Work Programme 2012 to 2014 Approved April 2012

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1 Work Programme 2012 to 2014 Approved April 2012 WORKING FOR ORGANIC FOOD AND FARMING IN EUROPE 1 (14)

2 Introduction: Herewith the IFOAM EU Group presents an ambitious work programme for the year 2012 to 2014 following discussion at the 5 th General Assembly in 2011 and final approval by the board. It follows the strategy of 2009 taking the latest developments and discussions into account. One focus is to influence the set up of the major policies within the new financial framework of the European Union (2014 to 2020) that is currently under discussion, with the Common Agriculture Policy and announced review of the organic regulation by the European Commission is key priority for the IFOAM EU Group. IFOAM EU seeks to enhance further its communication outreach and its role as information exchange platform. Finally, IFOAM EU wants to support and enhance key developments in organic productions, to improve the system and to support capacity building in particular in new member states. The IFOAM EU Group works primarily in three areas and therefore the five goals identified are grouped according to these strategic areas along with a cross cutting area of management. Position Organic & Advocacy work at EU level Support organic key developments & Capacity building Management of organisation Provide Information Platform for organic movement The IFOAM EU Group has five main goals: Area I: Position Organic & Advocacy work at the EU level Goal 1: Shaping proactively organic regulations in the EU post revision area Goal 2: Influence the establishment and implementation of key policies within the new EU Financial Framework 2014 to 2020 and ensure that Organic concepts are sufficiently recognised Area II: Information and discussion platform Goal 3: Develop the IFOAM EU information platform Area III: Support key organic developments & projects Goal 4: Be the main driving force towards sustainable food production Cross cutting area: Management of organisation Goal 5: Ensure a well managed organisation based on sustainable resources 2 (14)

3 Area I: Position Organic & Advocacy work at the EU level Goal 1: Proactively shaping organic regulations in the EU post revision area The new organic regulation (EC) 834/2007 and its implementing rules came into force on 1 January 2009, with the labelling regime and organic aquaculture rules in mid With the last missing bid of the wine processing rules, the revision comes to an end and an experience with the new organic regulation is in place. However, the European Commission announced a review of the organic regulation for the years 2012/13 with possible legal proposal for a change. The new Lisbon treaty will impact decision making not only for organic EU regulation and therefore the IFOAM EU Group will need to re- adjust its advocacy work to new procedures and the further development of different areas. It will further develop a long term strategy to regulate organic farming at the European level. Objective 1: Adjust the advocacy rules to new EU procedures and Lisbon treaty The Lisbon treaty and the set up of an Expert Group for Technical Advice on Organic Production (EGTOP) by the European Commission will change the decision making procedure regarding the implementing rules (889/2008) on the basis of organic regulation 834/2007. Currently, on the one hand, EU institutions try to find an agreement for the alignment of the Lisbon treaty, while in the future technical rules may be adapted directly by the Commission without the necessary approval of the Standing Committee on Organic Farming. Instead a veto right by member states and the European Parliament will be granted. On the other hand, the newly established EGTOP, that needs to be technically consulted before amending the organic implementing rules, will weaken the role of organic stakeholders in the approval procedure. Therefore the IFOAM EU Group must adjust its lobby work to the new EU procedure in order to ensure that in the future it continues to be sufficiently acknowledged. 1. Assessment of procedural changes through Lisbon alignment/egtop 2. Adjust advocacy approach and implement new lobby strategy Objective 2: Re- define approach towards the EU organic regulations and gaining leadership in its further development Since the early nineties, organic food and farming has been regulated by the EU and is managed by governments and authorities. also a challenge to the organic movement, who developed organic as a positive social and environmental tool and therefore claims its ownership. Further, the EU organic regulation becomes more and more detailed and organic stakeholders are questioning the approach to be taken towards the EU legislation. Consequently the IFOAM EU Group initiated a process to work out a long term strategy on how to regulate organic food and farming in Europe. The IFOAM EU Group already approved a position on how to use the flexibility rule within the EC 834/2007 and will work on its long term strategic approach towards regulating organic production in the EU. This includes 3 (14)

