development of the finnish agri-environmental policy as a learning process

Copyright © 2005 John Wiley & Sons, Ltd and ERP Environment

European EnvironmentEur. Env. 15, 13–26 (2005)

Published on Wiley InterScience (www.interscience.wiley.com). DOI: 10.1002/eet.370

Development of The Finnish Agri-Environmental Policy as

a Learning Process

Laura Kröger*MTT Agrifood Research Finland/Economic Research, Finland

ABSTRACTWhen Finland joined the EU in 1995, agri-environmental policy changed significantly,in terms of both content and style. As a result of the policy process, substantialchanges took place in institutional structures and in policy instruments. The mostremarkable change, however, was that co-operation between environmental and agri-cultural administration began. This co-operation has become ever more important,especially regarding future challenges of implementing the EU Water FrameworkDirective. This paper examines the development of Finnish agri-environmental policyin the Advocacy Coalition Framework by concentrating on three separate, but interconnected, policy formation processes, namely the Finnish Agri-EnvironmentalProgramme, the Nitrates Directive and the recent Water Framework Directive. By con-centrating on these policy processes it was possible to analyse the evolution of thepolicy subsystem over time, to examine the changes in policy belief systems, then toanalyse the elements that either enable or prohibit co-operation and finally to assessthe role of policy learning in the process. Copyright © 2005 John Wiley & Sons, Ltdand ERP Environment.

Received 24 February 2004; revised 5 September 2004; accepted 23 September 2004

Keywords: policy learning, Advocacy Coalition Framework, agri-environmental policy, Nitrates Directive, Water Framework

Directive

*Correspondence to: Laura Kröger, MTT Agrifood Research Finland/Economic Research, Luutnantintie 13, 00410 Helsinki, Finland. E-mail: [email protected]

Introduction

DURING THE PAST 20 YEARS ENVIRONMENTAL PROBLEMS IN AGRICULTURE HAVE INCREASED. THESE

problems are mostly due to the greater intensification, higher productivity and concentration

of production. In the middle of the 1980s, the European Commission underlined in its Green

Paper (EC, 1985) that environmental policies must set the framework in which agricultural

production takes place. The idea of combining environmental and agricultural policies was then an

14 Laura Kröger

important pillar in the reform of the Common Agricultural Policy (CAP) in 1992. By introducing the

EU agri-environmental Regulation 2078/92 (CEC, 1992) as a part of so called accompanying measures

to the CAP, the reform reflected political and financial priorities given to the role of agriculture in pro-

tecting and maintaining the environment. This role is becoming even more important due to the recent

CAP reform in 2003. Agri-environmental policy is also regarded as a way to smoothly integrate the new

member states.

In addition to agri-environmental policies, there are also environmental regulations concerning agri-

culture. The most difficult piece of EU environmental legislation with regard to agriculture has been

the Nitrates Directive (91/676/EEC; CEC, 1991). The implementation record of this directive is very

poor: 12 of 15 member states have been the subject of legal proceedings with respect to incorrect imple-

mentation of the directive (EC, 2002). The member states have faced quite similar problems in imple-

menting this directive. The problems have not necessarily occurred only at the national level, but also

at regional and local levels where there is a lack of resources or interest to successfully carry out envi-

ronmental duties. Another demanding piece of environmental regulation regarding agriculture is the

recent Water Framework Directive (2000/60/EC; CEC, 2000). Due to its far-reaching and demanding

objectives, successful implementation can hardly occur without policy learning. Instead of forcing imple-

mentation to happen through legal obligations and court procedures, a policy learning approach empha-

sizes co-operation, networks and the use of new policy instruments.

When a new member joins the EU, it faces an enormous challenge to implement the acquis commu-nautaire after a relatively short transition time, and often environmental concerns are not given the

highest level of priority. Since Finland joined the EU in 1995, the Finnish agri-environmental policy has

quite recently undergone significant changes, in terms of both content and institutional structures.

Finland has had to accommodate its national policies to the principles and objectives of the Common

Agricultural Policy, its accompanying measures and the environmental legislation of the EU. This has

been a challenging task for both the environmental as well as the agricultural policy sectors.

In Finland, since there are nearly 200000 lakes, 46000km of shoreline and 20000km of rivers,

the issues that are related to water protection have usually gained most of the attention in agri-

environmental policy (Jokinen, 1995, 2000; Kaljonen, 2003; Yliskylä-Peuralahti, 2003). Hence, this

paper analyses three independent, but interrelated, policy processes, which are of relevance in this

respect. First, the Finnish Agri-Environmental Programme (MAF, 1994 1999) was a response to EU

Regulation 2078 (2078/92/EEC, CEC, 1992; 1257/99/EC, CEC, 1999). The programme introduced new

kinds of economic policy instrument such as voluntary contracts and subsidies and its implementation

relied on co-operation between agricultural and environmental sectors. Since both policy content and

style were new to the agricultural administration, which was responsible for the programme, the policy

process presented a real challenge. Second, the Nitrates Directive (91/676/EEC; CEC, 1991), in turn,

represents a command-and-control approach with strict requirements and mandatory measures for

farmers. Since regulatory environmental instruments had not been used before in agri-environmental

policy, the implementation of the directive became an issue of conflict between agricultural and envi-

ronmental sectors. Third, the recent Water Framework Directive (2000/60/EC; CEC, 2000) is a com-

bination of both voluntary and command-and-control approaches. It represents a shift from a sectoral

to a horizontal policy style and embodies a number of requirements for co-operation between different

water use sectors, including agriculture. With regard to this paper, the three pieces of EU regulation

mentioned above are considered theoretically as ‘shocks’ from outside the Finnish agri-environmental

policy subsystem. In Paul Sabatier’s Advocacy Coalition Framework (ACF), these external shocks,

together with policy learning, can cause a policy change to occur. The development of the Finnish agri-

environmental policy is then analysed in terms of the characteristics of certain types of policy change

identified by Peter Hall (1993). By concentrating on these three policy processes it is possible to analyse

Copyright © 2005 John Wiley & Sons, Ltd and ERP Environment Eur. Env. 15, 13–26 (2005)

Finnish Agri-Environmental Policy as a Learning Process 15

the evolution of the agri-environmental policy subsystem over time, examine the characteristics of dif-

ferent policy beliefs within, identify the elements that may either prohibit or enable co-operation and

assess the role of policy learning in the process. Empirically, this study draws on semi-structured inter-

views with key persons in the Finnish agri-environmental policy community and literary reviews.

