Guidelines for policy audit / D6.1

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Guidelines for policy audit/D6.1 2 D6.1 - “Guidelines policy audit” Technical references Project Acronym SMART ERA Project Title SMART community-led transition for Europe’s Rural Areas Project Coordinator Fondazione Bruno Kessler (FBK) Project Duration January 2024 – December 2027 (48 months) Deliverable Title D6.1 - “Guidelines for policy audit” Deliverable Type R Dissemination level* Public Work Package WP 6 - “Policy Analysis and Recommendations” Lead beneficiary European Association for Innovation in Local Development (AEIDL) Author(s) Serafin Pazos-Vidal (AEIDL), Carla Lostrangio (AEIDL) Reviewers Blanca Casares (AEIDL), Janne Sinerma (AEIDL), Andrea Mora (POLI), Alessia Torre (FBK) Due date of deliverable 28 June 2024 Actual submission date 28 June 2024 * PU – Public, fully open, e.g. web (Deliverables flagged as public will be automatically published in CORDIS project’s page) SEN – Sensitive, limited under the conditions of the Grant Agreement Classified R-UE/EU-R – EU RESTRICTED under the Commission Decision No2015/444 Classified C-UE/EU-C – EU CONFIDENTIAL under the Commission Decision No2015/444 Classified S-UE/EU-S – EU SECRET under the Commission Decision No2015/444 v Date Contributor(s) Comment 0.1 01/06/2024 Serafin Pazos-Vidal (AEIDL), Carla Lostrangio (AEIDL) First draft prepared for reviewers 0.2 21/06/2024 Blanca Casares, (AEIDL), Janne Sinerma (AEIDL), Andrea Mora (POLI) Review of the document 0.3 25/06/2024 Serafin Pazos-Vidal (AEIDL), Carla Lostrangio (AEIDL) Revised text by authors integrating feedback and suggestions 1.0 28/06/2024 Alessia Torre (FBK) Final editing and submission 3 D6.1 - “Guidelines policy audit” Table of contents Acronyms........................................................................................5 Executive Summary ........................................................................6 1. Context and understanding ........................................................7 1.1. Aim of the deliverable ......................................................................................... 7 1.2. Policy Background .............................................................................................. 8 2. Steps for policy audit ................................................................ 14 2.1. General considerations: steps and roles ........................................................ 14 2.2. Step 1: Identifying the issue ............................................................................. 14 2.3. Step 2: Identifying the actors ........................................................................... 17 2.3.1. Types of actors ............................................................................................. 18 2.3.2. Identifying authorities and delivery agents.................................................... 19 2.4. Step 3: identifying positions, opportunities and barriers .............................. 20 2.4.1. Identifying actors’ positions .......................................................................... 21 2.4.2. Stakeholder matrix ....................................................................................... 22 2.5. Step 4 Identifying solutions .............................................................................. 24 2.5.1. Options for policy change ............................................................................. 24 2.5.2. Scenario Building ......................................................................................... 24 2.5.3. Final Report .................................................................................................. 26 3. Conclusions ............................................................................. 29 4. References .............................................................................. 28 5. Annex 1 – Tools and case studies ............................................ 30 List of tables Table 1 OECD Rural Policy 3.0 ....................................................................................................... 9 Table 2 Areas of EU and shared competence ............................................................................... 10 Table 3 EU policy analysis frameworks for rural areas .................................................................. 12 Table 4: Template of Policy analysis factors…………………………………………………………….16 Table 5 Actor identification criteria ................................................................................................ 18 Table 6 Template for Actor identification ....................................................................................... 