4 the aim to re- gain leadership on the development of organic standards as well as the development of new complementary tools such as a Code of Practice, which can be agreed as a common Code of Conduct. One example is the guidelines for pesticide residues in the processing sector, which the IFOAM EU Group published in Develop long term regulation strategy over next two year 2. Start implementation from 2014 onwards 3. Develop code of practices and update and promote guidelines on pesticide residues in the processing sector 4. Develop flexibility concept further and advocate for its acceptance at level of the European Commission 5. Promote Group certification also at within EU Objective 3: Integrating rules for EU Organic Processing into EU regulation 834/07 The IFOAM EU Group produced several suggestions on how to develop organic processing within the EU organic regulation 834/2007. However, due to other priorities, e.g. the implementation of the import regime and the issue of organic wine processing, the European Commission postponed the processing issues. However, the IFOAM EU urges the European Commission to place processing as a priority on its agenda and to distinguish between dossiers where an agreement can be easily found and issues that need more detailed elaboration, and therefore need more time. The IFOAM EU Group further organised its first conference on organic processing in 2011 that should be followed up with a succeeding conference. 1. Advocate for a two step approach of the European Commission to integrate different processing issues (Annex VIIIA; IX) 2. Work out concept to improve the environmental performance of organic processing in the EU organic regulation 3. Organise 2nd conference on organic processing and follow up conferences Objective 4: To advocate for the consistent further development of the organic EU regulation The revision of the organic regulation and its implementation has bound tremendous resources of the European Commission, in particular the organic unit in the last years. Nevertheless, by obtaining the remaining pieces, in particular the wine implementing rules, several other issues are on the desk of the European Commission for further elaboration. The most prominent ones are detailed rules for poultry, greenhouses, and the end of several derogations, e.g. feed. The IFOAM EU Group will closely follow and monitor the Commissions timetable and will with a proactive approach give guidance to the legislator. 4 (14)

5 1. Monitor closely the agenda of the organic unit of the European Commission and EGTOP 2. Advocate for IFOAM EU position in area of organic poultry, feed and greenhouses 3. Position the organic movement on relevant topics, such as risk based inspections, ending derogations, wild animals, etc. Objective 5: Ensure a credible Import regime The EU is currently implementing the revised rules on the import regime. However, more and more stakeholders of the organic sector raised concerns regarding its implementation referring to both: credibility and practical implementation. Areas of concern are for example the list of certification bodies approved for their operations in third countries, clear criteria for assessment of equivalence, clear explanation of roles of member states, with regards to imports under ATC and CB approved trade, ensuring independence between certifiers and operators, etc. The IFOAM EU Group already had discussions with the European Commission and integrated the topic prominently in its 2010 and 2011 conferences. Now, it is time to work out clear recommendations for a credible and reliable import regime and to provide guidance towards the European Commission and member states. The issue of simplifying procedures for exports of EU products should be also included. 1. Establish an import expert group to picture current situation and to work out recommendations to improve import regime 2. Establish regular dialogue with the European Commission on this topic 3. Consider strengthening engagements in the Anti- Fraud Initiative (guided by XY) or to develop own project Objective 6: Be driving force in the The European Commission will provide in spring 2012 a report on the implementation of the organic regulation to the Council including the aspect of the scope of the regulation and how to further improve it. In particular, the issue of improving controls will be in the focus, as well as simplification, flexibility, GMOs and imports. The report will kick off a regulation review process anticipated in the Commission work plan for 2012/13, that will be followed by stakeholder consultation, external evaluation report and Commission impact assessment. The IFOAM EU Group seeks to be main stakeholder in this process, calling for a careful analysis and focused improvement of the regulation, avoiding uncertainties for the organic sector after a five year revision process. At the same time the Commissions directorate for health and consumer protection (DG Sanco) will begin work on definitions for natural and organic cosmetics. The IFOAM EU Group will be ahead of the discussion with clear statements towards Commission and Council. 5 (14)