Policy Learning and Change

Policy change does occur and there exists a wide and diverse theoretical literature that describes and

explains policy change in various ways. For this research, literature on learning-based policy change was

chosen as the basic theoretical reference point, since it seems to provide the most comprehensive theory

to explain policy change.

The policy process can be understood in terms of policy learning. The different approaches to policy

learning share a view that learning takes place in complex arrangements of state and societal actors, in

various types of domestic and transnational policy network and policy community (Bennett and Howlett,

1992, p. 282). Policymakers work within a framework of ideas and standards that specify not only the

goals and instruments of the policy, but also the nature of the issue in question (Hall, 1993). Policy-

makers must strengthen their understanding of the problem beyond the current conceptualization to

be able to formulate new policy objectives and instruments that can contradict old policy beliefs, espe-

cially when the policy change is radical or sudden, for instance when implementing new EU directives.

In fact, this conflict between old and new policies often facilitates learning (see, e.g., Heclo, 1974;

Etheredge, 1981; Thomas, 1999; Wilson, 2000; Sanderson, 2002).

Policy learning occurs in the context of political process. The first learning-based theory of policy

change developed by Heclo (1974, p. 306) described ‘political learning’ as relatively enduring alterations

of thought or behavioural intentions that result from experience. In addition to policy-makers’ experi-

ence, the existing policy matters. According to Sacks (1980), while policy-makers learn in response to

changes in the external policy environment, the most important influence in this learning is previous

policy itself. However, learning does not always have to draw on one’s own past experience; it can also

be comparative in focus. Rose (1991) uses the concept of lesson-drawing to describe the process by which

policies and programmes developed in one country are emulated by others. It raises the possibility that

policy-makers can draw lessons from others that will help them deal better with their own problems.

The accumulation of policy experience over time and continuing advances in science and technology

also create opportunities for policy-makers to learn (Busenberg, 2001). The learning process requires

particular institutional arrangements, such as certain procedures and customs that promote individual

learning. However, while some arrangements act to promote learning, other institutional arrangements

can act as constraints. A fragmented administrative structure, for instance, prevents a flow of informa-

tion to other departments, thereby inhibiting wider learning. Furthermore, as Hall (1993, p. 293) points

out, learning does not necessarily mean that policy becomes better or more efficient; rather, it reflects

an attempt to adjust policy in the light of past experience and policy relevant knowledge.

The problem is to verify that policy learning has occurred. Eising (2002, p. 91) suggests that first it

has to be shown that actors have changed their preferences, and then a policy change indicates that

policy learning has occurred. Following Hall’s (1993) distinction between three orders of policy change,

it becomes more systematic to assess the evidence on policy learning. First order policy change involves

only incremental change, and the policy-makers’ response to demands for change is to use the same

kinds of solution they have used before. Second order policy change includes a redefinition of the policy

problem and strategies. It can also lead to moderate institutional changes, while the overall goals of

policy remain the same. Instead of policy learning, a first or second order policy change can indicate


16 Laura Kröger

that policy adaptation has occurred. The difference between learning and adaptation, according to Haas

(1990), is that in policy learning process the principles, objectives and values underlying the policy are

examined and questioned by actors, whereas adaptation is the ability to change behaviour in order to

meet the challenges of new demands without having to evaluate the existing policy and reason its legit-

imacy. The third order policy change in turn involves changes in policy principles, objectives and instru-

ments. It also includes a different conceptualization of policy problems that leads to changes in policy

content and style. Due to its emphasis on interaction and communication between state and societal

actors, third order change can also be characterized as social learning (Glasbergen, 1996; Fiorino, 2001).

Learning-based theories of policy change have often been criticized for not distinguishing between

policy learning and policy change (e.g. Bennett and Howlett, 1992; Mintrom and Vergari, 1996).

However, one important observation found in literature on this topic is that, rather than offering an

explanation of change, learning is seen as an instrument to facilitate a policy change. As Jordan and

Greenway (1998) put it, learning is a means of getting preferred ideas or beliefs reflected in public policy

programmes. In this paper this instrumental definition of learning is used, based on the idea that learn-

ing is often necessary for policy change to occur.

Policy learning, ‘policy-oriented learning’ to be exact, is also of particular interest in the Advocacy

Coalition Framework (ACF), an actor-based analytical framework for analysing policy change, developed

in response to the complexity of environmental policy subsystems (e.g. Sabatier, 1986, 1998; Jenkins-

Smith and Sabatier, 1994). The ACF assumes that policy change is a result of policy learning and exter-

nal perturbations to the subsystem. Sabatier (1986) translates Heclo’s (1974) basic ideas of political

learning and issue networks into a conceptual framework for examining policy change over time. Instead

of focusing on individuals, the ACF focuses on ideologically based advocacy coalitions, which consist of

actors from a variety of public and private institutions who share a set of basic beliefs and show co-

ordinated activity over time. The ACF assumes that each coalition seeks to influence the policy formu-

lation and implementation in order to achieve their policy goals. This can be achieved by using various

policy strategies and guidance instruments for changes in rules, budgets and personnel or public opinion

(Sabatier and Jenkins-Smith, 1993). The competing advocacy coalitions thus work to materialize their

belief systems through a policy change.

The belief system is organized into a hierarchical structure, implying the assumption that resistance

to change decreases from deep core beliefs to policy core beliefs and to secondary aspects (Peffley and

Hurwitz, 1985). Deep core beliefs operate across all policy subsystem and, therefore, are outside the

focus of this study. Policy core beliefs represent a coalition’s basic normative commitments and causal

perceptions. An agreement over policy core beliefs is the principal glue holding an advocacy coalition

together (Jenkins-Smith and Sabatier, 1994, p. 183). While the policy core beliefs are resistant to change

and keep the coalitions stable, they can also be subject to change over periods of a decade or more. Sec-

ondary aspects, in turn, comprise instrumental decisions and information searches that relate to the way

in which policies are implemented. Beliefs in the secondary aspects are assumed to be easily adjusted

in the light of new data, experience or changing strategic considerations.