20 Table 7 Example of Actor identification: Stakeholder positions in EU Structural Funds 2014-2020 21 Table 8 Template for detailed stakeholder matrix .......................................................................... 23 Table 9 Policy Audit’s Checklist for SMART ERA Pilot Regions .................................................... 27 4 D6.1 - “Guidelines policy audit” List of figures Figure 1 A Schematic hierarchy of EU regulations and directives (Vendt et al., 2022) ...... 11 Figure 2 An actor-centric conceptual framework for the study of multilevel governance ................ 12 Figure 3 The STEEPED Wheel Scheme in all of its components (Van Woensel, 2021) ................ 16 Figure 4 Example diagram with broad stakeholder relationships ................................................... 22 Figure 5 The bias wheel, a tool for becoming aware of biases in policy analysts' tasks ................. 23 Figure 6 The Futures Wheel. Source: EPRS (2021) adapted from Glenn (2009). ......................... 26 5 D6.1 - “Guidelines policy audit” Acronyms Acronym Description AEIDL European Association for Innovation in Local Development CoR Committee of the Regions DG Directorate General ENRD European Network for Rural Development EPRS European Parliament Research Service ESIF European Structural and Investment Funds ESPON European Observation Network for Territorial Development and Cohesion ISO International Standards Organisation ODA Overseas Development Administration OECD Organisation for Economic Cooperation and Development RegHub Regional Hubs for evaluation of EU public policies STEEPED Social, Technological, Economic, Environmental, and Political EU European Union 6 D6.1 - “Guidelines policy audit” Executive Summary Deliverable D6.1 “Guidelines for policy audit” will allow pilot responsible partners to analyse the key policy frameworks and the initiatives, strategies, and instruments in their national and regional contexts (with a particular emphasis on EU-supported policies) that are enablers and/or disablers of community-led innovation in rural areas. The guidelines will also support project partners and other multi-actor participants in identifying key policy concepts and options that are affected by ongoing policy developments. These Guidelines are aimed at providing a very simple and user-friendly 4-step way for specific territories such as the SMART ERA Pilots, can identify: ● The issues that concern them ● The actors that are involved in it ● The barriers that are in place ● The possible solutions To do so, a 4-step process is outlined: 1. Identify the issue affecting the area (what, who, why, where, when, how) 2. Identify the actors (Stakeholder mapping) 3. Identify positions, opportunities and barriers (stakeholder positioning) 4. Identify solutions for policy change (Scenario building) For the governance of this process the Pilot Orchestrator is key as it will be the one in charge of driving the policy analysis process described above. Equally the Community Activator has a crucial role in both organising the brainstorming sessions with internal and external actors and stakeholder identification. This methodology is based on the state of the art of EU guidelines for Better Regulation and the emerging methodologies on rural proofing. This will allow both to carry out policy analysis in different Member States and more fundamentally to reach policy outputs that can be more easily adopted by the EU institutions (and Member States implementing EU legislation) as the basis for policy change. Lastly, in addition to the guidelines and templates provided specifically to carry out this kind of policy audit, a further set of tools and examples is provided in Annex 1. 7 D6.1 - “Guidelines policy audit” 1. Context and understanding 1.1. Aim of the Deliverable SMART ERA will develop Smart Innovation Packages (SIPs) that will address the vulnerabilities and exploit the potentials of rural areas where they are applied. These Smart Innovation Packages are designed to be replicable in other rural regions and serve as the basis for a Europe-wide rural innovation strategy. These packages will integrate a long-term impact analysis and sustainability strategy already in place at the end of the project in order to spread out the approach and solutions beyond the project duration and the regions involved. The starting point are the six SMART ERA pilots situated in different countries (Italy, Spain, Finland, Bosnia and Herzegovina, Bulgaria and the cross-border region between Slovenia, Italy and Croatia) and the socio-economic and environmental challenges they face as rural areas. These rural areas are characterised by different geographic contexts and socioeconomic conditions. For the purpose of this project, rural areas are broadly defined following the Eurostat definition as areas “where more than 50 % of its population lives in rural grid cells”. The SIPs will focus on challenges identified