narrating impact assessment in the european union · 2019. 10. 21. · research narrating impact...

RESEARCH

narrating impact assessment inthe european unionclaudio m. radaelli a,*, claire a. dunlopa and oliver fritschbaDepartment of Politics and Centre for European Governance, University of Exeter, UKE-mails: [email protected]; [email protected] and Sustainability Institute, Department of Politics and Centre forEuropean Governance, University of Exeter, UKE-mail: [email protected]

*Corresponding author.

advance online publication, 10 May 2013; doi:10.1057/eps.2013.26

AbstractSince 2003, the European Commission has produced analytical documents(called Impact Assessments, IAs) to appraise its policy proposals. Thisappraisal process is the cornerstone of the regulatory reform policy of theEuropean Union. Previous research has been concerned with the quality ofthe IAs in terms of evidence-based policy, usages of economic analysisand other standards of smart regulation. Instead, we move to a differentperspective. We draw on the narrative policy framework to explore IAs as atext and discursive instrument. Conceptually, insights from discursive insti-tutionalism are used to explore narratives as tools of coordination withincomplex organizations such as the European Commission, and as commu-nicative tools through which policy-makers seek to enhance the plausibility,acceptability and, ultimately, legitimacy for their policy proposals. Empi-rically, we consider a sample of IAs that differ by originating DGs, legalinstrument, and level of saliency. The findings show that both in coordinatingand communicating policy, the European bureaucracy projects a certaindefinition of its identity via the narratives it deploys. The Commission mayuse IAs to produce evidence-based policy, but it also an active narrator. Itengages with IAs to provide a presentation of self, to establish EU norms andvalues, and to create consensus around policy proposals by using causalplots, doomsday scenarios, and narrative dramatization.

Keywords European Union; impact assessment; learning; policy narratives;regulation

Since 2003, after a decade of experi-ments with various tools of policyappraisal, the European Commissionhas used the impact assessment (IA)procedure to support the policy formulationprocess in the context of the EU’s ‘smart

european political science: 2013

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regulation’ strategy (European Commis-sion, 2010). The IA is a single templatefor the appraisal of different types of effectsof policy proposals on economic sectors,the environment, and citizens. It alsoincludes different tests on administrativeobligations and competitiveness. Draw-ing on the international experience ofusing economic analysis to appraisepolicy proposals (OECD, 2009), the Com-mission is committed to the analysis ofboth legislative and non-legislative pro-posals via a series of steps described inthe IA guidelines (see http://ec.europa.eu/governance/impact/index_en.htm).The IAs are published online whenthe accompanying proposal is formallyagreed upon by the College of Commis-sioners. The process of preparing an IAincludes problem definition, the identifi-cation of alternative feasible options,consultation, economic analysis of thepossible choices, and a final policychoice – regulatory or not. For example,the IA may well conclude that a code ofconduct is better than a directive.The template for IA1 is designed by

the Secretariat General, which also has acoordinating role in individual appraisalprocesses. The Impact Assessment Board(IAB) is a regulatory oversight body. Itsmembers are high-level officers from keyDirectorate Generals appointed in theirpersonal capacity. It is chaired by theDeputy Secretary General.Previous research has shown that IAs

and regulatory oversight are relativelywell-embedded in the EU policy formu-lation (Alemanno, 2008; Allio, 2008;Radaelli and Meuwese, 2010). The IA ofthe Commission draws on European andNorth-American experience with regula-tory appraisal. Yet it is distinctive in twoways (Meuwese, 2008). First, it considersthe social and environmental dimen-sions alongside the economic dimensionof policy proposals, while other systemsare eminently concerned with one dimen-sion, typically the economic effects or

sustainability. Second, there is no a prioripreference for cost-benefit analysis (CBA)as the main method used to carry outeconomic analysis.

