EUROPEAN COMMISSION Brussels, 22.6.2022 SWD(2022) 166 final COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Regulation (EC) No 1217/2009 as regards conversion of the Farm Accountancy Data Network into a Farm Sustainability Data Network {COM(2022) 296 final}



RESULTS OF THE TARGETED STAKEHOLDER CONSULTATION The consultation of stakeholders is an essential part of the consultation strategy set up for the process of conversion from the Farm Accountancy Data Network (FADN) into the Farm Sustainability Data Network (FSDN). The consultation was targeted on the main data providers and users of the FADN system. Member States, as main actors of the network, were strongly associated in the consultation. The consultation took several forms, among which were the publically available Roadmap and the written consultation via the EU Survey targeted to all identified stakeholders, as well as the FSDN stakeholders’ workshop and the FADN Committee together with its three thematic Working Groups (WGs). The present report summarizes the answers and feedbacks received. 1.Key outline of the consultation strategy, its objectives and specific activities The FSDN consultation strategy was established in spring 2021 and it aimed at gathering contributions to (1) inform about possible simplification paths and possible burden reduction, (2) explore additional data needed for assessing environmental and social practices and sustainability aspects at farm level, and (3) enhance the use of existing and explore new data collection tools. It also aimed at (4) identifying incentives to enhance farmers’ participation in the data network that would improve their farming practices. In the Strategy the following three main stakeholders groups were identified: (1) data providers (farmers), (2) data collectors (public authorities responsible for data collection, submission and for access to administrative data in EU Member States (e.g. Member State authorities, FADN Liaison offices, National Statistical Institutes) and (3) data users (e.g. policy-makers, farm advisors, academia, researchers, evaluators, consultancies). The following consultation activities took place in the process of preparing a proposal for the conversion into the FSDN: In February 2021, an initial workshop was organized in order to take stock of the Member States, third countries, the Commission as well as other stakeholders (e.g. farmers’ organizations, NGOs) knowledge and experience as regards the above-mentioned objectives. In the next step, the FSDN Roadmap was published on 4 June 2021, with a four-week feedback period, outlining the main objectives of the future FSDN proposal. At the end of the feedback-period, 33 feedbacks were received. A targeted written consultation in the form of an on-line questionnaire took place during summer 2021 using dedicated EU Survey. It was addressed to all three main identified stakeholders groups: (1) data providers, (2) data collectors and (3) data users. The questionnaire covered aspects related to both the simplification of the current FADN survey as well as to its conversion into the FSDN, by adding environmental and social variables at a farm level, as specified in the Strategy objectives. More than 300 replies to the EU Survey were received. In September 2021, another workshop was organized, with around 160 participants. The goal was to discuss the outcome of the previous consultation activities and to exchange on concrete simplification and modernization proposals. All stakeholder groups were represented; including farmers, who were represented by the umbrella organization COPA-COGECA. In the framework of the consultation activities, two FADN Committee meetings took place in April and October 2021, where the conversion into the FSDN was discussed with the FADN Committee members. In addition, the FADN Committee set up three dedicated Working Groups (WGs). WG1 focused on reinforcing and simplifying FADN to screen the current FADN variables and propose simplifications and methodological improvements. WG2 more generally worked on the process of conversion of FADN into FSDN, whereas WG3 tackled the FADN individual data request tool to deal with existing issues related to access to individual FADN/FSDN data. An additional, long-standing working group on the EU farm typology also contributed to this work. All above-mentioned Working Groups are set up under the umbrella of the FADN Committee and are composed of voluntary experts from the Member States, DG AGRI members and the other Commission services such as Eurostat. Finally, an FSDN Conference was due to take place at the beginning of 2022. However, this event has been postponed: 1)Because of Covid pandemic restrictions, as well as 2)due to the fact that the scope of the planned Conference (e.g. presentation of the results of the consultation activities, presentation of the initiative’s scope and harvest feedback from all stakeholders) was already fully addressed with the FSDN Stakeholders’ workshop (September 2021) and subsequent Working Groups meetings (meeting during the period of November 2021 until March 2022). It was decided that this event would be more valuable in autumn 2022. At that time, the Commission will have adopted the FSDN initiative proposal (June 2022) and discussions with the Council and the EP as regards the FSDN proposal will commence as from September 2022. In addition, partial results from the on-going IPM2-FSDN pilot project will be submitted and informal discussions with the Member States will start. With that timing, the above-mentioned event would suit better to harvest feedback from stakeholders as regards the secondary legislation ideas. 2.Overview of the respondents to the consultation activities There were 33 feedbacks received on the Roadmap. More than half of the feedback come from either business organization or academic institutes (27% and 24%, respectively). Feedback from business associations and NGOs constituted of 15% and 12% respectively, whereas EU citizens – 12%, Public authorities – 6% and trade union – 3%. As regards the coverage, the feedback came from 13 countries: Austria, Belgium, France, Germany, Ireland, Italy, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia and the United Kingdom (see Chart 1). Chart 1.

