tag:blogger.com,1999:blog-241938842023-06-21T06:52:37.327+02:00Reflections on cognitive interdependencies in policy makingA pre-cooked account of my thoughts on the nature and origins of interest intermediation in political processes. The primary focus of my work is the political sytem of the European Union.Unknownnoreply@blogger.comBlogger39125tag:blogger.com,1999:blog-24193884.post-36050604298837043282008-08-24T22:57:00.005+02:002008-08-25T01:59:04.388+02:00the value of framing conceptsFraming concepts are definitely very helpful for analysing - or in a first step heuristically describing - policy making processes in complex environments like the European Union.<br /><br />Two important reasons stand out in this regard: Firstly the very limited amount of actual knowledge about the a given policy that exists among the relevant actors; and secondly the fact that policy processes and - even more so - policy documents are highly abstract in nature, which makes it very difficult to conceive many actors that have direct experience or schemata that could function as an a priori context for a policy message. <br /><br />Thus, if almost nobody knows what exactly a policy tries to accomplish, and even fewer people have a preconceived idea how to judged such a policy, a policy frame (which defines the problem, identifies the cause, provides a value judgement and proposes a remedy to address the problem) becomes the most important cognitive basis for the policy making process. Applied to a concrete case, an interesting question is exactly how few people can be expected to know what a policy is about and why it is necessary. <br /><br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-4804757869296916202008-08-24T18:39:00.001+02:002008-08-24T18:40:51.258+02:00time is runningIt has again been many months since the last post here, and despite the fact that theory-building has to some extend been pushed onto to the backseat (at least in any direct, concretely manifested manner) due to more pragmatic, in-the-field research activities, a number of issues have emerged that will be reported here. <br /><br />To start: It has become very clear that the moving-target quality of policy-making warrants specific attention. While any policy document has a prescriptive quality to it, ie. is meant to trigger certain developments or at least reactions, some documents seem to be little more than defensive instruments developed to essentially accomplish two things:<br /><br />1. Fulfill a political promise that a certain measure would be taken by a specified time in regard to constructed problem or need<br /><br />2. To provide a document that, while being broadly acceptable to the stakeholders involved in the issue, summarizes the questions at stake hinting in a certain direction without actually answering them.<br /><br />Thus, such a document is meant to functionally clarifying a political issues in order to keep the drafting entity in business of coming up with follow-up documents and reports, thereby proving involvement and responsibility taken seriously (and hence proving its own relevance) <br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-50248357769506349602008-02-19T22:40:00.001+01:002008-02-19T22:41:30.186+01:00ETI - still aliveThe ETI is still ravelling along. Proof of its existance are the contributions to a recently finished public consultation on a proposal for code of conduct for interest represenatives. To be found here:<br /><br /><a href="http://ec.europa.eu/transparency/consultation_code/contributions_en.htm">European Commission - Consultation on a Code of Conduct for Interest Representatives - Contributions</a><br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-26608166309503797892007-08-25T01:22:00.001+02:002008-08-25T01:30:01.253+02:00quoted on euractiv.comThe RCIPM blog has been mentioned (or listed - to be honest :-) on a EurActiv.com article about "<a href="http://www.euractiv.com/en/pa/blogs-filling-eu-communication-gap/article-164717">Blogs: Filling the EU's 'communication gap'?</a>".<br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-39441062874968835482007-07-16T23:32:00.000+02:002007-07-16T23:35:57.356+02:00ETI update<p class="MsoNormal"><span style="" lang="EN-GB">I just attended a talk with a Cabinet Member of Commissioner Kallas who informed an interested audience about the ETI. As news, it was understood that the COM currently negotiates with the EP to broaden the scope of the register to cover lobbyists working with both EU institutions.<o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">Interestingly, he summed the initiative up by stressing that it addresses transparency in three regards: (1) in terms of the identity of interest representatives; (2) as means to ensure balanced access to policy makers (or rather as defensive mechanism, so that the COM can proof it is not biased in its choices of conversation partners); (3) as a precaution to prevent “<a href="http://www.washingtonpost.com/wp-dyn/content/linkset/2005/06/22/LI2005062200936.html">Abramoff</a>” to happen in the EU. <o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">According to his explanations, the ETI is also meant fight “deceptive” lobbying i.e. via <a href="http://www.sourcewatch.org/index.php?title=How_to_research_front_groups">front groups</a>. Those front groups were also cited to support the argument that financial disclosure is necessary in the proposed lobby register. Another argument used was that companies might use funds to lobby against regulation instead of using the same money in R&D to develop new, compliant solutions. <o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">Well, even if those arguments are rather poor, it is worrying that the discourse does now revolve around this question. Not only is it very difficult to define which financial information should be required for disclosure, the COMs position to leave companies much flexibility as possible risks to blur the whole argument itself. If it is not prescribed exactly how to measure the numbers required, the data is not comparable and rather worthless. Though even more important is the fact that the speaker could only refer to peer pressure arguments as he responded to the question why the register is not compulsory or why the voluntary register does not have better incentives to register. Indeed also the exclusion argument (i.e. a compulsory register would put non </span><st1:city><st1:place><span style="" lang="EN-GB">Brussels</span></st1:place></st1:City><span style="" lang="EN-GB"> based organisations at an disadvantage) does not hold, because it is entirely a procedural question i.e. one could offer a fast track registration for interest that seek for the first time contact with institution and that are not based in Brussels.<br /></span></p><p class="MsoNormal"><span style="" lang="EN-GB">Thus, even if the lobby ecosystem depends to a large extend on the individual companies reputation (which serves a vital precondition to operate), it is questionable if the register will create a sufficiently powerful social dynamic to effectively “force” companies to register. We’ll see next year, the register is expected to open in spring 2008.</span></p><p class="MsoNormal"><br /><span style="" lang="EN-GB"><o:p></o:p></span></p><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-73846683235691653372007-07-15T00:28:00.000+02:002007-07-15T00:34:20.203+02:00berlaymonster blog<p class="MsoNormal"><span style="" lang="EN-GB">While staying here in </span><st1:city><st1:place><span style="" lang="EN-GB">Brussels</span></st1:place></st1:city><span style="" lang="EN-GB">, doing some field research in the nitty-gritty details of technology policy making in the EU, i came across a number of things that some people call the <i>EU ecosystem in </i></span><st1:city><st1:place><i><span style="" lang="EN-GB">Brussels</span></i></st1:place></st1:city><span style="" lang="EN-GB">. Since this ecosystem is a hugely important stage for all issues addressed here, a lot needs to be said about this example of jargon, but first - as an appetiser - see this blog as one of the best examples of the cyberspace part of this ecosystem > </span><a href="http://berlaymonster.blogspot.com/"><span style="" lang="EN-GB">Berlaymonster</span></a></p><p class="MsoNormal"><a href="http://berlaymonster.blogspot.com/"><span style="" lang="EN-GB"><br /></span></a></p><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com2tag:blogger.com,1999:blog-24193884.post-88417085875991285722007-06-14T23:47:00.000+02:002007-06-15T00:10:10.861+02:00inner dynamics of bureaucracies<span style=";font-family:";font-size:85%;" lang="EN-US" >Large bureaucracies are very complex organizations. Indeed, in terms of procedures, inner workings and resistance to change this is well known. But astonishingly, these complexities have a very serious </span><span style=";font-family:";font-size:85%;" lang="EN-US" >impact</span><span style=";font-family:";font-size:85%;" lang="EN-US" >l on the output capabilities of such an organization. This is to say, not only the individual motivation of employees is important (and because of their numbers and complex interdependencies really difficult to measure) but also the difference between levels of an organization. The cognitive distance between political management level and case officer/policy developer can be immense even though people work on the same issue/topic. One of the most important reasons for the distance is the variation in timelines/differences in timing considerations. Those are related to fundamental employment or term durations, but affect essentially every decision, especially those related to tactic and strategic planning. Essentially, the same issue/topic can not mean the same thing for employees on different level of a large organization or bureaucracy i.e. neither in administrations nor in private organizations.