limited or prohibited. On the other hand, fishing zones can be established to support the fishing industry by designating areas where fishing is allowed and regulated. There can be spatial misalignment when MPAs overlap with designated fishing zones. This can lead to conflicts between conservation efforts and fishing activities, undermining both the protection of marine biodiversity and the support for the fishing industry.
  • Fisheries policies may aim to ensure sustainable fish stocks through annual quotas and seasonal fishing bans. The policy may set annual catch limits based on current stock assessments. On the other hand, a country may aim to adapt to long-term changes in marine ecosystems due to climate change through the implementation of long-term strategies to protect marine biodiversity and habitats. Annual catch limits may however not account for long-term shifts in fish populations due to climate change. This temporal misalignment can lead to overfishing or underutilization of stocks, undermining both sustainability and adaptation objectives.
  • Most countries in Europe aim to coordinate the spatial and temporal distribution of human activities in marine areas through long-term marine spatial plans that balance ecological, economic, and social objectives. On the other hand, most countries also have a strong aim to increase renewable energy production through the construction of offshore wind farms to comply with the climate policies. A current acceleration is happening through the fast-tracking of permits and construction timelines to meet renewable energy targets. The long-term nature of Marine Spatial Planning may not align with the urgent timelines for offshore wind development and create incoherent measures.
  • Certain measures taken pursuant to the Offshore Wind Energy Act in the Netherlands can enhance coherence between policies and interests. To illustrate, the possibility of multi-use wind farms supports additional policy objectives such as aquaculture and biodiversity protection. Another measure that can support biodiversity objectives is the use of non-price ecological criteria in offshore wind energy tenders, which is allowed under the Offshore Wind Energy Act and is also promoted by the EU through the Net-Zero Industry Act and the EU Recommendation on the use of non-price criteria in tender procedures for renewable energy. Another measure that cuts both sides is the support of nature-inclusive design as a requirement under the licenses for offshore wind farms in the Netherlands.
  • In France, the Programs of Measures developed within the Marine Strategy Framework Directive and Water Framework Directive refer to one another, and other policies (such as the Habitats Directive) by explaining linkages between measures.
  • Monitoring measures for offshore wind developers is a possible measure to support the monitoring obligations under the Marine Strategy Framework Directive and collect data that feeds into the implementation of the Maritime Spatial Planning Directive as well.
  • Measures designed to promote renewable energy can conflict with agricultural policy objectives, leading to horizontal inconsistencies. To illustrate, governments may provide subsidies to encourage the production of biofuels as part of their renewable energy strategy. This aims to reduce reliance on fossil fuels and lower greenhouse gas emissions. However, agricultural policies often aim to ensure food security and promote sustainable farming practices. The subsidies for biofuel production can lead to a significant portion of agricultural land being diverted from food crops to biofuel crops. This can reduce the availability of land for food production, potentially undermining food security and sustainable farming objectives.

Do you want to go more in depth? Be aware of the following:

For the analysis of coherence between policies, the identification of relevant guiding questions for the assessment of measures may depend on what type of policies are being assessed.

To start the formulation of relevant guiding questions, we recommend applying and adjusting the guiding questions from the internal coherence assessment of measures to the external coherence assessment.

For more in-depth assessments in the context of environmental policies, we have developed two illustration cases for the assessment of:

1) Environmental policies towards other environmental policies.

2) Environmental policies towards other types of policies, for instance sectoral policies that regulate economic activities.

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Note that elements from both illustration cases might be combined, depending on the types of measures. It is important to align the guiding questions with the type of policies that are subject to the assessment.

Targeted guidance: How to assess policy coherence between measures of environmental policies?

Policies primarily focused on governing environmental status and protection should be mutually supportive (e.g., Marine Strategy Framework Directive, Water Framework Directive, Habitats Directive, Nature Restoration Regulation). The coherence assessment should focus on understanding whether the policy measures sufficiently promote synergies towards a coherent landscape of environmental policies, for example by asking:

  1. What specific natural assets do the various measures of the policies within the group aim to manage? Examples are individual species, groups of species, habitats, ecosystems.
  2. Do the policy measures complement each other, or do they lead to inconsistencies, fragmentation, and additional burdens? Examples include terminology and definitions, use of indicators, and definitions of threshold values.
  3. Many environmental policies require strategic plans as a policy measure to coordinate across sectors that cause pressures on nature.
    1. Are all sectoral authorities that might have an impact on the natural asset’s environmental condition involved and coordinated in the strategic planning processes?
    2. To what extent are the planning cycles between the selected policies coherent:
      • Are they temporally aligned?
      • Are there collaborative efforts in monitoring and reporting across the policies?
      • Are shared stakeholders and decision-making authorities engaged throughout the planning cycles of various policies to ensure coherence?
      • Are programs of measures compatible and mutually supportive? Are they referring to each other?

Together, these questions may frame the assessment of measures between environmental policies.

It is important to be aware that the level of coherence between policies that belong to the same policy area should be high. This means that the measures and the objectives of such policies should reinforce one another, enabling synergetic planning, policymaking and decision-making with positive outcomes for the environment.

Targeted guidance: How to assess policy coherence between measures of sectoral and environmental policies?

When assessing the coherence of a group of policies that includes at least one sectoral policy (such as Common Fisheries Policy, Common Agricultural Policy, Renewable Energy Directive) alongside an environmental policy(e.g., Marine Strategy Framework Directive, Water Framework Directive) it is essential to understand how the combination of policy measures within the group influences its overall policy direction.

This involves examining whether the policy measures are balanced to achieve all policy objectives simultaneously, or if some measures are more influential than others, potentially leading to incoherence where not all policy objectives are met. The assessment should focus on understanding these dynamics across the various policy measures, identifying where trade-offs could occur and where synergies can be pursued. The following questions are recommended:

  1. Which policy measures that are part of the assessment target the same actors or activities?
  2. Do the measures provide supporting or conflicting incentives?
    1. If the measures provide conflicting incentives, which of these policy measures are more influential? Compare for example their legal status, enforceability, and impact on decision-making processes.
    2. How does this affect the realization of policy objectives? Does this lead to one policy, or a set of policy objectives, being more easily achieved than others?
  3. Are environmental considerations mainstreamed into the sectoral policy?
    1. If the sectoral policy includes subsidies and financial resource allocation, how does this impact the achievement of environmental policy objectives? Do these financial measures create conflicting incentives, or do they support the realization of environmental objectives?
    2. Are the licensing and permitting criteria within the sectoral policy aligned with the indicators and objectives of the environmental policy?
    3. Are the criteria with direct applicability aligned with the indicators and objectives of the environmental policy?

Together, these questions may frame the assessment of the measures between sectoral and environmental policies.

It is important to be aware that trade-offs are common in decision-making processes. Without strong and enforceable measures in the environmental policies, trade-offs can easily have negative consequences for the environmental objectives while fostering economic development.

The implementation of measures of sectoral policies should not hinder progress towards realizing the environmental policies’ objectives and measures. This is the minimum level of coherence that should be envisioned in such assessments.

Further reading

For an overview of the references and sources used for the development of this handbook, see References.

For more examples on identified policy (in)coherence challenges, see the Marine Policy Coherence Roadmaps developed within the CrossGov project: Roadmaps - Crossgov Project.