A total of 330 participants have answered the targeted written consultation via EU Survey. The main contributors of the survey have been advisors (81 participants) and farmers (64 participants). For a more detailed overview of the respondents to the EU Survey, see Chart 2.



Chart 2. In the different thematic FADN Working Groups, a total of 20 Member States were represented. Poland was overall most represented Member State with ten participants throughout the Working Groups. The Czech Republic and Slovakia were represented with nine participants each, followed by Germany and Spain with seven participants each. Belgium, France and Italy were represented with six participants each, and Austria, Bulgaria, and the Netherlands with three participants each. Finally, Denmark, Estonia, Finland, Greece, Hungary, Ireland, Latvia, Portugal and Slovenia each had two representatives or less. The 160 participants to the workshops were from Member States (e.g. FADN liaison offices), advisory services and research institutes. There were representatives from third countries (e.g. the United States and New Zealand), from the different European Commission services as well as from private companies. 3.Results of the stakeholders’ consultation by specific theme The consultation process covered various themes, with often more than one stakeholder group being involved in the process. In the following, the consultation process is compartmentalized in themes, with each theme relating to objectives of the FSDN initiative. 1)Theme One: Simplification (linked with reinforcing relevance of FADN) The consultation process covered possible simplification paths. First, the FADN variables were reviewed and assessed by the Commission. The following criteria were taken into account: the present and future usefulness of the variables and possible other means of collecting then (other than via the FADN farm return). Results of the work were presented and discussed, at first, with the Member States representatives (at the FADN Committee and the dedicated Working Group meetings). Secondly, with all stakeholders at the FSDN stakeholder workshop in September 2021. The discussion considered several possibilities that could lead to reinforcing and simplifying FADN, among which a possibility: -to stop collecting selected variables in the FADN farm return -to aggregate selected variables where details are not needed -to estimate some variables based on others data and/or sources -to split some aggregated variables where it adds value -to increase reporting of underreported variables -to improve quality of reported variables. The initial Commission review contained proposals and considerations of simplifications and improvements. Several discussions took place on these proposals. Several Member States’ representatives and policy makers shared their opinions and suggestions. First, it was considered that one of a possible simplification path could be enhanced use of administrative data that already exists or to make use of data from other sources. Secondly, the simplification process should be addressed where the simplification will take place: at farmers’ level, in Member States’ administration level or at EU level. A subsidiarity principle was recalled that for collecting a variable at EU level, EU relevance is to be assessed.