comprise key hurdles for the selected rural areas requiring an urgent intervention. For each pilot, a Pilot Orchestrator (in the case of SMART ERA these partners are: FBK, UL, UOULU, ANYSOL, SFTH, DPA) and Community Activator (PAT, ROTUNDA, C.OULU, +CULTURA, TORS, SEVLIEVO) were selected. The Pilot Orchestrator is a technical partner responsible for deploying its SIP in its own territory, orchestrating pilot activities, and monitoring their execution. The Community Activator is a local Public Authority or Non-Governmental Organization (NGO) that has strong ties with the local residents and stakeholders and a demonstrated experience in engaging them in innovative projects and initiatives. All these couples have long-standing relations and many successful collaborations. In the frame of the piloting, the SIPs will be co-defined, implemented and tested involving local actors. In SMART ERA, WP6 “Policy analysis and recommendations” aims to support the building of modern community-led innovation policies in rural areas that enhance the “enabling environment” and promote “rural proofing” within the EU multi-level public policies. In particular, the key objectives are: i) to develop an approach and detailed methodology to assess policy and governance frameworks supporting community led innovation in rural areas. ii) to analyse and map the evolution and influence of public policy frameworks supporting community-led innovation across pilot areas. 8 D6.1 - “Guidelines policy audit” iii) to co-develop relevant recommendations, together with an interactive tool for the modernisation of multi-level policy interventions. Within this wider context, this document D6.1 “Guidelines for policy audit” has been developed by AEIDL to enable pilot responsible partners to analyse the key policy frameworks and the initiatives, strategies, and instruments in their national and regional contexts (with a particular emphasis on EU-supported policies) that are enablers and/or disablers of community-led innovation in rural areas. In addition to project partners, these guidelines will also help other stakeholders outside the project in identifying key policy concepts and options that are affected by ongoing policy developments, as it will be a public and Open Access document. 1.2. Policy Background In order to introduce innovative solutions (practices, technologies, policies, services) in a specific local, and indeed rural context it is necessary to understand the policies already in place, what are the actors (i.e. the stakeholders) that are affected (positive or negative benefit), are interested by it and most importantly those that shape, promote, or block these policies. It should be noted that Policies are widely understood as the sum of regulations, decisions, and funding schemes that have been officially agreed to on a particular issue or group of connected issues. The paradigms behind rural development policies have become increasingly sophisticated over the last couple of decades. As a case in point of this development, Table 1 describes the Rural Policy 3.0 paradigm from the OECD, which has subsequently permeated the EU Long-Term Vision for Rural Areas (European Commission, 2022) and indeed the Territorial Cohesion policy thinking of the EU (European Commission, 2024). This paradigm argues that a key objective of rural policy should be to increase rural competitiveness and productivity in order to enhance the social, economic, and environmental well-being of rural areas. It is more complex and multidimensional than previous approaches to rural policies that were top down or bottom up, mostly reactive and silo-driven. In the present rural approach, policies should focus on enhancing competitive advantages of rural communities. They should also draw on integrated investments and the delivery of basic services (public and privately provided) that are adapted to the needs of diverse types of rural areas. The Rural Policy 3.0 (and the Long-Term Vision for Rural Areas in the EU context) describes a partnership-driven approach that builds capacity at the local level to encourage participation and bottom-up development. 