<br /><br /><br /></span><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-57949343694759261302007-04-12T23:48:00.000+02:002007-07-17T00:09:18.643+02:00expertise requirements in policy making<p class="MsoNormal"><span style="" lang="EN-GB">One of the fundamental questions regarding the need for information input into policy making processes is that of the assumed correlation between administrative resources and the need for outside information. In a nutshell, this assumption says: because the Commission is a small administration that lack administrative resources it has a greater need for external expertise than – for instance – Member States governments. Thus, the Commission is supposed to be more receptive for lobbying efforts. This assumption, though compelling, certainly needs to be validated under a perspective of a general enquiry into the expertise requirements in policy making.</span></p><br /><p class="MsoNormal"><br /></p><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-45045982902024820142007-03-17T00:07:00.000+01:002007-07-17T00:10:07.210+02:00reframing<p class="MsoNormal"><span style="" lang="EN-GB">Reframing of issues in new contexts is a fundamental process in policy making. Interest frame are aggregated and integrated in policy processes, hence the cognitive environment of an issues changes. This change affects basically everyone involved – or rather: everyone who follows the current developments of a specific topic. Thus on a private level, the reframing phenomenon can be seen as related to the personal intellectual stamina, i.e. do I follow a new way of looking at an issue or do I stay with my preconceived opinion (possibly in the face a mounting conflicting evidence)? However, in public such a reframing event is related to the intellectual reputation of an individual, i.e. referring to the question: do I want to be regarded as an innovative mind or do I stick to defending “old thinking”. <o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">Hence, a reframing event puts actors in of an intellectual environment under pressure to adapt to the new frame, provided the reframing event is staged in a public forum that guarantees enough attention underpinned by a sufficient <i style="">opinion leader</i>-reputation.</span></p><p class="MsoNormal"><br /><span style="" lang="EN-GB"> <o:p></o:p></span></p><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-51077604689490519812007-02-18T16:18:00.000+01:002007-06-15T00:11:10.248+02:00“windows of opportunity” and “policy frames”<a href="http://dict.leo.org/ende?lp=ende&lang=de&searchLoc=0&amp;cmpType=relaxed§Hdr=on&spellToler=on&search=coincide&relink=on"> </a><p class="MsoNormal"><span style="" lang="EN-GB">The question of the relationship between “windows of opportunity” and “policy frames” is an especially interesting one, because by answering it one has to bridge the difference between two perspectives on the policy process.<o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">One the one hand, <i style="">windows of opportunity</i> suggests a chronological dimension of the policy process, whereby different institutional events and circumstances coincide to open the window (Kingdon’s “streams”) that stays open until the establishing circumstances change.<o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">On the other hand, <i style="">policy frames</i> are cognitive constructions that can or cannot come into being in relation to real-life circumstances, but refer to a certain interpretation of reality that as such is stable over time. Thus, a frame can be preserved even if the circumstances that triggered its construction change. <o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">Taken together the following relationship between both terms is adequate:<o:p></o:p></span></p> <p class="MsoNormal"><span style="" lang="EN-GB">Whereas <i style="">windows of opportunity</i> offer the chance to use a certain policy solution/concept in order to solve a problem in a particular time und specific circumstances, <i style="">policy frames</i> are a lasting argumentative windows that interprets reality in favour of certain policy solution/concept to solve the problem. A <i style="">policy frame</i> manifests itself to a <i style="">window of opportunity</i> in Kingdon’s sense as soon as a sufficient number of relevant people in the policy discourse accept the frames interpretation of reality as a cognitive basis to act upon.</span></p><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1165070305158259952006-12-02T15:37:00.000+01:002006-12-02T15:39:32.773+01:00political strategies as policy framesThe EU Commission fairly regularly publishes broad policy strategies that address specific societal concerns and define policy priorities accordingly. There are numerous examples for this among the current activities of the EU policy-maker. One could argue that the common market itself – and hence important parts of the political system – originates from such a strategy as formulated in the 1985 White Paper "Completing the Internal Market".<br />One interesting aspect of such strategies is the fact that they function as a frame of references for subsequent policies. However, the mechanism how this works is rather complicated.<br />(1) Strategies are derived from prior policies or rather the implementatory experiences of prior policies. Thus, one could think of them as a stock-taking and bundling exercise with regard to prior activities.<br />In addition, (2) strategies have a future oriented feature, by assessing future developments and the associated needs. That is, stock-taking and drawing lessons from prior experiences and then bundling activities to address the challenges that result from such an exercise.<br />Such a strategy (3) then defines the priorities in a policy field and proposes activities that should be undertaken to meet the challenges identified in the strategy. Thus, a cause or rational is created to achieve specific goals by specific means.<br />After such a strategy is adopted, subsequent policies and the strategy in the field stand in an interactive relationship to each other. On the one hand are specific policies necessary to implement the strategy. On the other hand the strategy defines what policies can be proposed and which goals should be pursued. <br />Hence, the question is: Are strategies instrumental in defining the content of subsequent policies, or do political strategies provide only the rational and the political justification for one sort of policies to be advanced rather than another one? <br />The answer seems to be related to two broader questions, namely: How are societal problems introduced in political systems? And: What is the relationship between the perception of a societal problem and the selection of policies to address it?<br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1164816217470364172006-11-29T17:03:00.000+01:002006-11-29T17:03:37.570+01:00two aspects of successful politicsThere are at least two different notions of success in the political system of the EU. One kind is more “political” and media/attention savvy, the other is more “policy-oriented” and results-focused. What does this mean? <br />Politicians need successes to justify their work. Either those successes come from long-term developments e.g. the results of an implemented policy or from short term attention in the media or among political elites. The problem is that timelines are not necessarily fair, meaning a policy built and implemented under a certain politicians watch may well deliver its success-results to the politician’s successor. Thus, politicians have to make sure that they get successes in their term of office. <br />Policy-makers on the other hand depend on long term successes to proof their competence and to underpin their reputations. Certainly the underlying social process does not involve the same kind of people, e.g. only experts in a certain policy field can assess a policy-maker’s reputation and only if they know the field long enough to oversee the policy making timeline. In order to safeguard such a long term approach to success-results, led victories are to be exploited or can even be seen only in hindsight.<br />Therefore: the difference between success-result timelines complicates the relationship between the political and the administrative level in the COM. <br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1161120403418336112006-10-17T23:26:00.000+02:002006-10-17T23:26:43.433+02:00COM consultations a pivotal sphere of interactionThe COM depends to an important extend on outside expert knowledge to draft policy proposals. That is, interests have to be consulted prior and during the process of developing a policy. One of the main reasons are the COM’s limited resources in comparison to its responsibility for the internal market and the often highly specialized and technical policy fields it is has to deal with. Although the there are recruitment schemes where experts work within the COM on a temporary basis, specialized expertise is generally a scarce resource with in the COM. <br />Therefore the COM has to make contact with outside experts and interest groups in order to assess the empirical realties (= the different perceptions ) of the societal problem at hand. This can be done in a variety of ways, such as genuine research approaches, information requests, or informal/personal contacts. However the more concrete a policy proposal gets the more relevant is the process of communication with stakeholders. The interaction between both sides becomes most visible if a public consultation is launched and stakeholders are called upon to respond to questions/statements in a consultation document. <br />A directory of ongoing and closed consultations can be found on the following webpage:<br /><br /><a href="http://ec.europa.eu/yourvoice/consultations/index_en.htm">Your Voice in Europe - Home - Consultations</a><br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1160318101705438952006-10-08T15:45:00.000+02:002006-10-08T16:40:35.353+02:00company interests and discursive policy makingIn an interview with a Brussels-based representative of a leading energy company, we discussed several important aspects of the communication process that links private interests and the COM.