Moreover, at present for a given variable, a concrete data should be collected. However, in the future for some representatives mentioned, if data cannot be collected, an estimation may be consider as acceptable, but with its clear indication. Finally, the discussion showed that the majority of Member States acknowledge the importance of the simplification issues discussed and of the initiative as a whole. The outcomes of these discussions showed that there is a potential to reduce the data collection burden in certain areas of currently collected data (i.e. to stop collecting certain variables) as well as areas of possible modifications and/or simplifications can be envisaged (i.e. to use other means to collect certain variables). On top of that, the targeted written consultation via EU Survey covered a series of simplification path suggestions; the results are shown in table 1 below.



Table 1. Non-Farmers’ approach to ways suggested for simplifying and reducing administrative burden Overall, results from the targeted written consultations show that the non-farmers are rather positive as regards four proposed simplification paths, but with different rate. Most of favourable opinions are to ease the farmers obligations in order not to ask farmers twice (around 90% of opinions of non-farmers). At the same time, the idea to share farm level individual data with other public bodies for statistical purposes is less popular (around 70% of opinions of non-farmers). 2)Theme Two: Reduce administrative burden (linked to the interoperability and use of new technologies) In line with the simplification paths, the consultation process also identified ways to reduce administrative burden. Interlinking FSDN with other existing (or possible future to be established) data management tools, such as the Integrated Administration and Control Systems, national statistics sources as well as making use of new technologies (e.g.: possibility of use of the geospatial data generated through the European Space program) for data collection. Through the workshops, the Commission learned from several Member States about examples of the already collected environmental and social variables currently at the Member State level to avoid duplication of collections. It has been found that there is a need to use external data sources to limit administrative burden and to ensure data quality. What’s more, the suggestion to limit the administrative burden has also been linked to farmers’ willingness to cooperate. The targeted written consultation via EU Survey has shown that farmer’s opinion on the suggestion to reduce the administrative burden is strongly positive. Around 84% of respondents support the suggestion that they “[…] should not be requested to provide data that are already available in the administration”. Farmers’ support for the suggestion that “the collected individual data should be shared with other public bodies for statistical purposes” shows that vast majority of farmers (around 58%) agree completely or tending to agree with that statement. It is notable however, that 36% of respondents tend to disagree or completely disagree on this point. About 58% of respondents completely agree or tend to agree to “enhance the use of remote data collection tools, such as remote sensing”; and 67% of respondents agree or tend to agree to “interlink different existing sources of information (interlinking for example satellite satellites, administrative and data provided by farmers”. The responses are shown in detail in Table 2 below. Table 2. Farmers’ approach to ways suggested for simplifying and reducing administrative burden When comparing results of opinions provided by farmers vs. non-farmers as regards possible simplification paths (referring to both tables 1 and 2), the tendency is very similar in both groups. Whereas, the non-farmers opinions look slightly more positive. The same question (farmers are not asked to provide data that are already available in the administration) has been answered by policy makers (at EU level, national or regional). About 58% of policy makers stated that they completely agree with the suggestion, 26% tend to agree and 16% tend to disagree. When asked about the relevance of using specific surveys (i.e. dedicated modules, every 3 years and not annually) on certain topics in the FSDN, in the light of reducing the number of yearly collected data, 37% of policy makers responded positively (i.e. it is relevant), 16% of policy makers responded negatively (i.e. it is not relevant). However, the most striking was that almost half of respondents (47% of policy makers) gave no opinion. The suggestion to reduce administrative burden by not collecting variables yearly, but instead e.g. every three years has been discussed with Member States. Concerns have been raised regarding the feasibility of this simplification and burden reduction path, as a less frequent data collection might lead to increased costs and impair administrative knowledge. 3)Theme Three: financial costs and the budget aspects linked to FSDN