9 D6.1 - “Guidelines policy audit” Table 1 OECD Rural Policy 3.0 Old Paradigm New Rural Paradigm (2006) Rural Policy 3.0 –Implementing the New Rural Paradigm (2016) Objectives Equalisation Competitiveness Well-being considering multiple dimensions of: i) the economy, ii) society and iii) the environment Policy focus Support for a single dominant resource sector Support for multiple sectors based on their competitiveness Low-density economies differentiated by type of rural area Tools Subsidies for firms Investments in qualified firms and communities Integrated rural development approach – spectrum of support to public sector, firms and third sector Key actors & stakeholder s Farm organisations and national governments All levels of government and all relevant departments plus local stakeholders Involvement of: i) public sector – multi-level governance, ii) private sector – for-profit firms and social enterprise, and iii) third sector – nongovernmental organisations and civil society Policy approach Uniformly applied topdown policy Bottom-up policy, local strategies Integrated approach with multiple policy domains Rural definition Not urban Rural as a variety of distinct types of place Three types of rural: i) within a functional urban area ii) close to a functional urban area, and iii) far from a functional urban area Source: OECD (2016) While this approach is more sophisticated than previous rural policy paradigms it conversely makes policy analysis more complex to carry out, as several levels of governance are concerned. These Guidelines focus primarily on EU policy analysis, both because this is mean to support the six SMART ERA pilots across various Member States, but also because the EU is at the source of most regulatory frameworks (EU environmental law, organisation of the food value chain) and financial incentives (i.e. the Common Agricultural Policy and the EU Cohesion Policy) impacting rural areas. Though this deliverable focuses on providing Guidelines for Policy Analysis for the SMART ERA Pilots, it can also be used for policy analysis of EU Macro-regional strategies, as the methodology used is a distillation of existing EU guidelines for better regulation and analysis of territorial impacts. That said, the impact of the EU is more nuanced in some policy areas than others. As it can be seen in Table 2, in most policy areas the EU shares competence with Member States or supports them. Within only a very small set of very high-level policy areas the EU has exclusive competence with all decisions taken in “Brussels”. For most cases, the EU might 16 D6.1 - “Guidelines policy audit” Figure 3 The STEEPED Wheel Scheme in all of its components (Van Woensel, 2021) This characterisation can be done in an organic, iterative way with further brainstorming sessions initially with the SMART ERA Pilot members (Step 1) and then involving the wider actors that have been identified (Step 2). As a result of these discussions, the policy audit lead (in this case the SMART ERA Orchestrator) will be able to put together a table characterising in as much detail as possible the various factors that have been identified, as in Table 4 Template of Policy analysis Factors template below. Table 4 Template of Policy analysis Factors Factor Subfactor (choose from STEEPED diagram Fig 3) Description Likely Beneficiary (positive or negative) Perceived source of authority (regulator, overseer, fund provider) Political Legal Environmental Economic Technological Societal Ethical 17 D6.1 - “Guidelines policy audit” Concurrently with the factor identification the Pilot Orchestrator needs to have a better understanding of the territorial impact, essentially addressing the following questions drawn from the EU Territorial Impact Assessment Better Regulation Tool #34 (European Commission, 2023): • Does the issue being considered affect economic activity, environment, or people living in cities, rural, cross-border, insular, mountainous, or sparsely populated areas and in the EU outermost regions to a significantly different extent than elsewhere in the EU? • Is it concentrated in certain areas (e.g. rural), regions, or Member States? • Does it affect certain areas (e.g. rural, mountain, island, border, peripheral), specific regions or Member States in a disproportionate manner? • Does it address regions differently according to their own specific characteristics and thus lead to uneven territorial development? • Does it distort the principle of territorial cohesion (i.e. increase disparities in economic development, social well wellbeing between different EU territories)? If the answer to any of these questions is positive, the Territorial Impact Necessity Check will help assess the need of a more in-depth analysis of the territorial impacts. To do so there is the possibility to use a Territorial Impact Assessment Quick Check is an interactive tool ESPON assessing ex ante the territorial impact of legislations, policies and directives. It allows the user to make a "quick and dirty" ex-ante analysis of the potential impact of EU legislation, policies, and directives on the development of regions, which might be unanticipated and undesirable (ESPON 2020). The tool combines knowledge gathered by those conducting the policy analysis (ideally a workshop) in a workshop with a set of statistical data describing the characteristics of regions. It is a free tool that can be used interactively, both at step 1 (identification of the problem) as well as step 2 (once all possible actors have been identified in detail) or step 3 (after gathering views from these actors as a result of a workshop or a survey). Through a series of 5 steps this tool will help the Pilot Orchestrator decides whether a Territorial Impact Assessment is useful for any given policy. Complemented with the detailed evidence gathered in the wider policy analysis process (what is the problems, who are the actors concerned, what are the lock ins and barriers, what are the possible solutions) it can help make a case for a policy change at the end of a policy analysis process, as a One Size Fits all policy does not work for all territories. 