<br /><br />In general he stressed the importance of Eurogroups that is European industry associations that are in direct contact with EU institutions. Those organisations function as communication platform on which a wide range of relevant contacts are cultivated and maintained. Eurogroups have multilingual staffs that make contacts especially to MEPs easier to develop; long standing experiences are also an important asset.<br />With respect to the specific policy area, where his company has vested interests, a cooperative working relationship has been established. Industry organises informal working groups to which policy officers from the COM are invited. The working groups serve as informal discussion forums where ideas can be discussed freely and opinions openly expressed. Invitations are personalized, no substitutes are allowed which makes the working group a trust based informal working relationships.<br />Since such relationships depend on personal contacts, it is important to nurture the relationship with COM officials, which includes the continuation of contacts even if an official is transferred to another post. In order to get the most out of the working group meetings it is also important be aware of the developments in the COM. Thus, one needs a network of personal contacts the build-up of which takes at least 12 months. <br />However, because those working groups are a permanent institution, there are no official COM publications that contain surprises for stakeholders. Policy proposals and political initiatives are effectively developed in dialogue between both sides. The subject of the cooperation is the “factual core” of a given policy. <br />In the light of our inquiry, this constitutes evidence that the development of a common understanding of a societal problem is an essential aspect of the process ob interest intermediation in the EU.<br />Another important hint toward the nature of this process can be drawn from his assertion that there are policy trends that need to be taken into account if the particular interests are to be advances in those communicative networks of actors. He mentioned the concept of “security of energy supplies” as a recent case in the point that constitutes a new frame under which particular interests have to be redefined and communicated. Such a redefinition of company interests can even reflect back into the company and raise the awareness for new possible business opportunities.<br />Hence, under the theoretical lens, the question arises how a companies particular interests are defined vis-à-vis the policy making process in the EU.<br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1160245200586402982006-10-07T20:19:00.000+02:002006-10-07T22:07:23.033+02:00black box and source of informationFor stakeholders the COM represents both a black box and a vital source of information. For representatives in Brussels the knowledge what the COM plans is a basic resource and since, especially with respect to future activities, it resembles a black box, some kind of an early alert is important to reduce the structural uncertainty of this situation. <br />Early alerts can be retrieved through personal contact and working relationships with officials. Because the question of how those contacts can be established is the subject of another <a href="http://lobbyeu.blogspot.com/2006_04_01_lobbyeu_archive.html">post</a>, we can here ask: What is the value of such an early alert?<br />First of all, retrieved from a personal contact the alert equals preliminary information on the internal policy agenda in the COM. The reliability of such information depends on the quality of the personal contact. Assuming that it is sufficiently reliable, the fact that it is early gives an actor a competitive edge to form an opinion and to develop a position toward a policy proposal. This value diminishes if the preliminary information is widely circulated among actors who are affected by the proposal. Early alert information is therefore not regularly shared among actors. <br />It is also important to note, that generally an existing interest in the subject is an perquisite for a early alert. Either an actor knows what to ask for or – more likely – a commission official know what a contact is interested in and offers information “that might be of interest to you”. Which then leads to the question, what benefits are in for an officials that distributes information?<br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1159043722341969892006-09-23T21:57:00.000+02:002006-09-23T22:35:22.373+02:00discursive politics and the role of politicians I<p class="MsoNormal" style="margin-bottom: 12pt;"><span style="" lang="EN-GB">Politics is a discursive process. At its heart the process consists of actors in the political system who take up problems/ issues, which are dealt with in other subsystems such as the economy, and frame it as a <i>political</i> problem. In doing so, a political debate is launched in which the political problem is discussed, or to be more precise, solutions for the political problem are discussed. Since a politician can only to a certain extend control the progress of such a debate, and is most probably not an expert, who can propose a solution for the problem, taking part in the debate is a politicians main interest. Given his role in determine the political systems response to the political problem the primary concern of taking part in the debate is worrying for anyone who is affected by the <i>societal</i> problems implication and would like to have it fixed asap. This is all the more relevant if we take into account the fact that there are usually more than one proposed solutions to a political problem. Each of the solutions might be favoured by different actors who may or may not themselves take part in the political debate.<br /><br /></span>Recap:<o:p></o:p></p> <ul type="disc"><li class="MsoNormal" style=""><span style="" lang="EN-GB">Politicians frame political problems in order to debate a solution<o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">A politicians main concern is to take part in such a debate<o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">Affected actors would like the problem solved <o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">There are more than one solutions to a given problem, and those solutions have different effects for actors<o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">Politicians are in charge of choosing a solution</span></li></ul><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1157311489548418102006-09-03T21:17:00.000+02:002006-09-03T21:27:46.160+02:00a response, part III / ETI<div class="Section1"> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">Response to the “European Transparency Initiative” as presented by the European Commission on May 3, 2006 <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">Response to Section II “Transparency and Interest Representation (Lobbying)”<br /> <o:p></o:p></span></b></p> <p class="MsoToc1" style=""><!--[if supportFields]><span lang="EN-GB" style="'mso-ansi-language:EN-GB';font-size:10.0pt;"><span style="'mso-element:field-begin'"></span><span style="'mso-spacerun:yes'"> </span>TOC \o "1-3" \h \z \u <span style="'mso-element:field-separator'"></span></span><![endif]--><span class="MsoHyperlink"><span style="" lang="EN-US"><a href="#_Toc145081317"><span style="" lang="EN-GB"></span></a></span></span></p>Question 3<br />Question 4<br />Final Recommendation<br /><br /><br /><p class="MsoToc1" style=""><span class="MsoHyperlink"><span style="" lang="EN-US"><a href="#_Toc145081319"><span style="" lang="EN-GB"></span><span style="display: none; text-decoration: none;color:#000000;" ><span style="">. </span></span><!--[if supportFields]><span style="'display:none;mso-hide:screen;text-decoration:none;color:windowtext;"><span style="'mso-element:field-begin'"></span></span><span style="'display:none;mso-hide:screen;text-decoration:none;color:windowtext;"> PAGEREF _Toc145081319 \h </span><span style="';color:windowtext;"><span style="'mso-element:field-separator'"></span></span><![endif]--><span style="display: none; text-decoration: none;color:#000000;" >4</span><span style="display: none; text-decoration: none;color:#000000;" ><!--[if gte mso 9]><xml> <w:data>08D0C9EA79F9BACE118C8200AA004BA90B02000000080000000E0000005F0054006F0063003100340035003000380031003300310039000000</w:data> </xml><![endif]--></span><!--[if supportFields]><span style="';color:windowtext;"><span style="'mso-element:field-end'"></span></span><![endif]--></a></span></span><span style=""><o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><!--[if supportFields]><span lang="EN-GB" style="'mso-ansi-language:EN-GB';font-size:10.0pt;"><span style="'mso-element:field-end'"></span></span><![endif]--><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><a name="_Toc145081317"><b style=""><span style="" lang="EN-GB">Question 3</span></b></a><b style=""><span style="" lang="EN-GB"> <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><i style=""><span style="" lang="EN-GB">Do you agree to consolidate the existing codes of conduct with a set of common requirements? Who do you think should write the code?