6 1. Analyse reports of the European Commission to the Council and possible advocacy work 2. Play leading role in the Commission s regulation review and ensure that the needs of the organic movement are well understood 3. Follow up DG Sanco work on definition of claims in area of cosmetics Goal 2: Influence the establishment and implementation of key policies within the new EU Financial Framework 2014 to 2020 and ensure that Organic concepts are sufficiently recognised Objective 1: Advocate for a CAP that supports the development of organic farming and that mainstream sustainability The Common Agriculture Policy (CAP) sets the political framework for farming in the EU and is the main funding instrument for farming in the EU. Therefore, the future direction of the CAP is of utmost importance for the further development of organic farming in the EU. The European Commission launched its legislative proposal in October These proposals are the basis of the co- decision procedure between the Council of ministers and the European Parliament, moderated by the Commission, which will constitute the final legal text for the CAP After the Lisbon treaty entered into force in December 2009, this is for the first time that the European Parliament is involved in the decision making process about the CAP on equal footing with the Council. The adoption of final legal texts can be expected for the beginning of As the new CAP enters into force on the 1st January 2014, member states will already begin to work on the national implementation in 2012, and will have to push through the legislative procedures in The IFOAM EU Group follows two lines in its lobby work: 1. A general mainstreaming of environmental and social sustainability in the CAP; 2. The prioritisation of and sufficient funding for of organic agriculture as a pioneering system approach to tackle sustainability challenges. IFOAM EU Group considers that the Commission proposals provide some useful tools, but are far from being ambitious enough. IFOAM EU Group will work in close cooperation with other environmental NGOs and civil society organisations in order to increase the pressure for change. The IFOAM EU Group focuses on the European Parliament as a direct lobby target, whereas it provides information, analyses and tools that aim to encourage and enable IFOAM EU members to effectively lobby towards ministries on both national and regional levels which would then influence the position of the Council of Ministers. In parallel, IFOAM EU group will begin, in the second half of 2012, to work on recommendations for the national implementation of Rural Development programmes with the aim of providing members with useful tools for national debates. 6 (14)

7 1. To draft a recommendation for amending COM legislative proposals as a basis of following lobby activities 2. Lobby campaign towards Members of the European Parliament 3. Provide information package, toolkit and analyses to members, coordinate and facilitate lobbying towards Ministers with the aim to influence EU Council position 4. Analysis and recommendations for Rural development programmes in order to inform members and facilitate their lobbying for national & regional implementation of CAP reform Objective 2: Monitor developments around new technologies in food policy and ensure GM free Organic production in the EU The years will be crucial for defending the GMO free sector against being economically knocked out through GMO contamination. The Commission Proposal of July 2010 to allow national bans on GMO- cultivation has found a majority of support in the European Parliament, but is now at a stalemate in the Council. This change is far from being an overall solution, but it could open pathways to increase responsibilities on the member state level. Therefore, the IFOAM EU Group will monitor the further developments and support the attempts to allow national bands supporting the European Parliament demand to create measures to prevent contamination, mandatory for all member states. With the publication of evaluation reports on the legislation on GMO cultivation (mainly directive 2001/18) as well as on GMO food and feed authorisations and labelling (mainly Regulation 1829/2003) by the European Commission in November 2011, a revision of GMO legislation has begun. The most likely points to be addressed, soon after the Commission has created a de- facto tolerance for non- authorised GMOs in feed, is the zero tolerance and unclear testing and sampling requirements for non- authorised GMOs in food and for both authorised and non- authorised GMOs in seed will also bring a follow- up of the EU court of justice ruling on GMO pollen in honey. IFOAM EU Group will focus its campaign for the freedom of choice for GMO free food on the socio- economic impacts of GMO contamination risks. Another major point will be GMO free seed which is an indispensable resource for the GMO free food sector. Another point of concern for the IFOAM EU Group would be the possible import and use of cloned animals, as well as the offspring and products that derives from these animals. IFOAM EU group lobbies for a total ban of these products. The development of policies related to the use of nanotechnology in food production and food packaging will be closely observed by the IFOAM EU Group, as well policy action will be take into consideration the case that consumer interest might be at risk. 7 (14)