2.3. Step 2: Identifying the actors Once Step 1 an initial set of actors potentially concerned by the issue being subject to policy analysis a more in-depth assessment of those not directly involved in the SMART ERA Pilot is needed. 18 D6.1 - “Guidelines policy audit” 2.3.1. Types of actors Building upon the findings of the brainstorming session and the resulting characterization in Step 1, the Pilot Orchestrator needs to build a more detailed stakeholder mapping covering all actors, which are directly, indirectly or potentially concerned with the policy issue being examined. To do so, a reliable way is to use the so-called Six Tests for Stakeholder Identification contained in Tool #51 of the EU Better Regulation Guidelines (European Commission, 2023, p. 766) Table 5 Actor identification criteria Type of Actor Criteria Direct Beneficiary Who is directly impacted? • Will their daily/weekly lives will change because of this issue (policy decision/legislation/funding, or absence of it)? • Can they easily avoid being affected by this issue? • Will they have to change their behaviour as a result of this issue? Indirect beneficiary Who is indirectly impacted? • Will their daily lives change because other actors have been directly affected by this issue? • Will they gain or lose because of changes resulting from this issue happening/not happening? Potential beneficiary Who is potentially impacted? • In particular circumstances, who will have a different experience as a result of this issue happening/not happening? • Are there individuals or groups who will have to adjust their behaviour if specific conditions apply? Source of authority Who is the regulator making the decision (or not taking it)? (eg making a rule, awarding a decision/not doing it) • Is there any other authority involved in making the decision? How? Delivery actors Are there vital individuals or groups in the delivery chain? Who is responsible for enforcing it? (if different from regulator) • Whose help is actually needed to make a decision work? • Who will have the ability to obstruct implementation unless cooperating? Knowledge actors Who thinks they know about the subject? • Who understands the likely impact of this decision on other stakeholders (if different from regulator)? • Who has studied the subject and published views on it? • Who has detailed know-how and expertise that those implementing the decision should also understand? • Are there individuals or groups that will be perceived as knowledgeable on the subject? Wider Stakeholders Who will show an interest in the subject? • Are there organisations, authorities, bodies, or individuals who think they have an interest? • Has anyone been campaigning about the issue? • Is there anyone publishing or broadcasting views on this subject? 19 D6.1 - “Guidelines policy audit” For instance, in a hypothetical example of extension of rural broadband, a fairly typical classifications of actors involved this issue could be as follows: ● Direct beneficiaries: local residents benefitting from rural broadband ● Indirect beneficiaries: local businesses, public services ● Potential beneficiaries: new investors making investment decision based on new broadband infrastructure in place ● Source of authority: EU regulator enacting legislation and rules on Broadband Expansion and technical standards, EU legislation and funds on subsidies for broadband expansion, national implementing legislation (parliament) and national competition authority (award decision on broadband expansion) and national government (co-financing EU funding on broadband expansion) ● Delivery Actor: regional government (delivery actor implementing national and EU decisions, or blocking it), other economic actors in favour -or againstbroadband exemptions to safeguard their own business interests. ● Knowledge actors: could be the local university rural research centre that provides knowledge to choose the most appropriate form of broadband expansion and identity issues. ● Wider stakeholders: for instance, members of the local community concern about the loss of local character as a result of technological change. NOTE: Step 1 and Step 2 can be done in a more complex matrix. This is particularly relevant when carrying