<o:p></o:p></span></i></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Reviewing the current situation of the various “codes of conduct” adopted by umbrella organisations of professionals in Brussels, the Green Paper states that: <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Up to now no cases of misdemeanour have been reported in the context of these voluntary codes of conduct. Another important point to note is that only consultants adhere to such codes. Neither lobbyists who are permanent employees of interest groups nor other groups of interest representatives who occasionally engage in lobbying activities (e.g. law firms and think-tanks) fall within the scope of such voluntary codes of conduct. Compared to the whole lobbying community in Brussels, the coverage of the voluntary codes has consequently been limited. Furthermore, as the current system relies on self-discipline it appears necessary to consolidate the existing codes and put in place a common enforcement and sanction system trusted by all. This could include a common code of conduct, applicable to all lobbyists, monitored by a special umbrella organisation and possibly coupled with a Commission-led registration system. It has also been suggested that the EU institutions should be willing to impose formal sanctions on any lobbyist breaking the code of conduct.<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Since a registration system needs to encompass all actors involved in lobbying the European institutions its inherent principles for consultation and participation are the basis upon which a common set of minimum requirements has to be built. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Because the participation of civil society in decision-making processes delivers mutual benefits to all participants, <b style="">we </b>agree that it is an important task to formulate those principles and minimum requirements in the format of a common code of ethics. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Such a code of ethics would equally apply to all actors involved. It should on the one hand relate to staff regulations within the institutions and on the other hand to codes of conduct of the respective associations or umbrella organisations. <o:p></o:p></span></p> </div> <span style=";font-family:";font-size:12;" lang="EN-GB" > </span> <div class="Section2"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">The process used to develop a common code is as important as the code itself. A review of the codes developed by the different professional societies (AALEP<b style="">,</b> SEAP, EPACA) <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">could be as useful as a summary of requirements derived from staff regulations and consultation principles to provide a starting point. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A committee of practitioners from all sides should then be summoned to formulate a common code of ethics which in turn could then be incorporated into the different codes of conduct. A distinction between code of ethics and codes of conduct is of major importance, because the overall ethical principles of the collaboration between institutions and civil society need to be uniformly accepted. While codes of conduct, although to be written within the guidelines of the code of ethic, may be specified and tailored to serve different groups of actors who might have a different self-conception of their respective role in the process. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Such a code of conduct should in our view among other things demand that lobbyists: <o:p></o:p></span></p> <ul style="margin-top: 0cm;" type="square"> <li class="MsoNormal" style=""><span style="" lang="EN-GB">specify the identity of his/her clients and the goal of their actions to the EU public office holder; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">do not encourage an EU public office holder to disobey the rules of conduct he/she is<u1:p></u1:p> expected to observe; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">avoid putting undue (exaggerated, abusive) pressure on an EU public office holder; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">ensure the accuracy and validity of the information given; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">respect the public’s right to have correct information in any of its communication aimed<u1:p></u1:p> at influencing public opinion; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">avoid making false or misleading statements to an EU public office holder or lead<u1:p></u1:p> </span><span lang="EN-GB" style="font-size:7;"><span style=""> </span></span><span style="" lang="EN-GB">anyone into error or purpose; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">take the public interest into account when making statements; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">act with professionalism, honesty and integrity; <u1:p></u1:p><o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">avoid placing himself/herself in a conflict of interest or representing clients with<u1:p></u1:p> <o:p></o:p></span></li><li class="MsoNormal" style=""><span style="" lang="EN-GB">competing or divergent interests without the permission of the people whose interests<u1:p></u1:p> </span><span lang="EN-GB" style="font-size:7;"><span style=""> </span></span><span style="" lang="EN-GB">are at stake;<o:p></o:p></span></li> </ul> </div> <div class="Section3"> </div> <span style=";font-family:";font-size:12;" lang="EN-GB" ><br /></span> <div class="Section4"> <p class="MsoNormal" style="text-align: justify;"><a name="_Toc145081318"><b style=""><span style="" lang="EN-GB">Question 4<br /></span></b></a><b style=""><span style="" lang="EN-GB"> <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><i style=""><span style="" lang="EN-GB">Do you agree that a new inclusive external watchdog is needed to monitor compliance and that sanctions should be applied for any breach of the code?<o:p></o:p></span></i></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p><br /></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">With regard to <b style="">our</b> views on question 3, the answer to questions 4 needs to be qualified. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">First of all, for a code of ethics, monitoring compliance is difficult since un-ethical actions are not necessarily apparent. Furthermore, the proposed code of ethics serves as an overall ethical standard for all conduct and therefore for the different codes of conduct of different groups of actors and stakeholders. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Thus a distinction is needed: <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">1. Compliance with the code of ethics… <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">…needs to be “monitored” by each and every person involved on either side of civil society consultation and participation in the political process of the European Union. In cases of unethical behaviour sanctions can only be applied by a process of “naming and shaming”. Since his or her reputation is the prime asset for each lobbyist, such a sanction mechanism is sufficient and may be strengthened by the establishment of a pillory. The pillory should be governed by an impartial and independent authority, which ensures that denunciations are only published if a complainant reveals his/her identity. The same would also apply for officials, who might face press coverage as well. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">2. Compliance with the provisions of the registration system… <o:p></o:p></span></b></p> </div> <b style=""><span style=";font-family:";font-size:12;" lang="EN-GB" > </span></b> <div class="Section5"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">…needs to be monitored by the management authority of the registration system according to applicable regulations and connected services. Sanctions need to be defined by the institutions which use the registration system. Enforcement of sanctions also depends on the service and/or right which is granted upon registering and thus can only be done by the respective institution. A close cooperation between the institutions and the managing authority is therefore needed. Albeit, sanctions can only be enforced by the institution affected by the violation of the provisions. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">3. Compliance with the code of conduct of a certain group… <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">…needs to be monitored by the respective group itself. Within the proposed framework, self-regulatory system of monitoring and sanctioning are sufficient. The code of ethics and the registration system provide for a sufficient behavioural corset for anyone who wants to be a reliable and responsible participant in the political process. Group-based codes of conduct thus are of great importance for the self-conception of different groups so that monitoring and credible enforcement mechanisms are in their own self interest. In addition groups should be encouraged to document their rules and procedures for public scrutiny and comparison in a common location, such as the online registration database or a related webpage run by its management authority. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">In addition to the hitherto stated views, <b style="">we</b> would strongly support the constitution of a new impartial independent and non-profit organisation committed to enhance transparency and democracy. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">As mentioned in the introduction, <b style="">we</b> regard the <b style="">“European Transparency</b> <b style="">Initiative”</b> as a valuable starting point to improve the public image of our profession. But it is just that – a beginning.<o:p></o:p></span></p> </div> <span style=";font-family:";font-size:12;" lang="EN-GB" > </span> <div class="Section6"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">To expect the Commission to be able to solve this important problem borders on wishful thinking. How can the actors involved with representing interests raise the public perception of their business solely by being subjected to governmental regulations? <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">As valuable as the current discussions among stakeholders are now is the time to go one step further. Whatever the results of the consultation and indeed what the ETI will look like in a few years, there is a clear need for something lasting and firmly based within the European civil society: an impartial independent non-profit organisation committed to enhance transparency and democracy in the European Union. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">We therefore urge every citizen committed to legitimacy of interest representation toward political institutions and the transparency of the political process to join our effort to establish a <b style="">European Foundation for Transparency and Democracy (EFTD).</b> And we call upon the stakeholders to support the EFTD in its endeavour to <o:p></o:p></span></p> <ul style="margin-top: 0cm;" type="square"><li class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">support the European integration process by raising awareness for its uniqueness and complexity; <o:p></o:p></span></li><li class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">serve the European citizens by advancing the knowledge about governance structures and processes on the European level; <o:p></o:p></span></li><li class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">establish a civil society Foundation from citizens for citizens, independent from the EU institutions; <o:p></o:p></span></li><li class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">build a permanent body to address issues of transparency in the EU in an impartial independent manner for European citizens. <o:p></o:p></span></li></ul> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">The EFTD’s activities should be underwritten by donations and endorsed by the European institutions. One of the first activities of the EFTD should be the launch its web page as a multi-lingual portal serving as a gateway for anyone who seeks information about lobbying in the European Union. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Initially the portal should pursue a two-tier approach: directory & information portal. It should serve as premier of source of information about EU-level interest mediation written by scientists, practitioners and stakeholders, all of which will be subjected to an open system of peer-review via a forum application. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">The directory should contain a structured overview and short abstracts for the large amount of web resources of information concerning the process of interest mediation in the EU, both from within and outside the EU institutions.<o:p></o:p></span></p> </div> <span style=";font-family:";font-size:12;" lang="EN-GB" > </span> <div class="Section7"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><a name="_Toc145081319"><b style=""><span style="" lang="EN-GB">Final Recommendation</span></b></a><b style=""><span style="" lang="EN-GB"> <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Lobbying activities should be public, transparent and, above all disclosed in a central register. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">We do not see any problem in opening up the activities of lobbyists to public scrutiny. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A coherent multilevel regulatory framework can serve as a guide to lobbying for citizens and citizens groups, thus contributing - as a real catalyst – to opening up and broadening access to law-makers. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">We recommend an approach which sees regulation as the beginning of a process which will help to reinvigorate democracy to the extent that it widens participation and demystifies commercial lobbying activity. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A centralized register would provide a public record of information about people and organisations shaping public policy at EU level. At present, the principles of openness and transparency that the European Institutions embrace lack a coherent concrete form and the present registers and databases are insufficient. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A register of lobbyists and their clients would be a very effective way of auditing the activities of outside interests who seek to influence policy making. One of the recurrent problems in trying to understand the nature and scope of lobbying activity has been the absence of any reliable data on what lobbyists actually do, and what resources are devoted to influencing policy. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">The drawbacks of regulations are, in our opinion, more imagined than real. There is evidence from the United States and Canada that registration systems can be administered easily and efficiently, especially in electronic form, which has the advantage of being relatively cheap and accessible. There certainly is a concern in some places (such as the US) that the systems of regulation in place are subject to loopholes and that corporations and lobbyists have found ways to get round them. In our view this is only an argument for having more, not less, effective regulation. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">For a central registration scheme to have the full confidence of the public, the European Parliament, and the lobbying community, it should be administered by an independent authority such as the European Ombudsman. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">The fundamental issue at stake here is the question of our democracy and how it operates. That democracy must be seen to be transparent and open and anyone who wishes to discover the identity of a person lobbying in favour or against should be able to do so by consulting the register of lobbyists. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Lobbying is a good aspect of the political process and it must be regulated. Unfortunately the Commission Green Paper shows only inconclusive commitment to introduce real legislation in this area. In all professions people do their business openly and they are subject to regulation. Part and parcel of the development of any profession is that it goes down the path of regulation. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">We are not advocating draconian measures to demonise or penalise people engaged in the lobbying profession nor are we proposing burdensome bureaucratic measures. What we are proposing is to put in place structures and principles of conduct. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Professional lobbyists have nothing to fear about revealing who they are, whom they represent and why they are lobbying. It is after all both in the public interest and for the future development of the profession.<o:p></o:p></span></p> </div> <span style=";font-family:";font-size:12;" lang="EN-GB" > </span> <div class="Section8"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">List of signatories<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> </div> <span style=";font-family:";font-size:12;" lang="EN-GB" ><br /></span> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB"><o:p> </o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB"><o:p> </o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1157311011859853362006-09-03T21:14:00.000+02:002006-09-03T21:16:51.873+02:00a response, part II / ETI<div class="Section1"> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">Response to the “European Transparency Initiative” as presented by the European Commission on May 3, 2006 <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">Response to Section II “Transparency and Interest Representation (Lobbying)” <o:p></o:p></span></b></p><!--[if supportFields]><span lang="EN-GB" style="'font-size:10.0pt;mso-ansi-language:EN-GB'"><span style="'mso-element:field-end'"></span></span><![endif]--><span style="" lang="EN-GB"><o:p></o:p></span> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB"><o:p> </o:p></span></b><br /><a name="_Toc145080030"><b style=""><span style="" lang="EN-GB">Question 2</span></b></a><b style=""><span style="" lang="EN-GB"></span></b></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB"><o:p></o:p></span></b><br /><i style=""><span style="" lang="EN-GB">Do you agree that lobbyists who wish to be automatically alerted to consultations by the EU institutions should register and provide information, including on their objectives, financial situation and on the interests they represent? Do you agree that this information should be made available to the general public? Who do you think should manage the register?<o:p></o:p></span></i></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p><p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">In order to achieve “effective and proportionate” measures in the field of transparency <b style="">we </b>consider a registrations system as an indispensable tool. However, since such a system is aimed to (1) provide transparency for European citizens of a (2) highly sophisticated sector of policy experts working on very specific topics, a consultation alert service seems to be an inadequate incentive. Anyone who is an expert working in a policy field certainly doesn’t need to be alerted to a consultation published on <b style="">“Your Voice in</b> <b style="">Europe”</b> while interested citizens already appreciate the alert service offered in order to keep track of policy developments in the European Union. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A register therefore poses the important question <b style="">“How to get people to register”.</b> According to the Commission’s proposal there would be: <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A voluntary registration system, run by the Commission, with clear incentives for lobbyists to register. The register would include automatic alerts of consultations on issues of known interest to the lobbyists.<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">The question is: <b style="">Can a voluntary registration system do the job? <o:p></o:p></b></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">To consider whether such a system can or cannot do the job requires a clear understanding of what the job is, as well as how existing registration systems work. The European Commission states the following as an essential component of a basic framework of understanding of the relation between EU institutions and lobbyists. <o:p></o:p></span></p> </div> <span style="font-size: 12pt; font-family: "Times New Roman";" lang="EN-GB"> </span> <div class="Section2"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">When lobby groups seek to contribute to EU policy development, it must be clear to the general public which input they provide to the European institutions. It must be clear also who they represent, what their mission is and how they are funded.<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">It follows that the question of which information must be provided in a registration system is probably more important than the question as to which incentives are used to get people to register. Secondly aiming at enhancing transparency in lobbying means that a registration system is not a goal in itself, whether it is compulsory or not. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Therefore a legitimate public interests of transparency needs to be balanced with a legitimate right of privacy for stakeholders. Certainly those considerations may be addressed with carefully worded information requirements. But even unfounded criticism toward built-in loopholes will undermine the purpose of the registration system. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A lasting assessment of which information need to be provide for the general public needs to be based on the Commission own requirements. By setting itself high standards of transparency in decision-making each Commission official has legitimate needs to know who is representing which interests. Those needs should be met in a registration system as a minimum requirement of information. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">In order to keep such a registration system updated, each time a stakeholder participates in a consultation the information given should be reconfirmed and/or updated if necessary. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">More importantly, since the registration system and its information requirements result from the Commission’s own commitment to transparency in policy making, it cannot be entirely voluntary to provide the respective information if one wants to participate in the political process. The responsibility of which comes with participation commands responsible stakeholders to provide the requested information. Thus a registration system would be the basis upon which access to the commission can be obtained. In turn it lies in the Commission’s own responsibility to live up to its own standards and to ensure that stakeholders are registered in a voluntary registration system. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Since the target of lobbying is for the most part the European Commission and the European Parliament, this means that we would have two registration systems: one applying to the European Commission (voluntary registration system) and another one applying to the European Parliament (non-voluntary registration system, since it is a condition for obtaining a badge)? <b style="">Do we need two distinct registration systems? <o:p></o:p></b></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Regarding the European Parliament: It is true that a register of accredited lobbyists is published on the EP website. As the Green Paper remarks it is simply an alphabetical list and it provides only the names of the badge holders and of the organisations they represent. It gives no indication of the interests for which a lobbyist is acting. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">It is our view that one registration system should cover <b style="">ALL</b> European institutions as well as <b style="">ALL</b> actors involved in lobbying those institutions. Therefore an encompassing registration system, combining the CONNECS database approach and the accreditation system of the European Parliament, is the only credible option. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A central registration system would provide for a number of advantages: Stakeholders and officials alike would have an important information resource, to say the least. And it could provide the public with important information about the political process and increase public confidence in the EU institutions. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Moreover, an encompassing registration database does not mean every entry carries the same amount of information, nor does it mean that every information is needed from each person or organisation registered. Information provided would relate to a specific purpose, e.g. obtaining an entry badge for the Parliament building, submitting a contribution to consultation, etc. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Objections to a statutory register of outside interests tend to focus on the difficulty in defining lobbyists and the impracticality of maintaining a register of outside interests. If a statutory register of lobbyists includes all those who lobby, then the difficulty of distinguishing between different types of lobbyists (commercial consultants, in-house corporate, civil society, voluntary sector) becomes less problematic. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">There is also evidence that these systems are practicable and they can make important information available to the public cheaply and effectively by electronic information gathering, storage and retrieval, providing easy access to all who wish it. It is inaccurate to claim that all statutory regulation is cumbersome and ineffective. In fact compared to the current situation of different databases and the need to state information over and over again, a central registration system can be expected to simplify the life of stakeholders. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">A central registration system with a reachable and comprehensible user-friendly online database would help to improve the transparency of governance and accessibility of the EU institutions. But a registration system is not a panacea for all problems stated in the Green Paper. It is only the first step in ensuring sound standards in public life. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Given the importance of a registration system for the European institutions the question who should manage it is very important. Since it provides a dual-use function with offering valuable information for the institutions and the public, reliability and impartiality are the most important management principles. The information gathered and provided needs to be accurately stored and traceably logged so that changes and developments can be followed.<o:p></o:p></span></p> </div> <span style="font-size: 12pt; font-family: "Times New Roman";" lang="EN-GB"></span> <div class="Section3"><p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">In order to guarantee the usability for the European Parliament and the European Commission a certain level of collaboration between both branches of the European polity is needed. Because the primary function of the registration system is to grant access to the decision-making processes on the European level the trust of citizens in the impartiality of a managing body is also needed. How should a governmental institution regulate the access to itself and building up the citizens trust? <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Therefore a compromise needs to be found in order to allocate the management authority to neither of the two institutions themselves, but to a third one which enjoys the confidence of both the public and the institutions. We would endorse the installation of an independent managing body installed under the auspices of the European Ombudsman. <o:p></o:p></span></p> </div> <span style="font-size: 12pt; font-family: "Times New Roman";" lang="EN-GB"><br /><blockquote></blockquote><br /> </span><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1157310836420906012006-09-01T20:59:00.000+02:002006-09-03T21:28:24.640+02:00a response, part I / ETIAs you know the European Commission held a <a href="http://ec.europa.eu/comm/eti/index_en.htm">public consultation</a> on its European Transparency Initiative (ETI), which has been open until the end of August. Although I wasn't interested in participating in the consultation myself, I worked together with a friend of mine to draft a response to the questions tabled in the <a href="http://ec.europa.eu/comm/eti/docs/gp_en.pdf">green paper</a>.