8 1. Monitor policy developments regarding the use of new technologies in food, with special concern for GMO cultivation, authorisation, labelling and imports as well as national bans; monitor co- existence legislation in member states 2. Highlight the problems of contamination in organic production in the EU towards the EU institutions and lobby for the freedom of choice for GMO free food production and consumption, demanding EU legal rules to protect GMO free production from contamination 3. Discussion roundtable 2012/2013 with organic food chain operators to identify challenges, formulate policy demands and develop practical advice ending in a publication in 2013/ Lobby for GMO free seed, coordinate farmer's groups to call for GMO free seed 5. Strengthen strategic alliances to work on broader GMO issues, e.g. national bans and continue to support the NGO initiative to ban meat of cloned animals and their offspring in the EU Objective 3: Increase the research money spent to develop organic solutions and innovations The EU will increase its research budget from, currently, 53 billion Euros (7 th Framework Programme 2007 to 2013) to 85 billion Euros in the financial period On December 6 th, the European Commission will publish its legal proposal for the new Framework Programme, and the discussion about the future research concept will begin in the European Parliament and member states. The IFOAM EU Group aims to influence the political discussion and final approval to integrate concepts that acknowledge the system approach of organic food and farming systems. The main tool to achieve this aim is the research Technology Platform TP that unites several EU umbrella organisations, organic companies, scientist and civil society organisations and where the IFOAM EU Group hosts the secretariat. In cooperation with civil society organisations the IFOAM EU Group will start an advocacy campaign towards member states and in particular the European Parliament. Further, TP Organics will develop an Education and Innovation plan in 2012/13 and an updated strategic research agenda and implementation plan in 2014 in order to provide input for research priorities in the new framework programme. 1. Analyse the legal proposal of the Commission and begin advocacy campaigns with civil society organisations and other partners 2. Organise conferences in EP to provide discussions with MEPs, member states and COM 3. Hand in yearly priority topics for organic food and farming research towards the European Commission 4. Increase strategic cooperation with TP Organics and other networks 5. Produce TP Organics Education and Innovation Plan 6. Produce TP Organics updated strategic research agenda/implementation plan for organic research (2014) 8 (14)

9 Objective 4: Highlight the pioneer role of organic farming in soil conservation and tackling the climate challenge The question on how to tackle the climate challenge in food and farming systems will remain of great importance and will be addressed in different EU policies (e.g. CAP, expected proposal for goals on how different industries can contribute to Greenhouse Gas Emission (GHG) reduction commitments 2012; strategy to adapt EU economy to climate change consequences to be published in 2013). The IFOAM EU Group will highlight the role of organic farming to provide sustainable solutions for carbon sequestration, GHG emission reduction and the adaptation of food systems to the consequences of climate change. Moreover, it will point out in cooperation with RTOACC - the best practices within the organic sector that can help to further develop the pioneer role in the climate debate. Healthy soils are the foundation of future food security. Organic farming begins with building up healthy soils. IFOAM EU Group supports an EU legal framework for the protection of soil and therefore urges member states to overcome the deadlock for the EU framework directive for soils in the European Council. Moreover, IFOAM EU promotes organic practices as the best practice to fight soil degradation and erosion and to set the foundations for future food security. 1. Publications on healthy soils and climate change: Factsheets on how member states can best improve the status of their soils and contribute to climate change mitigation by meaningful combinations of EAFRD measures; Brochure to highlight the climate change adaptation potential of Organic Farming 2. Lobbying: Meetings and lunch debates with MEP and Commission officials to highlight the role of organic farming in the creation of the climate change adaptation strategy as well as Greenhouse Gas Emission reduction activities. 3. Use the studies on climate change mitigation (2009) to lobby for organic farming as system approach in climate change mitigation and carbon sequestration, e.g. in the CAP debate. 4. Closely observe developments regarding the directive for the protection of soils, in case of upcoming discussions inform members and encourage them to advocate for the adoption of the directive Objective 5: Advocate for organic farming as best practice for sustainable, long term food security Scarcity of natural resources and the growing world population are of major concern for the future of food security. Food and farm systems must significantly improve regarding the recycling of nutrients, dependency on external inputs (feed, fertiliser, and pesticides), efficient energy use and the careful treatment of water and soils in order to guarantee the availability of natural resources we urgently need for the future our food production. The IFOAM EU Group will advocate for a policy framework that puts long term sustainability of food systems first. Moreover, it will highlight the pioneering role of organic farming in almost closed nutrient cycles, overall sustainability and resource efficient livestock systems including on farm feed production. 9 (14)

