Environmental Engineering Reference
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The possibility is also given to wait with consultation until there is a full draft
proposal, only applying EU's minimum standards for consultation. Although the
latter policy procedure has been the most frequently used option, at some stage the
results will always be subject to public examination. This examination will by
nature be politically as opposed to scientifically motivated.
Introduction of the IA instrument in European policy making is a helpful step to
make economic development more knowledge based and rational but economic
development is nonetheless always a struggle between conflicting interests. We are
considering here the 'adversarial model' by Hoppe (2005) , where politics is a non
violent power struggle between political parties and/or organized interest groups,
that lead to temporary compromises of the public interest (Lindblom 1968) .
The EC and its administrations are under heavy pressure from influential spheres
of power. Also scientists and the use of scientific modelling tools will be subordinate
to the political interplay, in which also scientific or other groups contributing to IAs
stand a risk of being targeted by a political critique (Bäcklund 2009) . The design of
the assessment as well as the outcome can be severely criticised on both factual and
political grounds (see, e.g. EEAC 2006 : 17). Hence, there is a need for scientists to
be aware of the political process in which they participate when consulted.
When the Commission proposes a new regulation the DG's argumentation for
the policy recommendation made in the proposal has to come across convincingly
to decision makers and the public. As it has to be explained how the assessment
results support the policy option in the proposal, officers want simplicity and
transparency in the modelling process. The models and the assumptions made have
to be understood by the policy experts. If it is not comprehensible and transparent
it is not politically useful for the administration (Bäcklund 2009) . The need for
simplification might be a source of conflict between the ambitions of a scientific
modeller and a policy expert. The core of this question concerns a 'cultural' difference
between researchers and practitioners' way of approaching a problem - especially
practitioners in highly politicised administrations. The interactions between these
cultures are therefore a main stake when developing and applying a system like
SEAMLESS-IF.
IA as a Learning Process
The aim of introducing the IA procedure is wider than to merely provide a knowledge
base for decision making. IA is introduced as a rational and better way to political
decision making but also as a tool to improve internal communication in the Union
and to restore an anticipated lack of confidence in European governance. The great
aspirations placed on the IA system as a way to achieve increased communication
and unity in European politics, to promote mutual learning between EU institutions
and Member States and help in “restoration of confidence in government” are
expressed in the Mandelkern report preceding the final IA proposal (Mandelkern
Group on Better Regulation, 2001) .
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