While the focus of the ACF is on belief systems and policy learning, the framework is also concerned

with two sets of external variables. The first set includes relatively stable exogenous variables that are

the basic attributes of the problem area, socio-cultural values and social structure, constitutional struc-

tures and natural resources of a political system. The stability indicates that these variables are very dif-

ficult to change and, therefore, are very seldom the subject of coalition strategies. These parameters are

stable regarding the theory, but in the case of the Finnish agri-environmental policy, due to the mem-

bership of the EU even some of the stable parameters changed. The second set of external variables

includes more dynamic variables that are policy decisions and impacts from other subsystems, changes

in socio-economic conditions, public opinion and systemic governing coalition. These variables are, in



turn, more likely to change over a decade or so. According to the ACF, the combination of stable and

dynamic external variables provides a set of constraints and opportunities that affect subsystem actors.

Policy change then occurs, partly in response to external changes and partly from policy learning. Change

usually alters the balance of power among the actors and it can also change the structure and the mem-

bership of the coalitions.

Since the Advocacy Coalition Framework was first introduced in 1986, it has successfully been used

in a number of studies. This exercise has confirmed the usefulness of the framework, but also suggested

some modifications. The revised version was published in 1993, together with a few reports of the case

studies (Sabatier and Jenkins-Smith, 1993). Since then Sabatier and other scholars have continued to

refine the framework by applying it to a variety of policy domains around the world (see the list of appli-

cations in Sabatier, 1998). Since the ACF was originally developed for the US system, Parsons (1995)

has questioned its applicability to countries with different political systems e.g. Scandinavian countries.

Yet the ACF has been applied the in the European context by several scholars, who have found it to be

useful at least for identifying important variables and relationships (e.g. Greenaway et al., 1991; Peter-

son, 1995; Elliott and Schlaepfer, 2001; Weber and Christophersen, 2002).

For the purpose of this paper, as Sabatier suggests, the policy learning approach is particularly suit-

able in the policy domains that are dominated by professionals, where natural systems are involved and

where quantitative data is available, as in agri-environmental policy. Since the ACF also deals with the

dynamics of both stability and change in the policy process, aspects that are of central importance in

the development of the Finnish agri-environmental policy, the ACF was chosen as the basic theoretical

framework for this study.

Birth of The Finnish Agri-Environmental Policy Subsystem

As in many other western countries, agricultural administration and farmers’ unions have traditionally

been able to formulate the agricultural policy in Finland. Jokinen (1995, p. 64) uses the concept of ‘agri-

cultural policy community’ to define the case of Finnish policy-making. This policy community had the

definitive decision-making power (Kettunen, 1992). There were no remarkable public, political or par-

liamentary disputes over agricultural policy principles. The policy was made to look like a technical non-

political process (Vihinen, 1990). From the ACF perspective, there was only one advocacy coalition,

namely the agricultural coalition, which was a very powerful actor in policy-making. It has held this

dominant position in the agricultural policy subsystem over several decades. One illustrating feature of

this closed policy community is the circulation of people in leading positions. For example, the same

people have held senior official positions in the Ministry of Agriculture and Forestry and in the Farmers’

Union and several ministers of agriculture have had a past in the Farmers’ Union. As Vihinen (1990)

and Aakkula (1991) also show, the agricultural coalition can be characterized by a limited number of

participants, the dominance of economic interests, frequent interaction between members, a high degree

of consistency in membership and broad consensus on policy beliefs and preferences.

The relationship between agriculture and nature was considered environmentally sound until the mid-

1980s when people became aware of the negative environmental impacts caused by agriculture (Jokinen,

2000). This happened partly due to increasing environmental awareness in general and partly by notic-

ing that, since municipalities and industry had cut down their water pollution, agriculture has become

a substantial source of nutrient loading. The need for scientific knowledge about the environmental

effects of agriculture led the Ministry of Agriculture and Forestry to establish a wide-ranging research

project. The results of the project showed that agriculture is as serious a polluter as many other indus-

tries (Rekolainen et al., 1992). In fact, the results were so significant that the environmental impacts of


18 Laura Kröger

agriculture could no longer be neglected by the agricultural coalition. As an interviewee from agricul-

tural administration put it, ‘it was an awakening’. Scientific evidence, together with changes in public

opinion as a result of increased awareness of environmental effects of agriculture, gradually led to the

formation of an environmental coalition in agricultural policy. The development of the Finnish agri-

environmental policy subsystem corresponds to Sabatier’s (1998, p. 114) idea of subsystems that emerge

from a relatively new issue. He argues that, as information develops concerning the seriousness of the

problem, and the causes and the costs of remedying the situation, actors tend to coalesce into distinct

coalitions. In the Finnish case, once environmental problems caused by agriculture were recognized, it

took over a decade for the subsystem with two distinct coalitions to become established.

The environmental coalition consisted of representatives from the central and regional environmen-

tal administration, the Finnish Environment Institute and the Finnish Association of Nature Conver-

sation. They believed that intensive agriculture was damaging the environment and that the objectives

of the agricultural sector were based on economic interests, mostly at the expense of the environment

(Valve, 1995). The general goal of the environmental coalition was then to protect the environment and

eliminate the damage caused by agriculture, whereas the agricultural coalition was defending the inter-

ests of private farmers and their businesses (Niemi-Iilahti and Vilkki, 1995). According to an intervie-

wee from environmental administration, the increase in information concerning the environmental

impact of agriculture led to some policy learning occurring within the agricultural coalition. They finally

agreed that pesticides have negative impacts on the environment and that eutrophication is partly caused

by the leakage of nutrients. Agricultural actors believed, however, that these problems can be solved with

technological solutions and that the best way to protect the environment is to leave it in the hands of

farmers (Kiijärvi, 2002). Eventually, aided by the right information, advice and support farmers will start

using good farming practices (ME, 1992). Suggestions for such policy measures were, e.g. special sub-

sidies for environmental investments and information guidance for farmers, i.e. the same kinds of

instrument as had been used before in the national agricultural policy. They also suggested more

research. Suggesting further research is also, according to Jenkins-Smith and Sabatier (1994, p. 194),

one of the means through which the major coalition will seek to diminish the reasons for change.