The literature on IAs in the EU,and more generally in Europe, is a grow-ing field, and two systematic reviewsare available (Turnpenny et al, 2009;Adelle et al, 2012), together with ameta-analysis of a sample of cases drawnboth from the EU and the UK (Dunlopet al, 2012). Extant literature has dis-cussed how the Commission handles theappraisal procedure in the context ofindividual policy sectors, showing whenand how the officers deviate from theirguidelines and benefit-cost principles(Torriti, 2010). The regulatory oversightdimension of the phenomenon is parti-cularly important for its implications forthe political control of the bureaucracy:on this the EU studies have connectedwith a large body of literature deve-loped in the US on IAs as a control tool(Alemanno, 2011; Radaelli, 2010).

However, most of this literature is limi-ted to two types of research questions:first, the governance characteristics ofIAs, including who uses it and for whatpurpose (Nilsson et al, 2008; Radaelli,2010); and, second, the trends in thetypes of tests and analyses contained inthe IAs (Renda, 2006; Cecot et al, 2008;Fritsch et al, forthcoming). Thus, weknow a good deal about how the assess-ments of the Commission differ fromtheir North American counterparts andthe role they play in evidence-basedpolicy as well as in oversight policies.But IAs are also an important step inlegitimizing policy proposals. Here, wefocus on this step by conceptualizing IAs

‘yIAs are also animportant step inlegitimizing policy

proposals’.

european political science: 2013 narrating impact assessment in the european union2

as a script containing arguments usedto justify a given definition of the policyproblem and EU regulatory intervention.These arguments typically follow a narra-tive arc2: They present a problem andshow how the situation will substantiallyimprove, thanks to the initiative sug-gested by the Commission.This leads us to a different perspective.

We look at the narrative structure ratherthan checking on the type and quality ofeconomic analysis or testing hypothesesabout how economics is used by regu-lators (on the latter, see also Schrefler,2010). To be clear, this is an exploratoryenterprise and so, at a very basic level,we are agnostic about the presence orabsence of narratives and ask a simpleset of questions: Is the Commissiona narrator when performing IAs? If so,what type of narrator is it? For exam-ple, do we find variability across theCommission or in relation to issue char-acteristics? By looking at the narrativestructure and content of individual IAs,we explore narratives as tools of advo-cacy as well as inquiry (echoing Toulminet al, 1984: 7).In his review of ‘Theories of the Policy

Process’ for the Public Policy Yearbook2011, Nowlin (2011) puts the NarrativePolicy Framework (NPF) at the top ofhis section on ‘emerging trends’. Theclassic claim of the NPF is thatpublic policy has a narrative struc-ture. In turn, narratives have causaleffects: they categorize or frame an issuein a peculiar way; they direct actiontowards certain actions; they expandthe scope and tasks of the organiza-tion that dominates the narrative; theycreate conflict-resolution pathways vianarrative synthesis and frame-reflection;and finally they reverberate in publicopinion, linking public policy to collectiveperceptions (Roe, 1994; Jones andMcBeth, 2010; Shanahan et al, 2011).Previous researched has demonstratedthat a narrative approach sheds light

on how power and legitimacy for theCommission’s intervention are generatedin EU public policy (Radaelli, 1999).

Briefly, over the years narrative ana-lysis has become one of the recognizedmodes of social scientific enquiry in EUpublic policy studies. Although narra-tive analysis does not present particularproblems to EU scholars, we need toclarify its epistemological and ontologicalstatus – because on these issues thecommunity of researchers is still divi-ded. Indeed, narrative analysis has oftenbeen associated with post-empiricalepistemologies of varying nature. Yet,Nowlin argues, NPF authors such as Jonesand McBeth (2010) have shown thatan interest in the narrative structureof public policy can also contribute tothe more established effort to ‘empiri-cally measure how policy relevant infor-mation is transmitted and interpretedby both policy elites and the masspublic’ (2011: 53, our emphasis). Indeed,narrative policy analysis can and shouldbe reclaimed by political scientists thatdo not subscribe to post-modernism,post-structuralism or phronetic ontolo-gies (on these approaches see Fischerand Gottweis, 2012; Hajer and Wagenaar,2003; Flyvbjerg, 2001).