The consultation explored possible ways to limit financial costs of the additional data collections by having a centrally placed FSDN system and its network covering all three dimensions (economic, social and environmental) that describe the farms context. It further tackled the question of sharing data and the use of other funds support to generate synergies. There have been several studies carried out to assess costs of FADN as well as for its possible extension. A study on the costs of extending the FADN to FSDN has found that collecting the sustainability data from all farms included in FADN would increase the cost by about 40%. The study showed great differences between countries, depending on the current costs of data collection and the expected additional work to include sustainability indicators. Certain countries are already collecting some variables foreseen in the FSDN, whereas others are not, and may thus face higher initial costs. The total expenditure of data collection is thus not directly comparable between Member States. Ultimately, the estimated changes in costs show a wide range, from countries such as Ireland (+10%) and the Netherlands (+11%) to France (+124%) and Malta (+225%). Through the targeted written consultation via EU survey, farmers were asked whether the collected individual data should be shared with other public bodies for statistical purposes. This would allow to interlink databases and to use additional tools to collect data. The analysis of the answers shows that 20% of respondents completely agree, and 38% tend to agree. 20% of respondents tend to disagree, 15% completely disagree, and 6% have no opinion on this. Finally, the specific Working Group discussed the costs and budget aspects related to the current FADN as well as possible upcoming conversion into the FSDN. Firstly, it was highlighted that the EU budget already contributes to the FADN. The Commission covers the central IT system and provides Member States with the annual standard fee (currently at the level of up to 180 EUR per farm return). The fee was slightly increasing over last 12 years. However, its was noted that the increase did not fully cover the inflation rate over this period. Secondly, some Member States provided their cost estimates as regards their FADN data collection costs. It appeared that on average the EU contribution covered up to 30% of the Member States’ data collection costs. The discussion showed that in case of the conversion into the FSDN (e.g. starting collecting new types of data related to environmental and social farms dimensions), all types of costs (e.g. human resources, IT adjustments/developments, new data collection methods) would be affected. It was noticed that for some Member States, it would be actually an opportunity to adjust a long-waited change of the current FADN system. The exchanges showed that possible increase of the annual EU standard fee as well as a set-up financial aid for conversion into the FSDN system would be significant help for Member States and ultimately also for farmers. The latter would benefit from the FSDN via better interlinks, enhanced data collection, ‘collect data once, reuse multiple times’ principle (e.g. better re-use of administrative data) and use of new technologies for collecting data. 4)Theme Four: environmental and social sustainability topics The consultation process identified possible topics to address environmental and social sustainability in FSDN, while also reassessing and reviewing economic variables. Generally speaking, it can be said that there is an agreement between the different stakeholders to add new variables to the FADN so as to assess not only the economic, but also environmental and social practices. FADN has been identified as an efficient tool to collect additional data at farm level. However, it has also been mentioned that farm level data on environmental and social practices should remain realistic with respect to the way they are accountable and collectable as well as with respect to its number, especially at the initial stage of the conversion process. Overall, FADN has been considered as an efficient and apt tool to collect additional variables at farm level. With regards to the number of new variables to be added, a poll among the stakeholders taking part in the workshops showed that about 36% of participants were in favor of adding more than nine variables. However, much more participants (around 74%) were for slightly modest approach where less new variables are added (‘adding more than four variables’). With regards to the willingness of data providers (i.e. farmers) to deliver additional data, the analysis of the results of the targeted written consultation via EU survey shows that around 70% of the farmers responding to the survey are willing to provide data on soil management (such as tillage, winter soil cover, carbon content, crop rotation etc.). About 53% of the respondents are willing to provide data on biodiversity, water management and renewable energy, and 52% are willing to provide data on animal welfare. A total of 31% of respondents however are not willing to provide data on circular and bio economy, for example adding value to bio-waste, by-products and increasing the circularity of resource flow. Results are detailed in Table 3.



Table 3. Farmer’s willingness to provide data for possible environmental sustainability topics On the usefulness of collecting additional variables, it was found that 72% of the farmers who participated in the survey already collect some additional data. When asked about the kind of additional data they collect, it was found that 63% of the respondents keep record of quantity data on pesticide use, and 61% keep record of quantity data on fertilizer use. According to the survey results, 58% of the respondents keep record of the quantity of pesticides and fertilizers they use at the same time. Additionally, 38% of farmer respondents keep record of the way or the type of treatment, or on the timing of soil management practices (see Table 4).