Nevertheless, the agri-environmental policy changed at the beginning of the 1990s. The most signif-

icant change, however, did not concern the content of the policy, but the policy-making style. For the

first time the environmental problems of agriculture were taken into account at the central government

level by the start of co-operation between the Ministry of Agriculture and Forestry and the Ministry of

the Environment. Although the co-operation was initiated by the Ministry of the Environment in order

to get information for the state budget, it started the era of co-operation between agricultural and envi-

ronmental administration. This co-operation, in addition to the results of the previous research pro-

gramme, led to the first Rural Environmental Programme (ME, 1992). The programme was based on

voluntary instruments; regulations were neglected. The measures included information guidance,

support for farmers to start using good farming practices and subsidies to environmental investments.

The development of the Finnish agri-environmental policy prior to EU membership corresponds to

the basic argument of the ACF: while policy-oriented learning is an important aspect of policy change

and can often alter secondary aspects of a coalition’s belief system, policy change requires perturbations

external to the subsystem (Jenkins-Smith and Sabatier, 1994, p. 183). Since there were no significant

changes in external variables, the agri-environmental policy subsystem was in a stable state and deci-

sion-making power stayed in the hands of the agricultural coalition. The changes in the Finnish agri-

environmental policy were then not due to changes in actors’ policy core beliefs, but on the level of

secondary aspects. Following Hall’s (1993) distinction between different orders of policy change, this

represents the first order policy change, where instruments are modified in the light of past experience

and new knowledge, while the overall goals and instruments remain the same.



Towards Shared Beliefs

Although the Rural Environmental Programme (ME, 1992) was set up with possible EU membership

in sight, the Finnish agri-environmental policy changed significantly as a result of joining the EU in

1995. The adaptation of the EU agri-environmental Regulation 2078/92 (CEC, 1992; in 1999 moved

into Regulation 1257/99, CEC, 1999) required changes in legal structures, bureaucratic practices and

administrative procedures. Regulation 2078 introduced new kinds of economic environmental policy

instruments. The monitoring and control requirements were also substantial, in comparison with the

previous national requirements. The most remarkable change, however, was that, from that moment

on, the Finnish agri-environmental policy was based on the principles and political objectives of the EU.

The Finnish Agri-Environmental Programme 1995–99 was prepared by a working group consisting

of agricultural and environmental authorities. The representatives from the Farmers’ Union, Associa-

tion of Rural Advisory Centres, and Finnish Association for Nature Conservation consulted the group.

Regional authorities were also given an opportunity to comment on the draft version. The preparation

was carried out to a very tight schedule and, therefore, it was based on the existing, very limited, knowl-

edge. This shortage of scientific data brought about different opinions on suitable measures.

Researchers, for instance, gave differing results on the optimal width of the buffer strips, which caused

the width to become an issue of conflict. From the ACF perspective, the members of the agricultural,

as well as the environmental, coalition used different research results as strategic tools to defend their

opinions.

There was a struggle for administrative power over environmental issues in agriculture in general,

which culminated in the question of whether the agricultural or environmental administration had the

power to determine the specific targeting measures. Despite several disagreements between the coali-

tions caused by different interests, policy beliefs and administrative traditions, both coalitions agreed on

the necessity of co-operation. Little by little they also ‘learned to speak the same language’ and some

common practices became established. Altogether, there was a common interest in finding the best

possible solution.

These changes in behaviour, according to Haas (1990), clearly indicate that policy adaptation has

occurred. Furthermore, following Hall’s (1993) distinction between different orders of policy change,

clear evidence for second order policy change can also be seen here: a redefinition of policy issues with

some institutional adjustments. There is, however, no evidence for the third order change. Policy prin-

ciples and objectives did not really change, and there was no a consensus on the adequate levels of envi-

ronmental requirements. Nor were preferences on the choice of suitable policy instruments similar. The

agricultural coalition emphasized the importance of economically profitable production and was still

favouring subsidies, voluntary measures and information guidance. The environmental coalition, in

turn, demanded more regulative control-and-command types of policy instrument. However, since the

Agri-Environmental Programme combines compensatory payments for farmers and environmental

requirements, both coalitions were able to turn its objectives to support their own interests.

The Ministry of Agriculture and Forestry launched a research programme to monitor the impact of

the programme. It also started a follow-up working group in order to assess the impact and to make

proposals for improvement. The members of the follow-up group included representatives from the agri-

cultural and environmental administrations, who in fact were mostly the same persons as involved in

the previous preparing group, representatives from the Farmers’ Union, the Association of Rural Advi-

sory Services and the Finnish Association for Nature Conservation. To facilitate their learning the group

used a wide variety of different learning mechanisms. For example, they listened to numerous presen-

tations from researchers and experts of both agricultural and environmental sectors. They also had


20 Laura Kröger

research carried out on specific topics of their own interest, such as loading of nutrients from agricul-

ture and problems concerning production of landscape and biodiversity. Furthermore, the group made

several trips to various regions to meet the people who are actually implementing the programme in

order to learn about measures and problems, and also to meet farmers. Finally, a seminar was orga-

nized, where decision-makers, authorities, researchers and other experts discussed the environmental

effects of different agri-environmental measures.

The Finnish Agri-Environmental Programme 2000–06 was prepared by the working group that con-

sisted mostly of the same people who were members of the previous follow-up group. In fact, some of

the members had been working together since preparing the first Rural Environmental Programme,

nearly a decade earlier. The interviewees emphasized the importance of knowing each other and their

different ways of thinking. This interaction in addition to ten years of policy experience and accumula-

tion of information concerning agri-environmental issues had a substantial influence on the policy

process. As a consequence, the preparing process occurred without any major disagreements. The draft

version of the programme was commented on by nearly a hundred actors from regional and local level

administration, organizations and businesses. Their comments were actually taken into account in the

final version of the programme. Since there were not even any significant changes in external variables,

the 2000–06 Agri-Environmental Programme differs from the 1995–99 programme only in some

details. Policy principles, objectives and most of the measures remained the same. When interviewed,

the members of the working group described this policy formation process as nice, smooth and easy as

well as common, shared and unanimous.