out rural proofing as there is a complex set of factors having a knock-on effect in territorial development, thus making individual, policy specific and silo approaches to policy analysis unsuitable for impact assessment in a given territory or local case study 2.3.2. Identifying authorities and delivery agents In policy analysis a particularly important actor that needs to be identified as much and as at an earlier stage are those that we have termed source of authority (i.e. most commonly the public authority or authorities that set out legislation, implementing rules, interpretative, or statutory guidelines or technical standards), often in conjunction with delivery actors in charge of enforcement (e.g. responsible to award decisions or subsidies), which may be a different authority from that setting out the rules. In some cases, delivery actors need not be a public authority but another organisation or entity (voluntary, chartered, social economy, etc.) to which public authority has entrusted the enforcement of a public policy, setting up guidelines or technical standards (e.g. ISO organisations). As mentioned in the introduction and in the above example on rural broadband it is particularly challenging to disentangle sources of authority as policies, particularly those 20 D6.1 - “Guidelines policy audit” emanating from the EU is very much fragmented and indeed shared between various levels of government (Multilevel Governance). Example: Identifying Authority and Delivery actors in fiscal benefits for depopulating rural areas In 2022 the EU has agreed to set out new Regional Aid Guidelines that give special treatment (for instance fiscal incentives) to areas affecting to 10% depopulation loss over the previous decade, this had to be set out by the corresponding Member State in their Regional Aid Map (and agreed by the Commission) whereas designing the specific schemes might fall to a national or regional authority and it is ultimately the local authority that administers the scheme. From the point of view of the local actor as direct, indirect or potential beneficiary it is not immediately clear who is responsible for what and if there is a lock in that prevent that policy from being applied where it can be in the regulatory and decision-making chain. From an actor-centred perspective the most practical way is to follow up the decision chain, as the local authority to award a scheme needs to refer to the rules that empower them to do so, and which authority has enacted them, in turn these national plans and specific national administration in charge of them need to specifically refer to the EU legislation and European Commission Directorate General that deemed these rules compliant with the EU Single Market. So following bottom up the paper trail can be an easy and practical way to identify both authority and delivery actors as well as possible lock ins and barriers that remain in place (Pazos-Vidal, 2022). Once the mapping of stakeholders has been completed a table such as the below Table 6 Template needs to be put together by the pilot orchestrator. Table 6 Template for Actor identification Types of actors Sub-types Who? Why? Where? When? How? Beneficiaries Direct Beneficiary Indirect Beneficiary Potential Beneficiary Decision Makers Source(s) of Authority Delivery Actor Stakeholders Knowledge Actors Wider stakeholders 2.4. Step 3: identifying positions, opportunities and barriers Once the stakeholders have been identified in Step 2, the next step is to identify their respective positioning as regards to the topic (problem, challenge, opportunity) that is being 21 D6.1 - “Guidelines policy audit” analysed. There are several ways of doing so, from documental analysis (e.g. public statements, legislation, policy documents), stakeholder group meetings, a survey to them or a combination of those (Asdal & Reinertsen, 2022). Organising a meeting with the wider set of actors identified in Stage 2 is a particularly efficient way to understand the nuances of each actor position. Unlike the meetings with members of the Pilot organised in Stage 1, this meeting should be facilitated by the Pilot Orchestrator as the lead of the Policy Analysis exercise. However, the meeting dynamics could be very similar to the meeting in Stage 1, only with a wider set of actors being represented. Still, in many occasions it might not be logistically feasible to bring all identified actors together, or they would be too remote or unwilling to meet, hence the value of combining stakeholder meeting with documentary analysis and surveys to all identified actors. 