Table 4. Environmental data already recorded by farmers Data Group Quantity Type of product/practices Frequency Way/type of treatment Timing: preventive or treatment Other Pesticide use 63% 56% 45% 48% 45% 9% Fertilizer Use 61% 50% 41% 34% 28% 9% Antimicrobial use 33% 19% 16% 17% 16% 34% Nutrient balance 42% 22% 23% 17% 14% 28% Soil management practices (tillage, winter soil cover, carbon content, crop rotation...) 36% 38% 27% 27% 22% 19%



The analysis of the survey results shows that farmers do not keep record of single data. They appear to be recording at least two product groups’ quantity data: 31% of the respondents keep record of all three groups of additional data (quantity of pesticide, fertilizer and antimicrobial use) and 28% of them keep record of the quantity of pesticide and fertilizer use. Another important intersection between different groups was the respective quantities of pesticide and fertilizer and the type of treatment of soil management. Similarly, 30% of the respondents keep track of all three of these simultaneously.





On environmental sustainability variables, the consultation showed that different stakeholders have different opinions. The lowest approval rate throughout all possible topics was recorded on the suggestion to add variables on ‘Circular and bio economy’ (only 46% of non-farmers respondents were in favour of adding this topic. The highest approval rate was received by the suggestion to add variables with respect to ‘soil management’ topic, with 89% respondents in favour (see Table 5, showing the respondents opinions and needs, per possible environmental topic, all non-farmers stakeholder groups mixed). Table 5: Non-farmers stakeholders needs to collect data on environmental sustainability topics



Policy makers were largely in favour of adding environmental sustainability topics. The highest approval rate was reached with the suggestion to add variables on ‘Renewable energy’ (90%), closely followed by ‘Biodiversity’ (89%), ‘Water management’ (89%), and ‘Soil management’ (89%), which all appear to be equally relevant for the concerned stakeholder group. Less approval, and thus higher disapproval rates were recorded with the suggestion to add variables on ‘Circular and bio economy’ and on ‘Food loss and waste management’ (see Chart 4). Chart 4.



Advisors answered somewhat similar, however, to them it was the suggestion to add variables on ‘Soil management’ that appeared to be the most important (88% approval). Adding variables on ‘Water management’ (81%), ‘Renewable energy’ (75%) and ‘Biodiversity’ (71%) was also deemed important. Adding variables on ‘Food loss and waste management’ on the other side received the highest disapproval rate (27%). See Chart 5. Chart 5.



Academia, including researchers and evaluators, responded in favour of adding variables on ‘Soil management’ (94%) and ‘Water management’ (92%). They were also largely in favour of adding variables on ‘Biodiversity’ (87%), ‘Climate change mitigation and adaptation’ (79%) and ‘Renewable energy’ (79%). Again, it can be seen that the suggestions to add variables on ‘Food loss and waste management’ and ‘Circular and bio economy’ received considerably less approval (53% and 61% respectively). See Chart 6. Chart 6.



FADN members, including data collectors, statistician, data managers, and accountants, again responded somewhat similar to other stakeholder groups, with most members in favour of adding variables on ‘Soil management’ (82%). The suggestions to add variables on ‘Circular and bio economy’ and ‘Food loss and waste treatment’ again received less approval, with only 30% and 46% in favour, respectively. What is striking, is that over half of respondents indicated to not have an opinion ‘Circular and bio economy’ (51%), see Chart 7. Chart 7.