This policy formation process led to restructuring of the Finnish agri-environmental policy subsys-

tem. Instead of two distinct coalitions, the subsystem is now dominated by a new agri-environmental

coalition, which consists of members partly from former agricultural and environmental coalitions. The

rest of the members have remained in their previous coalitions. The establishment of a new coalition

corresponds to the findings of Elliott and Schlaepfer (2001) regarding the development of Swedish forest

certification. The results of this research then confirmed their proposal for a new hypothesis to the ACF

concerning policy learning across belief systems followed by changes in coalition structure and mem-

bership, which before were considered so rare that there was no specific hypothesis about them.

The observations above indicate that a fundamental change in the Finnish agri-environmental policy

subsystem has occurred. The stable external variables have been constant, with the exception of joining

the EU. However, the national decision-making process, often characterized as an open, multi-party polit-

ical system, did not change as a result of EU membership. The dynamic external variables have also been

relatively constant during the past decade. There have not been changes in governing coalitions or socio-

economic conditions that have affected agricultural policy. The major changes in public opinion, in turn,

occurred already in the late 1980s and early 1990s when people became aware of the environmental effects

of agriculture. When the Rural Environmental Programme was prepared at the beginning of the 1990s,

there were many disagreements between the coalitions, but as a result of years of co-operation and mutual

learning a shared understanding has developed and policy actors have found common practices. During

the policy process interaction between authorities, organizations and farmers has increased. As infor-

mation and knowledge have been accumulated and policy learning has occurred, adjustments have con-

tinuously been made to the Agri-Environmental Programme, which at present is much more effective

than it was in 1995 (MAF, 2004). According to the follow-up study, the programme has encouraged

farming to move towards more environmentally sound practices; e.g., use of fertilizers has decreased and

the vegetation cover in wintertime has increased. The programme has also contributed to a change in

farmers’ actions and attitudes towards the environment. Furthermore, since 90 per cent of farmers have

joined the programme, participation has well exceeded the official target. To summarize, from the policy

perspective, it can be said that the Finnish Agri-Environmental Programme has been successful.



Nitrates Directive – A Conflict Unsolved

As a member of the EU, Finland had to abide by the rules of the Nitrates Directive concerning the pro-

tection of waters against pollution caused by nitrates from agricultural sources (91/676/EEC; CEC,

1991). The Nitrates Directive represents a command-and-control approach with strict requirements and

mandatory measures for farmers. Its implementation has been, as in many other European countries,

an issue of conflict (EC, 2002). The nature of nitrogen pollution is also of significance. The complexity

of the nitrate pollution problem makes a source appointment complicated and, therefore, the regulation

of the problem is very difficult (Goodchild, 1998; Heinz, 2001).

In Finland, the Nitrates Directive is the responsibility of the Ministry of the Environment. They set

up the first preparatory group in 1996 in order to implement the directive. The preparatory group con-

sisted of several representatives from the environmental administration, a representative from the Min-

istry of Agriculture and Forestry and a representative from the Ministry of Justice. Several researchers

and other experts, mostly from the environmental sector, also consulted the group. Although the group

worked for a long time, they were not able to find a consensus and, in the end, the representative from

the Ministry of Agriculture and Forestry left a dissenting opinion to the report (ME, 1997). The proposal

for implementation was not completed until 1998, after negotiations at governmental level. The Com-

mission did not approve the proposal as it was, but after readjustments it was approved in 1999. These

readjustments were made by the second preparatory group, in which a broader participation of stake-

holders was invited. The group came to a compromise proposal for national nitrate regulations.

However, the Commission gave a reasoned opinion, which noted the insufficient requirements of the

national regulation and, in order to avoid the Court of Justice, further adjustments were made. Finally,

the national nitrogen regulation was approved by the Finnish Council of State in November 2000.

The preparatory groups disagreed on several requirements of the directive. The main cause of con-

tention was that the agricultural coalition saw a contradiction between the proposal and the prevailing

Agri-Environmental Programme, which, at the time, was already approved by the Commission. They

claimed that the required measures were unreasonable for farmers. Under the Agri-Environmental Pro-

gramme farmers get support for certain measures, which were now proposed to become mandatory on

the basis of the Nitrates Directive. Since farmers are not allowed to be compensated for implementing

mandatory measures, the proposed regulation would have led to financial losses for farmers. The con-

flict became so serious that the Ministry of Justice was asked to give a statement over the interpretation

of the Nitrates Directive and Regulation 2078/92. The environmental coalition, in turn, saw the Nitrates

Directive as opening up the possibility of making regulations, for the first time, to control the nutrient

load from agriculture. They emphasized that the objectives of the directive were to reduce and prevent

further water pollution from agricultural sources. Therefore, they wanted to make the national

legislation stricter than the directive demands and also stricter than the requirements in the Agri-

Environmental Programme. The agricultural coalition argued that these demands were much too

strict and detailed and were also against the policy principles of the Finnish government. They claimed

that the situation of water protection against pollution caused by agriculture was much better in Finland

than in many of those countries that the Nitrates Directive originally targeted.

The policy process lasted for four years, and the same arguments were used throughout the process.

In ACF terms, at the beginning there were two distinct coalitions and a conflict between them; four

years later there were still two distinct coalitions and a conflict between them. As an interviewee put it,

‘it was a very difficult process that left scars on both sides’. There was no evidence to be found of policy

learning across the coalitions. The regulation at the end was a compromise. As an interviewee pointed

out, ‘there was a need for change already when the regulation was approved in 2000, and there still is’.


22 Laura Kröger

Quite recently the Ministry of the Environment published a memo, which tries to explain what was reallymeant when making the regulation (emphasis put by an interviewee). Although the policy formation

process was difficult, the Nitrates Directive has had some positive effects as regards e.g. storage of

manure and use of fertilizers (MAF, 2004). Its monitoring requirements have also forced the regional

environmental and agricultural administrations to develop new ways of co-operation. As an interviewee

from the agricultural administration puts it, ‘the initiation of this regional level co-operation has come

as a nice surprise’.