2.4.1. Identifying actors’ positions Out of this a very simple table of stakeholder positioning can be used. One much used for local development worldwide is due to its simplicity that provide by ODA (1995) as it can be summarised in a very synthetic table such as in the example as in Table 7 below. Table 7 Example of Actor identification: Stakeholder positions in EU Structural Funds 2014-2020 Actor Position Detail Member State + - Increase freedom to design priorities. Avoid binding and detailed Partnership obligations, conditionalities. EU Commission (Secretariat General) + + Use Structural Funds (ESIF) as a way to influence Europe 2020 agenda implementation. Increase consistency via Common Strategic Framework as a way to increase legitimacy over the EU budget. DG REGIO + + - Keep substantive budget. Be the lead DG in ESIF and Partnership negotiations. Avoid reduction of budget towards thematic funds. DG AGRI + - Keep managing Rural Development fund. Resist CSF, ESIF Common provisions. DG EMPL + + - Increase share of ESIF, at least 20% ring-fence for ESF. Increase visibility, separate identity of ESF. Resist any provision that undermining identity of ESF, e.g. Multi-fund Thematic DGs + + - Increase budget to the detriment of ESIF. Alternatively increase access of ESIF to finance own policies. Resist CSF, Integrated approach to be directly binding on them. European Parliament + + + - Increase ESIF budget. Increase ability to scrutinise and accountability over ESIF implementation. Widen legitimacy from LRAs (territorial instruments, partnership provisions). Resist MS watering down regulations, cut down budget. Committee of the Regions + - Increase budget, partnership provisions, CoR own scrutiny role. Reduction of budget, conditionalities. Local and Regional Authorities + + - Access EU funds. Territorial Development instruments (CLLD, ITI), sub-delegation. Additional audit/regulatory burden, Conditionalities. 22 D6.1 - “Guidelines policy audit” Civil Society + + - Increase earmarked funds. Increased partnership provisions (visibility of decisions, access to decisionmaking). Limit additional obligations (audit, co-financing) in exchange for enhanced partnership provisions or fund allocation. Source: Pazos-Vidal (2014). However, this assessment of the various actors' position is too static and a more dynamic picture of their relationships (hierarchical, partnership) or interdependencies (top down, bottom-up) and attitudes (constructive, resistance) can be created to better illustrate them, as shown in the Figure 4 example. Figure 4 Example diagram with broad stakeholder relationships 2.4.2. Stakeholder matrix Depending on the availability of information or feedback from the positions of each actors a more fine-tuned assessment (stakeholder matrix) can be created by exploring the detail positions relationships and biases of each actor. 23 D6.1 - “Guidelines policy audit” Table 8 Template for detailed stakeholder matrix Name Type of Actor (as in Step 2) Role and Importan ce Interest pursued Power and resource s for influenci ng Formal and Informal Linkages with other actors Incentives Bias Source: adaptation from ODA (1995) and European Commission, 2012). In the above mapping characterising, the respective actor biases may be difficult to be identified and quite subjective for the Orchestrator to do so, as the actor may be reluctant to fully spell out its views. However, to the extent that is possible it is useful information to have. Again, a useful guidance of the types of bias is provided by the European Parliament own guidance (Van Woensel, 2021). Source: Van Woensel (2020) Figure 5 The bias wheel, a tool for becoming aware of biases in policy analysts' tasks 24 D6.1 - “Guidelines policy audit” 2.5. Step 4 Identifying solutions The last step is carried out based on the information gathered in previous steps and it aims at providing one or several recommendations of options for policy change (significant changes or minor adjustment) and the various scenarios that could emerge as a result. 2.5.1. Options for policy change The broad categories for policy options can be drawn from the EU Better Regulation Tool #34 on Territorial Impact assessment, already cited, are as follows: 1. Adjust the policy for the entire Union (or country, or region) or some of its parts; 2. Grant more time to implement a policy in some territories or some sectors/actors; 3. Exempt from the policy those actors or territories that are unaffected by the problem the policy aims to address; 4. Use existing policies to address asymmetric territorial impacts (for example by using Cohesion Policy, etc); 5. Create a new instrument to address asymmetric territorial impacts if/when they arise. Therefore, a policy option needs to have as end result one or several of these options. Because, more often than not, the issue being analysed might involve more than one policy and more than one level of governance answering the above set of questions can be refined further using the Subsidiary Assessment Grid (European Commission, 2018) 2.5.2. Scenario Building