HOW CONTEXT MATTERS
Wednesday, 28 July 2004
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3. QUALITY FOR WHOM? THE ROLE OF RIA STAKEHOLDERS
This paper shows how context matters by breaking it down into four dimensions. I
define them by using the simple labels of ‘stakeholders’, ‘institutions-territory’,
‘policy process’, and ‘legitimacy’. The main point is that not only is convergence
around one notion limited, it is conceptually impossible to adopt a ‘one-size-fits-all’
approach to quality.
What is a ‘good RIA’? This is not the right question, unless one has answered the
question what do the main stakeholders want when they talk about quality of RIA?
What are the models of politicians, civil servants, firms, experts, and citizens that
provide us with their preferences in terms of quality? Quality is not the same thing for
every stakeholder. Drawing on a classic study of decision-making in international
politics, Graham Allison’s Essence of Decision (1971), Farrow and Copeland (2003)
argue that ‘RIA quality’ can be interpreted in three different (yet not mutually
exclusive) ways. They argue that there are at least three RIA stakeholders, i.e., the
‘expert’, the ‘civil servant’, and the ‘politician’. I add a fourth important stakeholder,
the ‘citizen’, and model her preferences. And, finally, a fifth important ideal-typical
stakeholder is the ‘corporate actor’ (the firm at the micro level and business
organisations at a more aggregate level).
Different stakeholders bring into RIA diverse logics, criteria, and quality assurance
mechanisms. More fundamentally, it is not clear what is the model of stakeholders
implicit in RIA programmes across the EU. Are these programmes based on the
assumption that politicians are rent-seeking - hence quality assurance mechanisms
should target this problem? Or do they make the assumption that policy-makers
regulate in the public interest, for example because they want to be re-elected and
good quality environmental regulation may increase their popularity? To what extent
do the preferences of independent agencies differ from the preferences of elected
officials and with what impact on the efficiency and credibility of impact assessment?
The literature on the political economy of regulation is vast. But one fairly common
result across several studies is that elected regulators respond to pressure groups and
Convention