10 er Food and farming related themes such as soil, water, minerals and food waste are addressed in this roadmap; a consumption paper on phosphorus scarcity will be published in 2012 The implementation of this Commission flagship initiative in different policy areas will follow in the coming years. The IFOAM EU group will continue to bring organic farming into the resource efficiency discussion, as started in The 7th EAP (Environmental Action Programme) ends in 2012 it is the basis of environmental action in the EU and a comprehensive update will be supported by IFOAM EU Group. The implementation of the Water Framework Directive will be ongoing through the coming years. The Commission will synthesise policy recommendations for ongoing policies to safeguard Europe's efficiency strategy towards IFOAM EU will highlight the role of organic farming to protect our water resources. 1. Highlight - strategy to face the food security and resource scarcity challenge in the future and advocate for organic food systems to address the resource scarcity challenge as related to the Commission roadmap for a resource efficient Europe 2. Further explore organic best practices and scientific evidence regarding resource efficiency, publish results 3. Support the creation of a comprehensive a 7th EAP with appropriate statements 4. Publish a position paper related to the implementation of the water framework directive and a fact sheet highlighting the role of organic farming as measure to protect waters in sight of the national Rural Development programmes 5. Lobby work to include OF as best practice for water protection in WFD implementation Objective 6: Advocate for biodiversity to be supported as resource for sustainable farm systems The EU biodiversity strategy to 2020 has been published in 2011 and is to be reviewed in In the now following implementation steps, IFOAM EU Group will advocate for organic farming as a best practice. To create synergies between the organic practices and markets and High Nature Value farming, an enforced dialogue will be held with NGOs, and possible paths will be developed and further explored. Further, the legislation on the marketing of seed and plant propagating material is crucial for the future of agro- biodiversity, as it regulates market access for plant varieties. The legislative framework is now under revision, a legislative proposal is expected for the first half of IFOAM EU group will continue to lobby for facilitated market access for open 10 (14)

11 1. Position paper on seed marketing legislation (first half of 2012) 2. Advocate for legislation that enables easier access of a wide range of plant varieties to the market; deliver continuously information to members about the progress of the legislative procedure and coordinate lobbying on member state level 3. Lobbying for Organic Farming to be considered as measure in the implementation of the Biodiversity strategy and update members about developments 4. Publish a fact sheet on biodiversity: How member states can best enhance biodiversity on farmland by meaningful combinations of EAFRD measures (end 2012) 5. Organise an enforced dialogue between NGOs lobbying for High Nature Value (HNV) farms to develop a strategy for creating synergies between Organic Farming and HNV Objective 7: Advocate for clear labelling rules, the promotion of truly sustainable food The IFOAM EU Group also closely observes developments of policies that impact on food labelling and advocates for the provision of clear messages to consumers. Labels referring to specific aspects of sustainability of a product (animal welfare, climate footprint, etc.) would not require the producer to follow a comprehensive set of rules as the organic logo does, which must be considered when further discussing new labelling schemes (see also under Goal 1, objective 6: Cosmetics). - EU group as leading to consumer confusion. The organic label should not be put in competition with a label that gives the impression of delivering similar performance, whereas in reality it does not address the same comprehensive set of sustainability standards as organic farming does. Therefore, the IFOAM EU group will continue to advocate for the scope of the eco- label not being extended to food. In parallel, IFOAM EU will work on progress regarding environmental improvement in organic processing to maintain the pioneer function of the organic sector also in this regard. promotion programmes and quality policy. The IFOAM EU Group advocates for the consideration of health and sustainability aspects in these programmes, with organic products given a priority as leading the scale of healthy and sustainable food. 1. Closely observe developments on EU level regarding food labelling and exchange with members on developments on EU and national level and take lobby action if appropriate 2. Advocate for clear labelling rules for food products that prevent any confusion of consumers; prevent competing labelling schemes with similar appearance or underlying message 3. including a comprehensive set of sustainability requirements, delivering healthy food consequently lobby for organic being prioritised under the promotional programmes 11 (14)