On social sustainability, it has been found that non-farmers stakeholders are mostly in favour of adding variables on the ‘Composition of the workforce’ (78% of respondents in favour), such as age, gender, skills or origin. On the other hand, least stakeholders are in favour of adding variables on ‘Health and well-being of the farm household’ (48% of respondents in favour). See Table 6 below. Table 6: Non-farmers stakeholders needs to collect data on social sustainability topics



Policy makers, overall tend to be largely in favour of adding variables on social sustainability. The strongest approval was recorded with the suggestions to add variables on ‘Access to essential services for farmers or workers (such as hospitals, schools, public transports and internet)’, ‘Attractiveness of the farming sector for newcomers and young generations’ and ‘Access to training and training participation’ (all three suggestions scoring 84% approval rate). Equally important appeared the suggestion to add variables on the ‘Composition of workforce’ (79% approval rate). Policy makers were less in favour (or did not give an opinion) on the ‘Health and well-being of farmers’ (58% approval, 26% have no opinion on this, see Chart 8). Chart 8.



Advisors on the other hand, when asked the same questions, responded largely in favour of adding variables on the ‘Composition of workforce’ with 73% in favour, and only 13% not in favour. Almost as many were in favour of adding variables on ‘Access to training and training participation of farmers or workers’, with 67% of respondents endorsing the idea. See Chart 9. Chart 9.



Academia’s answered somewhat similarly, with the suggestion to add variables on the ‘Composition of the workforce’ being deemed very important (85% approval rate). Adding variables on the ‘Access to essential services for farmers and workers’ and on ‘Health and well-being of the farm household’ on the other hand was deemed less important, with 43 and 42% approval rates respectively. See Chart 10.

Chart 10.





FADN members similarly to other stakeholder groups deemed the suggestion to add variables on the ‘Composition of the workforce’ to be most important (73%). Once again, the suggestion to add variables on the ‘Health and well-being of the farm household’ was deemed least important (42% approval rate, 36% disapproval rate). See Chart 11. Chart 11. 5)Theme Five: incentives for farmers to participate The consultation process explored possible tools and incentives that could support farmers’ participation to FSDN. When asked about the relevance of a number of possible incentives for farmers to provide the data for FSDN, it appeared that receiving financial compensation and being granted selection priority for CAP supports under the rural development measures received the highest approval rates. Indeed, 64% of respondents rated financial compensation “very relevant”, or “somehow relevant”, and 61% of respondents rated the possibility of being granted selection priority for CAP supports under the rural development measures “very relevant”, or “somehow relevant”. The possibility of receiving tailor-made advice based on the data provided was equally approved, with 60% of respondents rating it “very relevant”, or “somehow relevant”. The least relevant appeared to be the suggestion of better communication of the purpose of the data collection, with only 39% rating it “very relevant”, or “somehow relevant”, and 23% rating it “somehow irrelevant” or “fully irrelevant”. The full analysis of the responses is shown in Table 7.



Table 7. Ways to increase participation of farmers to the FADN/FSDN. 6)Theme Six: Tools to improve farming practices Finally, the consultation process identified tools to improve farming practices by using FSDN data, and by facilitating the use of farm-level data in farm advice, benchmarking, training, research and innovation, with the aim of providing tailored advisory services. The prospect of interlinking different existing sources of information (for example satellites, administrative and data provided by farmers) is rather well supported by farmers, with 67% of respondents completely agreeing or tending to agree, opposed to 22% of respondents who tend to disagree or completely disagree.



4.Summary of written contributions by respondents Respondents had opportunity to accompany their feedback to the Roadmap as well as replies to the targeted written consultation via EU survey by submitting their specific position papers. There, the respondents’ provided suggestions (including indicators and data collection schemes) and reservations for the new FSDN. It is observed that respondents’ perceptions on FADN/FSDN are different: some respondents perceive FADN/FSDN as a monitoring tool while some perceive as a tool to collect all data available at farm level. Perception of the respondents directly influenced the feedbacks they provided. Main elements in the feedbacks from the position papers are summarised below: ·A need for an impact assessment for Farm to Fork Strategy, and opposed to use indicators in parallel with Farm to Fork strategy;