To understand this, one has to con-sider that social scientists often ope-rate with a social ontology combinedwith an objective epistemology (Searle,1995). Granted that entities such asnarratives are representations of policy

‘ynarrative policyanalysis can and shouldbe reclaimed by political

scientists that do notsubscribe to post-modernism, post-structuralism or

phronetic ontologies’.

claudio m. radaelli et al european political science: 2013 3

created by social actors, and thus havean inter-subjective nature, they can stillbe examined empirically using an objec-tive epistemology. This article shares thisNPF combination of social ontology andobjective epistemology. But it also repre-sents an attempt to build on these broadontological and epistemological claimsby adding two research foci that havenot yet crossed their path in the NPF (seeJones and McBeth, 2010, for the hall-marks of the NPF). The two foci arediscourse (Schmidt, 2008) and the pre-sentation of self (Goffman, 1959). Byincorporating these two dimensions,we are able to expose the differentpurposes to which narratives are direc-ted. Let us begin with discourse. Accor-ding to Schmidt, the discursive aspectsof policy-making fall in two categories.One is coordinative discourse, that is:how elites use discursive structures, tomake sense of reality and coordinatetheir policy initiatives. The other is com-municative discourse, that is: how policynarratives are communicated to pressuregroups, the public and, more generally,the external environment in order toachieve legitimacy for the policy choicetaken by elites. In our article, we explorenarratives as tools of discursive coordi-nation within a complex organization likethe European Commission, and as com-municative tools through which policy-makers seek to enhance the plausibility,acceptability and, ultimately, legitimacyfor their policy proposals. Both in coor-dinating and communicating policy,bureaucratic elites tend to project acertain definition of their identity via thenarratives they deploy, most often interms of the moral and normative as-sumptions behind policy choice. Here iswhere we need Goffman. Indeed, drawingon Schimmelfennig’s insight that drama-tic action is often present in internationalorganizations (Schimmelfennig, 2001),we can follow Goffman (1959) in arguingthat the presentation of self combines

narrative activity at the back and frontstages.

In the next section, we introduce theidea of IAs as narratives. In the subse-quent section we outline our researchquestions, data sample, and coding. Thenin the latter section, we present ourempirical analysis of the data. Since thisis the first study to consider the narra-tive dimension of IAs, one aim of ouranalysis is to explore the variability andcommon features in our sample, ratherthan presenting specific hypotheses to betested. We conclude with a discussion andsuggestions for future research, includinghypotheses that might usefully be testedin the future.

IMPACT ASSESSMENT ASNARRATIVE

(Why) should we look at IAs throughthe lenses of the NPF? The Commissionuses IA documents to make the case forits proposals and to show how a givenconclusion on the chosen option wasreached. Thus, in a sense, the IA activityis all about persuading the reader that theaccompanying proposal meets some cri-teria of evidence-based policy to whichthe EU is committed. Previous studieshave also found that the Commissionbecomes a narrator to increase the scopeand breadth of EU action in areas whereconsensus is particularly difficult to reach(Radaelli, 1999). But, there are also morespecific issues to consider.

The guidelines of the European Com-mission (2005b, 2009c) have an expli-cit narrative structure. Indeed, wecan match precisely the steps of theIA, and some features of argumen-tation and policy narratives (Roe, 1994;Toulmin, 1958). The IA, so the guide-lines say, should start with a presentation of what the problem is. In terms ofToulmin’s analysis of argumentation, thisis the ‘claim’ made by the Commission.