The interesting question now is what made the policy formation process so difficult. First, the Nitrates

Directive is based on regulative mandatory measures, in comparison with the Agri-Environmental Pro-

gramme, which is based on voluntary contracts and economic instruments. Since regulative environ-

mental policy instruments have not been used before in the agricultural sector, there is a strong

resistance among agricultural actors towards introducing them. Second, the Nitrates Directive is the

responsibility of the Ministry of the Environment, whereas agri-environmental issues have usually been

under the Ministry of Agriculture and Forestry. Therefore, the administrative traditions and policy beliefs

are very different. Third, the co-operation between environmental and agricultural administration was

very difficult because of intense disagreements. It could be said that whenever the Ministry of the Envi-

ronment suggested any measure the Ministry of Agriculture and Forestry together with the Farmers’

Union strongly opposed it. From the ACF perspective, the coalitions could not achieve a common under-

standing on the policy issues, because their policy beliefs concerning the Nitrates Directive were very

different and, furthermore, no policy learning across the coalitions occurred. Following Hall’s (1993)

distinction between different orders of policy change, no evidence of policy learning can be found here.

Water Framework Directive – Consent or Dissent?

Another environmental directive concerning agriculture is the Water Framework Directive

(2000/60/EC; CEC, 2000) agreed on by the European Parliament and the Council in 2000. The overall

objective of the Water Framework Directive (WFD) is to achieve a ‘good’ ecological status for all water

in Europe by the end of 2015. Given the past improvements in reducing point source pollution, the

emphasis of the WFD will be on minimizing non-point source pollution, which will cause additional

challenges for agriculture.

The WFD lays emphasis on interactive decision-making, public participation and regional diversity,

but at the same time it embodies elements of command-and-control regulation and procedural require-

ments (Fairley et al., 2002; Kaika and Page, 2002; Kallis and Butler, 2001). According to the directive,

water management plans, programmes of measures and environmental quality objectives are to be

pursued at the scale of river catchment areas. By setting up water management at the river basin level,

a more holistic and territorially integrated approach to problems related to water is encouraged (Moss,

2004, p. 85). This approach requires the close co-operation of all actors, including farmers in the area,

which in turn demands the establishment of regional level water networks. These key provisions of the

WFD, as Flynn and Kröger (2003) point out, encourage policy learning to occur at the implementing

stage.

The Ministry of the Environment is responsible for the WFD in Finland. In order to transpose the

legislation and prepare for implementation, they set up a committee with a broad participation of stake-

holders, a steering group consisting of officials from different sectors, a number of thematic working

groups and pilot projects. So far, the preparation work has concentrated on the technical issues of water

classification, collection and harmonization of data and developing a better scientific approach to mon-

itoring. As one interviewee from the environmental administration pointed out, ‘the WFD is a great



opportunity – for researchers’. From the institutional point of view, the existing legislative and admin-

istrative arrangements already meet most of the demands of the WFD, and its implementation will leave

the current legal system largely unaffected. Until now, the policy process has occurred without consid-

erable conflict. The proposal for national legislation was prepared quite unanimously and, at the

moment, is being circulated for comments. Since the legislation only gives a framework for imple-

mentation, major disagreements are not expected (according to an interviewee from the environmental

administration). With regard to the reduction of non-point source pollution caused by agriculture, the

agricultural coalition maintains that existing agri-environmental measures are, in the main, sufficient.

They admit that, in certain areas, some more targeted and efficient measures are needed, though exist-

ing supplementary measures in addition to more financial resources may suffice.

The practical implementation of the WFD is the responsibility of Regional Environmental Centres,

in which quite similar general water protection plans have been made since the 1970s. These planning

processes have been based on a voluntary, participatory and cross-sectoral approach and their main objec-

tive has been to reconcile different needs and interests of different actors in the region. As a result,

plenty of data has been collected, knowledge has increased and actors in the region have learned to co-

operate. However, regional agricultural actors have very seldom been involved in these processes. Thus,

the requirements of the WFD (2000/60/EC; CEC, 2000) for co-operation, public participation and a

river basin approach are common practices in the environmental sector, but not within the agricultural

sector. The situation is very similar with regard to policy instruments. The regulative, i.e. command-

and-control, environmental instruments, which are also included in the WFD, are widely used in envi-

ronmental policy, but not in agri-environmental policy. Given these observations, it can be assumed that

the implementation of the WFD presents a great challenge, especially for agricultural actors. With regard

to policy subsystems, the agricultural sector is now facing the same state of affairs at the regional level

as that which existed at the national level during the formation of the first Agri-Environmental Pro-

gramme ten years before. At the regional level, there is an agricultural and environmental coalition, but

the agri-environmental coalition does not exist.

Until now, the regional environmental administration has established a co-ordination group in each

of the seven river basin districts, but not every group has a representative from the agricultural sector.

Since the main issues in implementation so far have concentrated on technical issues, meetings have

been very matter-of-fact, consisting mostly of lectures by experts followed by discussions based on tech-

nical details. However, this process has only just begun and it is still at a very early stage in the imple-

mentation process. When the implementation process gets to the operational stage, the modus operandi

may change.

Conclusion

This paper has examined whether policy learning has played an important role in the Finnish agri-

environmental policy process. In order to analyse the development of the policy system, examine the

changes in actors’ policy beliefs and then assess the role of learning, three separate processes have been

examined. To explain these processes, the literature on learning-based policy change has been used as

the basic theoretical reference point. Certain findings point out elements that either enable or prohibit

policy learning.

From the policy perspective the Finnish Agri-Environmental Programme is a success story. The

Nitrates Directive, in contrast, represents an unsuccessful policy process. One reason for these differ-

ent outcomes can be explained by the nature of the policy itself. The Agri-Environmental Programme

combines different elements allowing both agricultural and environmental actors to use its objectives


24 Laura Kröger

to support their own interests, i.e. neither of the coalitions had to give up their policy beliefs. In con-

trast, the Nitrates Directive includes certain required measures, which the agricultural sector never

approved of, while the environmental sector even wanted to tighten them up. In order to achieve a

common understanding one of the coalitions would have had to change their policy beliefs, which they

did not. This shows that policy learning across the coalitions occurs only when there is a common

interest to find the solution.