Scenario building should be constructed to understand the levers and barriers for policy change. Scenarios can be drafted by building on the combination of outcomes of the analysis of the available evidence and the outcomes of the brainstorming exercise in Step 1 and wider Stakeholder meeting and engagement in Step 3. These need to be prepared by the Orchestrator but should ideally be supported by policy analysis (such as the Knowledge actors identified in Stage 2). A small team of policy analysts can also prepare them. Ideally this scenario building should receive input from the wider actors identified in Step 3 and validated by the SMART ERA Pilots. Such scenario building needs to gather all available evidenced and seek to address the following questions for each of the possible policy options: - In order to achieve policy change X, who is the primary actor responsible for taking that decision? 25 D6.1 - “Guidelines policy audit” - Who stands to benefit or be negatively affected by change X? - What would be the knock-on effect of change X in the other identified actors? - What would be the consequence in policy Y of this change in policy X? - What would be the actors affected positively or negatively by this knock-on effect change in policy Y? This is why the questionnaire for the above-mentioned stakeholder group/survey or documentary analysis need to respond to the previous questions. In essence, this allows to consider adjusting policy by looking at the principles of subsidiarity and proportionality: ● The subsidiarity principle helps determine whether it is justified for the Union to act within the shared or supporting competences it has been given under the Treaties or whether it is more appropriate that Member States act at the appropriate national, regional, or local levels. ● The proportionality principle helps ensure that the intensity of the legislative obligations or policy approach match the intended objectives of the policy or legislation. This means that the content and form of Union action (and likewise national and subnational authorities) must not go beyond what is necessary to achieve the intended objective For illustrative purposes, If you've ever needed to explore the full impact of a proposed change, these dependencies and interrelations can be illustrated by a diagram of the direct and indirect future consequences of a particular change or development. This is where the Futures Wheel can help. This visual tool gives you a structured way of brainstorming the direct and indirect consequences of a decision, event, or trend. In 'The Futures Wheel´ the change that has been identified is placed in the middle and is a way of organising thinking and questioning about the future–– then small spokes are drawn wheel-like from the centre. Primary impacts or consequences are written at the end of each spoke. Next, the secondary impacts of each primary impact form a second ring of the wheel and future rings with more knock-on effects can be added until the most complete picture of effects and consequences is identified. Therefore, this is not just a useful way to illustrate in the final Policy Analysis report the consequences of the intended changed, but also this provide as template that can be used in the above-mentioned brainstorming sessions to help collectively identify the possible consequences of a given scenario. 32 D6.1 - “Guidelines policy audit” rp_conclusions_of_the_g100_rural_proofing_ initiative_from_spain_pazos-vidal.pdf  Pazos-Vidal, Serafin, Martinez Tomey, Miguel, (2021) G100.-Conclusiones-finales-modeloRural-Proofing.pdf (ruralproofing.com)  Rouby, Alexia. (2022) Rural Proofing in the Long Term Vision for Rural Areas, DG AGRI/European Commission  Selander, E. (2022) ‘A stronger rural perspective: How we work with rural proofing in Sweden’. Presentation to the First Meeting of the European Network for Rural Development’s Thematic Group on Rural Proofing.https://ec.europa.eu/enrd/sites/default/files/tg1rp_a_stronger_rural_perspective_how_we_work_with_rural_proofing_in_sweden_selander .pdf  Shortall, Sally . (2022) Rural Policy / Rural Proofing in Northern Ireland, Waterford Institute of Technology, Ireland  Kasemets, Aare and Taavi Kurvits, (2022) How to make the regional impact assessment, rural proofing, a routine part of the decisionmaking process of officials across the government, in all ministries? Ministry of Rural Affairs, Estonia  Swedish Agency for Economic and Regional Growth, Jan. 2022. A Stronger Rural Perspective, Howe we work with rural Proofing in Sweden https://enrd.ec.europa.eu/sites/default/files/ tg1rp_a_stronger_rural_perspective_how_we_work_ with_rural_proofing_in_sweden_selander.pdf  Tvrdonova, Jela, National LAG Network, Slovakia Rural proofing – reflection points and suggested actions, Jela Tvrdonova, National LAG Network, Slovakia