APPENDIX 3: EUROPEAN COMMISSION RESPONSE
TO THE EUROPEAN UNION SELECT COMMITTEE REPORT ON THE ANNUAL POLICY
STRATEGY FOR 2008
COMMENTS OF THE EUROPEAN COMMISSION ON AN OPINION
FROM THE HOUSE OF LORDS[80]
COM(2007)65 - ANNUAL POLICY STRATEGY FOR 2008[81]
The Commission welcomes the Report from the House
of Lords EU Committee on the Commission's Annual Policy Strategy
(APS) for 2008 as a constructive contribution in view of the preparation
of the Commission's Legislative and Work Programme (CLWP) for
2008.
The Commission takes note of the many clear and constructive
ideas outlined in the report as to how the structure and presentation
of the APS could be improved to make it more strategic and to
allow a more focused and timely policy dialogue with the European
Parliament, the Council and national parliaments in preparation
of the CLWP.
The Commission agrees with the principle that the
APS should as far as possible be focused on strategic priorities
and provide a vision for the coming year. Nevertheless, it sees
some tension in the report between this recommendation and the
wish for a more detailed description of individual policy initiatives
in the APS. Being more specific or detailed on individual policy
proposals at such an early stage is difficult, not least since
the Commission is fully committed to respect our better regulation
agenda including proper consultation and impact assessment on
all initiatives appearing on the CLWP later on in the year (except
Green Papers, social partner consultation documents and regular
reports). A choice, therefore, has to be made and the Commission
is clearly in favour of the more strategic approach.
Presenting the annual policy strategy according to
traditional policy areas (rather than following the Commission's
strategic objectives) might facilitate a sectoral policy dialogue
with other institutions. At the same time, such an approach could
lead the debate away from a more strategic vision by focusing
on sector-specific interests instead. The Commission considers
the inclusion of a number of cross-cutting issues a positive element
which should give a clear idea of the Commission's overarching
priorities while allowing for sectoral expertise to become engaged
in the debate.
The Commission agrees with the Committee that the
APS should be construed around a set of clear strategic priorities
defined at the political level around which operational services
should provide their contributions. This, in fact, reflects rather
well the process that is currently in place to prepare the document.
Like the Committee, the Commission attaches great
importance to a constructive and politically anchored scrutiny
process by the European Parliament, and also welcomes input from
national parliaments, in view of preparing the CLWP. Time-wise,
however, the input provided by these institutions should reach
the Commission in the first semester of the year for it to be
adequately taken into account by the Commission in the preparation
of the CLWP. For information, the Commission services start preparing
their input for the CLWP already in June/July.
Giving a justification, explaining the added value
and discussing financial implications of each individual policy
proposal in the APS would, the Commission believes, make the document
rather difficult to read and would most likely change its character
from a vision document to a rather detailed list of policy initiatives.
Some of the disadvantages of such an approach are discussed above.
The Commission appreciates the need to explain more
pedagogically in the APS the link between the APS and resources.
The various initiatives proposed by the Commission in the APS
for 2008 should be seen in the context of the very recently agreed
spending programmes and political priorities that underpin the
overall financial envelopes agreed for the 2007-2013 Multi-Annual
Financial Framework (MFF) in the Inter-Institutional Agreement
of 17 May 2006. In terms of financial resources, the MFF indeed
remains the framework for the APS and it has been fully taken
into account when drawing up the APS. Section 3.2 of the APS only
proposes marginal adjustments to the MFF.
With respect to the budgetary implications of the
APS on an annual basis, the Commission considers that budget
and policy should be seen as complementary. The purpose of the
APS is precisely to set the political framework in which the annual
budget is to be established. However, the institutional framework
of the EU is such that there is seldom a direct link between the
policy initiatives undertaken in a given year and their related
expense in that same year. For instance, the 2008 Budget will
finance actions which flow from legislative proposals presented
in previous years, which the co-legislators have approved in 2007
or earlier. By the same token, the legislative proposals put forward
in 2008 will have almost no budgetary implications for 2008, but
will come on stream at the earliest in 2009. Furthermore, many
initiatives from the Commission have little or no costs to the
EU budget at all, such as the legislative actions in the area
of the internal market or the application of EU competition rules.
The Commission's simplification work is programmed
within the multi-annual Rolling Simplification Programme which
has a horizon of 2-3 years and is up-dated every year (see COM(2006)
690), normally at the same time as the presentation of the CLWP.
This medium-term forward planning is public and allows the other
institutions and stakeholders to comment on the Commission's simplification
priorities.
Whilst the Commission's Annual Report on Better Lawmaking
is focused on progress during the preceding year (including key
developments at the inter-institutional level), the Commission
regularly undertakes strategic reviews on better regulation, setting
out its priorities and policy initiatives for the following years.
Such strategic reviews were presented in March 2005 (COM(2005)
97) and November 2006 (COM(2006) 689). The next review is planned
for early 2008.
Following an external review of the impact assessment
system, carried out between August 2006 and April 2007, the Commission
is currently reviewing its impact assessment methodology and guidelines.
In this context, the Commission is examining how the assessment
of particular aspects such as competitiveness, social impact,
and fundamental rights can be reinforced without jeopardising
the overall balanced and proportionate approach to impact assessment.
Concerning the sometimes detailed comments on individual
policy initiatives in the APS provided by the sectoral sub-committees
of the House of Lords, the Commission will consider these when
it draws up its CLWP for 2008. The Commission will also communicate
these comments to the competent services which may decide to take
them into account when developing the policy initiatives further.
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COM(2007) 65 Back
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