It is also interesting to see how strongly the success of the policy process is influenced by which sector

is responsible for that process. This, of course, refers to the different policy beliefs, administrative tra-

ditions and working practices between different sectors. As the main policy core belief, the agricultural

sector emphasizes the importance of economically profitable production, whereas the environmental

sector is oriented towards environmental protection. Administrative traditions also differ; while the agri-

cultural sector has a strong centralized sectoral tradition, in environmental sector more decentralized,

co-operative and cross-sectoral forms of governance are typically used. These differences can also act as

constraints for mutual learning. By comparing the policy formulation of the Agri-Environmental Pro-

gramme and the Nitrates Directive, it becomes evident that particular arrangements are needed to facil-

itate learning and thus promote consensus in cross-sectoral policy processes. These arrangements

include e.g. working groups with broad stakeholder participation, acceptance of informal negotiations,

free flow of information and close co-operation with researchers and other experts. The Agri-Environ-

mental Programme is a good example of how long term co-operation, policy experience and the accu-

mulation of information, i.e. policy learning, can significantly affect the success of the policy process.

An interesting question is whether the policy process of the Nitrates Directive was an exception or

whether it is likely to be repeated in the implementation of the WFD. Since, in addition to the volun-

tary policy instruments, the WFD also includes regulatory instruments, there is a possibility that the

agricultural sector may resist implementation. If the requirements for cross-sectoral co-operation and

public participation are also taken into account, the possibility of resistance increases. In order to avoid

resistance and promote consensus, the regional environmental actors need to involve the agricultural

actors in the process at as early a stage as possible. Good examples of how to promote cross-sectoral co-

operation, build up common practices and thus facilitate mutual learning can be found in the forma-

tion process of the Agri-Environmental Programme. The success of the implementation will

be dependent on good collaboration between sectors and on a common understanding of roles and

responsibilities.

The WFD itself is also creating opportunities for overcoming the problems of co-operation by the legal

requirements for active involvement of all interested parties and for cross-sectoral co-ordination. How

far the WFD will prove successful in encouraging participatory forms of governance will depend on the

willingness of actors to take this approach. These topics should be examined further in the future.

References

Aakkula J. 1991. Yhteinen Valinta Maatalouspolitiikassa, MTTL, Tiedonantoja 164. Finland.

Bennett C, Howlett M. 1992. The lessons of learning: reconciling theories of policy learning and policy change. Policy Sciences25: 275–294.

Busenberg G. 2001. Learning in organisations and public policy. Journal of Public Policy 21(2): 173–189.

Council of European Communities (CEC). 1991. Directive 91/676/EEC Concerning the Protection of Waters Against Pollution

Caused by Nitrates from Agricultural Sources. Official Journal L375/1.

Council of European Communities (CEC). 1992. Council Regulation No 2078/92 on the Introduction and Maintenance

of Agricultural Production Methods Compatible with the Requirements of the Protection of the Environment and the

Management of the Countryside. Official Journal L215.



Council of European Communities (CEC). 1999. Council Regulation No 1257/99 on Support for Rural Development from

the European Agricultural Guidance and Guarantee Fund (EAGGF) and Amending and Repealing Certain Regulations.

Official Journal L160.

Council of European Communities (CEC). 2000. Directive 2000/60/EC Establishing a Framework for Community Action in

the Field of Water Policy. Official Journal L327/1.

Eising R. 2002. Policy learning in embedded negotiations: explaining EU electricity liberalization. International Organization56(1): 85–120.

Elliott C, Schlaepfer R. 2001. Understanding forest certification using the Advocacy Coalition Framework. Forest Policy and Economics 2: 257–266.

Etheredge L. 1981. Government learning. In The Handbook of Political Behaviour Vol. 2, Long S (ed.). Pergamon: New York;

73–161.

European Commission (EC). 1985. Perspective for the Common Agricultural Policy – the Green Paper of the Commission, Green

Europe news flash, Brussels.

European Commission (EC). 2002. Implementation of Council Directive 91/676/EEC Concerning the Protection of Waters AgainstPollution Caused by Nitrates from Agricultural Sources, synthesis from year 2000 member states reports. Luxembourg.

Fairley R, Smith C, van Gleen H, Hoedl-Adick M, van Thuyne G, De Roover D. 2002. Riding the new wave of European water

law: how member states are tackling the Water Framework Directive. European Environmental Law Review August/

September: 232–239.

Fiorino D. 2001. Environmental policy as learning: a new view of an old landscape. Public Administration Review 61(3): 322–334.

Flynn B, Kröger L. 2003. Can policy learning really improve implementation? Evidence from Irish responses to the Water

Framework Directive. The Journal of European Environmental Policy 13(3): 150–163.

Glasbergen P. 1996. Learning to manage the environment. In Democracy and the Environment: Problems and Prospects, Lafferty

W, Meadowcroft J (eds). Elgar: Cheltenham; 175–193.

Goodchild R. 1998. EU Policies for the reduction of nitrogen in water: the example of the Nitrates Directive. EnvironmentalPollution 102(51): 737–740.

Greenaway J, Smith S, Street J. 1991. Deciding Factors in British Politics: a Case Studies Approach. Routledge: London.

Haas E. 1990. When Knowledge is Power. Three Models of Change in International Organisations. University of California Press:

Berkley, CA.

Hall P. 1993. Policy paradigms, social learning, and the state. Comparative Politics April: 275–296.

Heclo H. 1974. Modern Social Politics in Britain and Sweden: From Relief to Income Maintenance. Yale University Press: New

Haven, CT.

Heinz, I. 2001. Voluntary and compulsory measures to implement more sustainable agriculture in water catchment areas. In

Agricultural Use of Groundwater – Towards Integration Between Agricultural Policy and Water Resources Management, Dosi C

(ed.). Kluwer: Dordrecht; 157–167.