12 Area II: Information and discussion platform Goal 3: Develop the IFOAM EU information platform Objective 1: Bring IFOAM EUs communication activities to a new decade The IFOAM EU Group increased its communication activities to better inform the membership and sector and provided a discussion platform through different events and its presence in social networks/new media. The new position in the Brussels office to enhance these activities was created. The IFOAM EU Group will organise a number of events, the main one among others, the series of European Organic Congresses as well as produce information material on current topics. It will strengthen presence in new media and will develop specific information services for the organic sector. In 2012, the webpage will be revised together with IFOAM World and the recently established intranet will be further developed. 1. Develop a comprehensive communication plan and double its outreach to the organic sector 2. Publish dossiers & information on current topics, such as dossiers on organic regulation and wine rules 3. Strengthen online presence and in new media and revise webpage, intranet 4. Develop new information services for members and organic sector 5. Organise one European Organic Congress per year, continue other events, such as the organic processing conference Objective 2: Enhance dialogue with national membership The IFOAM EU Group was very successful in establishing an office in Brussels, to build strategic alliance and to become a political player on the EU scene. However, the IFOAM EU Group decided to be a stronger presence at national/transnational levels to be part of the discussion regarding membership. Therefore, the Brussels office staff as well as board members are participating in different national events, visiting the membership and the IFOAM EU Group was taking up patronages of key regional events. The IFOAM EU Group will continue these activities, also strengthening its national lobby work, providing information to national levels and furthering its knowledge about the different situations in member states. 1. Patronage of core events and initiatives of the organic movement 2. Participate at national events to contribute from the European level 3. Enhance dialogue with national membership 12 (14)

13 Area III: Support key organic developments & capacity building Goal 4: Be the main driving force for sustainable food production Traditionally, the IFOAM EU Group worked mainly on topics of interest of EU 27/EFTA countries. However, in recent years there has been an increased number of specific requests to the IFOAM EU Group and it was concluded that there is a need for specific projects by membership that might be only of interest to some countries or sectors. Conversely the IFOAM EU Group had more discussions on how to remain the main driving force towards sustainable food production and the main time finding compromise between all EU 27/EFTA countries in its daily advocacy work, in particular in the area of regulation. Therefore the IFOAM EU Group will integrate the area of supporting organic key developments and projects in its strategy. This will strengthen the IFOAM EU Group as the leading organisation for organic food and farming in Europe. The following key directions have been identified so far (but might be amended): a) Capacity building & training of organic sector, in particular in new member states b) Credibility of organic sector, e.g. Code of conduct organic processing, credibility initiatives regarding import regimes c) Improve environmental and social performance, e.g. in area of climate change mitigation, biodiversity d) Facilitate knowledge transfer and management Cross cutting area: Management of organisation Goal 5: Ensure a well managed organisation based on sustainable resources Objective 1: Ensure long term financial security The IFOAM EU Group has improved its key financial factors since the last GA in 2009, but long term financial security still remains a primary concern and serious planning is limited to one year. The per year. However, the implementation of the new membership fee system will bind a lot of resources for the next transition period. Further, a new concept for sponsorship should stabilise or increase this income and a newly established full time position as project fundraiser will ensure that at least 50% of the needed income can be ensured through projects and operational grants. It was decided that the diversity of project participation was in order to decrease dependency on single operational grants. This should provide the IFOAM EU Group staff a long term perspective and security. 1. Implement the new membership fee system beginning in Diversify and increase project income 13 (14)

14 Objective 2: Strengthen involvement of the membership and review its internal procedures The IFOAM EU Group board decided in 2009 to amend its working methods to make the IFOAM EU Group more efficient, to increase the involvement of membership and organic sector and above all, make the group more influential and increase quality outputs. It took into consideration that a board of 30 members is a rather large construct to be able to guarantee sufficient flexibility to react to political developments. For example, it was agreed that the IFOAM EU Group needs to benefit more from its membership expertise and therefore, it was decided that content discussions should take place in extra established working groups involving the membership. This reform will be now reviewed and evaluated. In the context of current discussion with the membership and with the board the review will also take into account the membership fee reform and its impact on participation in decision making processes. 1. Establish task force to review the 2009 reform 2. Produce conclusion report after one year intensive discussion and consultation (2012) 3. Discuss and agree results in extra GA February Implement decisions ( ) Objective 3: Increase organisations productivity Financial means are increasingly difficult to obtain in times of financial crisis. Therefore the IFOAM EU Group plans to increase its productivity in different areas. Currently the technical potential to facilitate consultations and coordination procedures has not been fully exploited, in particular in area of document sharing. Therefore, a high level advisory group will be established to help the IFOAM EU Group and the monitoring system will be improved to ensure that the IFOAM EU Group is well informed about cross- cutting legislation that impacts organic food and farming to ensure that IFOAM EU is able to take the appropriate actions in time. Further, a register of lobby activities will be integrated in this part. 1. Produce a recommendation report to increase productivity (2012) 2. Establish a high level advisory group 3. Improve legislative and advocacy monitoring systems 14 (14)