<br />We answered only the four questions in section II of the green paper and included some preliminary remarks before doing so:<br /><br /><div class="Section1"> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">Response to the “European Transparency Initiative” as presented by the European Commission on May 3, 2006</span></b><br /><span style="" lang="EN-GB"><o:p></o:p></span><br /><b style=""><span style="" lang="EN-GB">Response to Section II “Transparency and Interest Representation (Lobbying)” <o:p></o:p></span></b></p> <p class="MsoToc1" style=""><span style="" lang="EN-GB"><o:p></o:p></span><br /><!--[if supportFields]><span lang="EN-GB" style="'mso-ansi-language:EN-GB';font-size:10.0pt;"><span style="'mso-element:field-begin'"></span><span style="'mso-spacerun:yes'"> </span>TOC \o "1-3" \h \z \u <span style="'mso-element:field-separator'"></span></span><![endif]--><span style="font-style: italic;" class="MsoHyperlink"><span lang="EN-US" style="font-size:10;"><a href="#_Toc145080028"><span style="" lang="EN-GB"></span></a></span></span></p>Preliminary remarks<br />Question 1<p class="MsoToc1" style=""><span style="font-style: italic;" class="MsoHyperlink"><span lang="EN-US" style="font-size:10;"><a href="#_Toc145080029"><span style="" lang="EN-GB"></span><span style="display: none; text-decoration: none; color: rgb(0, 0, 0);"><span style="">. </span></span><!--[if supportFields]><span style="'display:none;mso-hide:screen;text-decoration:none;color:windowtext;"><span style="'mso-element:field-begin'"></span></span><span style="'display:none;mso-hide:screen;text-decoration:none;color:windowtext;"> PAGEREF _Toc145080029 \h </span><span style="';color:windowtext;"><span style="'mso-element:field-separator'"></span></span><![endif]--><span style="display: none; text-decoration: none; color: rgb(0, 0, 0);">2</span><span style="display: none; text-decoration: none; color: rgb(0, 0, 0);"><!--[if gte mso 9]><xml> <w:data>08D0C9EA79F9BACE118C8200AA004BA90B02000000080000000E0000005F0054006F0063003100340035003000380030003000320039000000</w:data> </xml><![endif]--></span><!--[if supportFields]><span style="';color:windowtext;"><span style="'mso-element:field-end'"></span></span><![endif]--></a></span></span><span style="font-size:10;"><o:p></o:p></span></p><!--[if supportFields]><span lang="EN-GB" style="'mso-ansi-language:EN-GB';font-size:10.0pt;"><span style="'mso-element:field-end'"></span></span><![endif]--><span style="" lang="EN-GB"><o:p></o:p></span> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span><br /><a name="_Toc145080028"><b style=""><span style="" lang="EN-GB">Preliminary remarks</span></b></a><b style=""><span style="" lang="EN-GB"> <o:p></o:p></span></b><br /><span style="" lang="EN-GB"><o:p></o:p><br />In the introduction to its Green Paper the European Commission stresses its commitment to the participation of civil society organisations and stakeholders in the policy process on the European level. <o:p><br /></o:p><br />With regard to the openness as one guiding principle it states that:<o:p></o:p></span></p> <p class="MsoNormal" style="margin: 0cm 30pt 0.0001pt; text-align: justify;"><span lang="EN-GB" style="font-size:10;">At the same time, the Commission has stressed the principle that “<i style="">with better</i> <i style="">involvement comes greater responsibility</i>”. Relations between the Commission and interest representatives must be open to outside scrutiny. Therefore it was considered timely to review the framework for activities of interest representatives and seek views on the need for new initiatives.<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">We</span></b><span style="" lang="EN-GB"> fully support the notion of responsibility which comes along with participation. As signatories of this position paper we strongly believe in the value of transparency.<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Despite the fact that most actors involved in the current debates increasingly emphasise the importance of interest representation for the political process, most citizens perceive it as backroom procedures illegitimately altering policies for the benefit of powerful special interests. To address this discrepancy between self-assessment and public perception, the Commission’s effort to regulate its relationship with interest groups can be a helpful exercise and ought to be supported. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">As signatories of this position paper we agree upon the following basic views with regard to the subject of the Green Paper:<o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">1. <b style="">We</b> strongly believe in the legitimacy of lobbying and its impossible dissociation from the democratic process. Trying to influence the content of EU public policies or attempting to gain advantages from an established EU programme is a fundamental right based upon two basic EU freedoms: freedom of speech and freedom of association. <o:p></o:p></span></p> </div> <span style="" lang="EN-GB"></span> <div class="Section2"><p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">2. <b style="">We </b>strongly believe that for the sake of transparency <b style="">ALL</b> lobbying organisations (lobbying- public affairs consultants, management consultants and accountants, lawyers, NGOs, think tanks, corporate and trade associations) trying to influence EU policy makers and the content of EU public policies must be treated on an equal footing. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">3<b style="">. We</b> accept that people have a right to know who is talking to policy makers and which organisations and individuals consider themselves stakeholders in a certain policy domain. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">4. <b style="">We </b>would support the European Commission in an effort to extend the principles and rules of conduct under which its own staff works with other participants in the policy formulation and decision-making processes, notably those for the purpose of the Green Paper defined lobbyists. <o:p></o:p></span></p> </div> <span style="" lang="EN-GB"> </span> <div class="Section3"> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p><br /></o:p></span></p><p class="MsoNormal" style="text-align: justify;"><a name="_Toc145080029"><b style=""><span style="" lang="EN-GB">Question 1</span></b></a><b style=""><span style="" lang="EN-GB"> <o:p></o:p></span></b></p> <p class="MsoNormal" style="text-align: justify;"><i style=""><span style="" lang="EN-GB">Do you agree that efforts should be made to bring greater transparency to lobbying?<o:p></o:p></span></i></p><p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><o:p> </o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><b style=""><span style="" lang="EN-GB">Yes.</span></b><span style="" lang="EN-GB"> A higher level of transparency will be beneficial for both the political process and the profession. The <b style="">European Transparency Initiative</b> points toward the right direction for it is the complexity and distance between Brussels and European citizens which lies at the heart of alienation and unfounded anxiety towards the EU. <o:p></o:p></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB">Therefore while one has to applaud the Commission for emphasising the already achieved transparency of governance, existing measures need to be fine-tuned in order to draw the curtain for the often misinterpreted process of lobbying the European institutions.<br /></span></p> <p class="MsoNormal" style="text-align: justify;"><span style="" lang="EN-GB"><br /><o:p></o:p></span></p> </div> <span style="" lang="EN-GB"> </span><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1155236807356522212006-08-10T21:06:00.000+02:002006-08-10T21:27:38.013+02:00policy networks bibliographyA bibliography with policy networks literature. Prepared by Mariangela Petrizzo. Thank You!<br /><br /><blockquote><a href="http://www.insna.org/INSNA/PNBIbliography.htm">Bibliografia sobre Policy Networks / Policy Networks Bibliography</a>: "by Mariangela Petrizzo"</blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1154989863944701342006-08-08T00:31:00.000+02:002006-08-08T00:34:50.026+02:00policy frames v. interestsPolicy frames and interests - both terms are interrelated. Policy frames are the reflection of a particular interest in terms of an action justification. <br />If political problems are dealt with in societies, different view points (= interest regarding an issue/question) compete with each other. The competition takes place in form of different/conflicting action formulas prescribed by interested parties in order to solve/deal with the problem. In order to justify the viability of a certain action formula a convincing story is needed as to convince others that the action formula ought to be applied. To be convincing, such a justification story needs to take the context and other perspectives on the problem into account. Thus, a policy frame is needed as a quasi connection of ones particular interest with other interests related to the problem in question.<br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1153081150565795792006-07-16T22:19:00.000+02:002006-07-16T22:36:55.083+02:00Frame AnalysisThis webpage offers a very concise introduction into the main areas of research where frames and frame analysis' are used.