Jenkins-Smith H, Sabatier P. 1994. Evaluating the Advocacy Coalition Framework. Journal of Public Policy 14: 175–203.

Jokinen P. 1995. Tuotannon Muutokset ja Ympäristöpolitiikka, Ympäristösosiologinen tutkimus suomalaisesta maatalouden

ympäristöpolitiikasta vuosina 1970–1994. Turun yliopisto. Julkaisuja C No: 116.

Jokinen P. 2000. Europeanisation and ecological modernisation: agri-environmental policy and practices in Finland. Environ-mental Politics 9(1): 138–167.

Jordan A, Greenway J. 1998. Green Challenges to Policy Networks: British Costal Water Policy, 1955–1995, conference proceedings,

Political Studies Association. http://www.psa.ac.uk/cps/1998/jordan.pdf [15 July 2004].

Kaika M, Page B. 2002. The Making of the EU Water Framework Directive: Shifting Choreographies of Governance and the Effec-tiveness of Environmental Lobbying, working paper of the School of Geography and the Environment, Oxford University.

Kaljonen, M. 2003. Ympäristöpolitiikkaa pellon laidalla. Tapaustutkimus suojavyöhykesuunnittelun käytännöistä. Alue &Ympäristö 2/2003.

Kallis G, Butler D. 2001. The EU water framework directive: measures and implications. Water Policy 3(2): 125–142.

Kettunen L. 1992. Suomen Maatalouspolitiikka, MTTL, Tiedonantoja 185. Finland.

Kiijärvi S. 2002. Paljon Melua Naturasta. MTK: n Rooli Natura 2000 – Konfliktissa, publications in sociology, University of

Jyväskylä, 69/2002. Finland.

Ministry of Agriculture and Forestry (MAF). 1994. Ehdotus Maatalouden Ympäristötukiohjelmaksi [Proposal for the Finnish Agri-Environmental Programme], Ministry of Agriculture and Forestry 19/1994, Helsinki.

Ministry of Agriculture and Forestry (MAF). 1999. Ehdotus Maatalouden Ympäristöohjelmaksi 2000–2006 [Proposal for FinnishAgri-Environmental Programme 2000–2006], Ministry of Agriculture and Forestry 13/1999, Helsinki.

Ministry of Agriculture and Forestry (MAF). 2004. Horisontaalisen Maaseudun Kehittämisohjelman Väliarviointi [Mid-Term Evaluation of the Horizontal Rural Development Programme], Ministry of Agriculture and Forestry 1/2004, Helsinki.


26 Laura Kröger

Ministry of the Environment (ME). 1992. Maaseudun Ympäristöohjelma [Rural Environmental Programme], Ministry of the

Environment, Helsinki.

Ministry of the Environment (ME). 1997. Nitraattidirektiivityöryhmän Mietintö [Memo of the Nitrate Directive Committee],

Ministry of the Environment, Helsinki.

Mintrom M, Vergari S. 1996. Advocacy coalitions, policy entrepreneurs and policy change. Policy Studies Journal 24: 420–434.

Moss T. 2004. The governance of land use in river basins: prospects for overcoming problems of institutional interplay with

the EU Water Framework Directive. Land Use Policy 21: 85–94.

Niemi-Iitalahti A, Vilkki B. 1995. Organisaatioiden Vuorovaikutus Ympäristöpolitiikan Toimeenpanossa, Vaasan yliopiston julka-

isuja. Tutkimuksia 195.

Parsons W. 1995. Public Policy. An Introduction to the Theory and Practice of Policy Analysis. Elgar: Cheltenham.

Peffley M, Hurwitz J. 1985. A hierarchical model of attitude constraint. American Journal of Political Science 29(4): 871–890.

Peterson J. 1995. Decision-making in the European Union: towards a framework of analysis. Journal of European Public Policy2(March): 69–93.

Rekolainen S, Kauppi L, Turtola E. 1992. Maatalous ja Vesien Tila, Luonnonvarainneuvosto, maa-ja metsätalousministeriö.

Luonnonvarainjulkaisuja 15. Helsinki.

Rose R. 1991. What is lesson-drawing? Journal of Public Policy 2(1): 3–33.

Sabatier P. 1986. Top-down and bottom-up approaches to implementation research: a critical analysis and suggested synthe-

sis. Journal of Public Policy 6(1): 21–48.

Sabatier P. 1998. The Advocacy Coalition Framework: revisions and relevance for Europe. Journal of European Public Policy5(1): 98–130.

Sabatier P, Jenkins-Smith H (eds). 1993. Policy Change and Learning. An Advocacy Coalition Approach. Westview: Boulder, CO.

Sacks P. 1980. State structure and the asymmetrical society. Comparative Politics 12.

Sanderson I. 2002. Evaluation, policy learning and evidence-based policy making. Public Administration 80(1): 1–22.

Thomas G. 1999. External shocks, conflict and learning as interactive sources of change in U.S. security policy. Journal of PublicPolicy 19(2): 209–231.

Valve H. 1995. Maatalouspolitiikan Suunnittelukäytännöt ja Ympäristövaikutusten Arvioinnin Kehittäminen, Vesi-ja ympäristöhal-

litus – sarja A 213.

Vihinen H. 1990. Suomalaisen Rakennemuutoksen Maatalouspolitiikka 1958–1987, Julkaisuja 8, Helsingin yliopisto, Maaseudun

tutkimus-ja koulutuskeskus, Mikkeli.

Weber N, Christophersen T. 2002. The influence of non-governmental organisations on the creation of Natura 2000 during

the European policy process. Forest Policy and Economics 4: 1–12.

Wilson C. 2000. Policy regimes and policy change. Journal of Public Policy 30(3): 247–274.

Yliskylä-Peuralahti, J. 2003. Biodiversity – a new spatial challenge for Finnish Agri-environmental policies? Journal of RuralStudies 19: 215–231.

Biography

Laura Kröger is a researcher in MIT Agrifood Research Finland. This document presents results

obtained within the EU project SSPE-CT-2003-502070 on Integrated tools to design and implement

Agro Environmental Schemes.


development of the finnish agri-environmental policy as a learning process

Documents