<br /><br /><blockquote></blockquote><a href="http://www.lboro.ac.uk/research/mmethods/resources/links/frames.html">Frame Analysis</a><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1160321661661488252006-07-08T17:33:00.000+02:002006-10-08T17:34:21.680+02:00An insider’s perspectiveIf one wants to know more about communications processes and independencies, well-informed journalist are vital source of information for a researcher. I am fortunate to have had the chance to discuss the issues followed in this blog with one of the most knowledgeable journalists about lobbying in the EU, who in addition has more than 15 years of experience in Brussels.<br /><br />The EP<br /><br />In his opinion is it way to much to ask of the EP to cope with the increasingly complicated matters of EU policy making. The primary reason for this inability is the incompetence of its scientific service and the lack of specialized expertise. This leads to a situation where MEPs charged with a report depend on outside expertise to fulfil their duties. In the more established policy areas, such outside expertise is provided in form of additional staff, which is paid via consulting contracts by vested interests. Also, being a lawyer by training is beneficial for an MEP because he than in not obliged to reveal his clients. Those clients on the other hand might well be related to a burning political interest of the same MEP in particular detailed political questions. <br />Since we already know that personal contacts are important, the above assessment leads to the a reminder that contacts and connections often are based on loyalty networks and dependencies.<br /><br />The COM<br /><br />If one compares the current situation with the situation before the “Kinnock-Reforms” had been pursued, individual COM officials are nowadays more insecure. The reason is the new staff evaluation system, which presumably cripples motivation and leads to insecurity. As observed by my contact, COM officials are increasingly interested in gaining recognition outside the COM.<br />In terms of policy making, a higher dependency on allies characterizes the COMs political initiatives. This in turn increases the chances for lobbies to influence policy initiatives.<br /><br />Personal networks <br /><br />Communication networks in Brussels work on three different levels. It is not only EU-Speak, the jargon of policy people, but rather a phenomenon that may be described as triple speak. It depends on the level of knowledge a listener has, if he understands only the openly expressed jargon message or the sub-textual messages referring to the network of interests or the personal relationships concerned.<br />Especially the personal level of communication seems to be important in an environment where most of the actors are expatriates that share similar private activities, such as school for children, sport, etc. <br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1152915069399454592006-06-24T00:11:00.000+02:002006-07-15T00:15:56.116+02:00a virtual tour of the lobby capital (as they call it)There are many lobbyists, but there is also a vibrant community of lobby-critics. In terms of lobbying in the EU, the Amsterdam-based think tank Corporate Europe Observatory is probably the most active anti-lobbying organisation. A couple of weeks ago CEO launched a new web service offering the possibility to take a virtual tour thru the EU quarter in Brussels.<br /><br /><blockquote></blockquote> <a href="http://www.eulobbytours.org/tour.html">http://www.eulobbytours.org/tour.html</a> <blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-24193884.post-1152730379887268232006-06-12T20:46:00.000+02:002006-07-15T00:20:42.153+02:00a letter to lobbyists / ETIBack in February 2006 a friend of mine and I wrote a letter to a number leading actors in the Brussels lobbying circus. As you can see in the following, we tried to come up with an innovative approach to issues discussed in course of the preparation of Siim Kallas' "<a href="http://ec.europa.eu/commission_barroso/kallas/transparency_en.htm">European Transparency Initiative</a>" consultation (which is <a href="http://ec.europa.eu/comm/eti/index_en.htm">open</a> now, until Aug. 31).<br /><blockquote></blockquote><br />Proposal for a non-profit non-governmental transparency organisation for Europe<br /><span style="font-style:italic;">(06.02.2006)</span><br /><br />In recent months we’ve witnessed a growing effort on part of the Commission to address the problem of vanishing trust in the European institutions by European citizens. Triggered by the rejection of the Constitutional Treaty in France and the Netherlands a widespread uncertainty about the reasons is being matched with different attempts to improve the overall situation without forestalling a debate over the future institutional structure of the EU. Among the most prominent efforts are the Commission's Plan D, the "White Paper on a European Communication Policy" and it's European Transparency Initiative. <br /><br />While knowledge and interest in the European integration is nowadays a rather scarce resource among citizens, it seems at least questionable how debate and dialogue – as laudable the idea is – could improve the citizens’ trust in the EU. Especially communication strategies and PR efforts by the Commission will probably raise the suspicion of citizens as being subjected to a concerted whitewash operation from politicians and bureaucrats in the "space station" Brussels. <br /><br />Commissioner Kallas' European Transparency Initiative on the other hand points toward the right direction for it is the complexity and distance between Brussels and European citizens which lies at the heart of alienation and unfounded anxiety toward the EU. Therefore one has to applaud Commissioner Kallas for his courageous attempt to emphasise the already achieved transparency of governance and draw the curtain for the often misinterpreted process of lobbying the European institutions. <br /><br />Despite the fact that all actors involved unceasingly emphasise the importance of interest representation for the political process, most citizens perceive it as backroom procedures illegitimately altering policies for the benefit of powerful special interests. To address this discrepancy between self-assessment and public perception, the Commissions effort to regulate its relationship with interest groups ought to be supported. But to expect the Commission to be able to solve this important problem borders on wishful thinking. How should a governmental institution regulate the access to itself and building up the citizens trust? How would the citizens be enabled to know who represents what interests to whom if each institution has its own regulations for it? And most importantly, how can the actors involved with representing interests raise the public perception of their business by being subjected to governmental regulations?<br /><br />As valuable as the current discussions among stakeholder are - and will be once the ETI green paper has been published in mid March - now is the time to go one step further. It is likely that the Commission eventually will come to terms with a suitable solution, but will a compromise achieve the goal? Whatever the compromises will look like, there is a clear need for something lasting and firmly based within the European civil society: an impartial independent non-profit organisation committed to enhance transparency and democracy in the European Union. <br /><br />We therefore urge every citizen committed to legitimacy of interest representation toward political intuitions and the transparency of the political process to join our effort to establish the European Foundation for Transparency and Democracy (EFTD). And we call upon the stakeholders to support the EFTD in its endeavour to<br /><br />• support the European integration process by raising awareness for its uniqueness and complexity;<br /><br />• serve the European citizens by advancing the knowledge about governance structures and processes on the European level;<br /><br />• establish a civil society Foundation from citizens for citizens, independent from the EU-Institutions;<br /><br />• build a permanent body to address issues of transparency in the EU in an impartial independent manner for the public to know.<br /> <br />The EFTD’s activities will be underwritten by donations, which will be up to public scrutiny. Initially the foundation will engage in two activities: that is establishing a European Council for Transparency (ECT) and building a web portal dedicated to its cause.<br /><br />The ECT will be a publicly elected council of high-level Experts in European Affairs dedicated to improve transparency and the dialogue between organisations, institutions and EU-citizens. Consisting off scientists, representatives of European level associations, NGOs and the European civil society, the ECT is meant to encompass a well-balanced group of EU stakeholders, but neither serving MEPs nor active civil servants of EU Institutions.<br /><br />The web portal Eulobby.net will be re-launched as a multi-lingual portal serving as a gateway for anyone who seeks information about lobbying in the European Union initially pursuing a triple-play approach: directory – register – information portal. It will serve as premier source of information on EU-level interest mediation by scientists, practitioners and stakeholders, all of which will be subjected to an open system of peer-review via a forum application.<br />The eulobby.net directory will contain a structured overview and short abstracts for the large amount of web resources of information concerning the process of interest mediation in the EU, both from within and outside the EU institutions. Its register will list all institutions, groups, firms and individuals who are engaged in the legitimate process of representing special interests at the EU-level. <br /><br /><blockquote></blockquote><div class="blogger-post-footer">interest intermediation in the European Union</div>Unknownnoreply@blogger.com0