By identifying a problem, the Commissionmakes a given social, environmental,economic problem ‘out there’ amenableto human action within the EU policy-making framework. As mentioned, IAsfollow a narrative arc: at the beginningthey define a given problem, and thenshow (optimistically, indeed) how theproblem can be acted upon via EU action.Roe (1994), this transformation of socio-economic problems into problems thatare suitable for the policy agenda of anorganization is an essential property ofpolicy narratives.The guidelines also specify that the

officers should provide evidence support-ing problem definition. Yet again, thiscorresponds to Toulmin’s (1958) linkbetween the ‘claim’ and the ‘grounds’ orevidence that is appealed to as a founda-tion for the ‘claim’. Further, there is anexplicit requirement to explain what willhappen in the absence of EU action – thedefault option of no intervention. In Roe’s(1994) narrative framework, the textdescribing ‘what happens if we do not

act together’ is the worst-case scenariocomponent of the narrative. By explicitlyrequiring an analysis of the ‘do nothing’option, the IA guidelines stimulateauthors to dramatize this scenario, oftentransforming it into a doomsday scenariowhere particularly bad policy outcomesare evoked. Finally, a good IA shoulddescribe a wide range of actors andsectors that can be affected by theproposed intervention. This is sometimesan aseptic list of those who are going togain from the EU policy and those who aregoing to incur costs. But, in some cases,the IA transforms this list into somethingmore, that is, following a classic feature ofcausal stories (Stone, 1988; Roe, 1994;Jones and McBeth, 2010), proper ‘heroes’and ‘villains’.

The IA document is thus a script with anarrative structure. One more observation

‘The IA document is thusa script with a narrative

structure’.

[email protected]


is in order: the IA script is related to boththe ‘frontstage’ and the ‘backstage’. Thebackstage is reflected in the sections ofthe IA portraying the coordination ofpolicy among different DGs and policyelites more generally. The frontstage iswhere the IA content is displayed forthe wider European public and memberstates. Following Goffman (1959), wesuggest that activity on these stagescombine to provide certain personae orpresentations of self of the Commission.This means that although, in principle,the process of preparing the assessmentshould be entirely dedicated to evidence-based policy, the Commission, accordingto this conjecture, can manipulate it toestablish norms, reiterate beliefs, definethe range of acceptable and undesirableactions – in short, present itself. Differentpresentations are conceptually possible,from presenting the Brussels-based bu-reaucracy as a diligent agent of the Eur-opean Parliament and the Council to moreassertive presentations, including the pre-sentation of an organization directly re-sponsive to public opinion and the majorstakeholders in the EU policy process.These remarks concerning the front

and the back stages have importantconnections with the discursive dimen-sion of policy narratives. To see this, weneed to relate IA to the policy formulationprocess. Before the introduction of the IAprocess in 2003, policy proposals weredeveloped within a given DirectorateGeneral, subject to inter-service consul-tation and monitoring from the Commis-sion’s Legal Service and more generallythe Secretariat General. Observers inthe past noted the relative autonomy ofthe DGs in the preparation of propo-sals, and the weakness of the SecretariatGeneral in providing robust coordina-tion. Upon completion of their interviewprogram within the Commission, Kassimand Menon (2004: 28) spoke of a ‘collec-tion of baronies’ to highlight the relativeautonomy of the DGs. The situation has

changed with the institutionalization ofthe IA process (Allio, 2008; Radaelli andMeuwese, 2010). Radaelli and Meuweseargue that the different preferences,constituencies and organizational cultu-res of the DGs are built into the IAprocess. DGs may have different ways oflooking at policy problems. But they havebeen forced to articulate their opinions interms of evidence, and consequently theyhave given up some bureaucratic auton-omy – to other DGs and to the SecretariatGeneral, which has gained in coordinationcapacity. This means that the process ofpreparing an IA has an important back-stage role or, following Schmidt (2008),provides a platform for coordinativediscourse. Tellingly, the IA document isfinalized together with the proposalagreed upon by the College of the Com-mission. Up until the last minute, theCommissioners can utilize the IA and thedraft proposal (say, a draft directive) tocoordinate and agree. The scrutiny ofthe draft IAs by the IAB adds anotherelement to the policy formulation network(Alemanno, 2008; European Commis-sion, 2012). The Board has leverage toinsist on the inclusion or exploration ofcertain issues, and steer coordinativediscourse in one direction or another.

However, the IA is also a discursivetool in providing justification and legiti-macy for the choices made. In thissense, the IA speaks to a broader audi-ence, where there are both institutionalpublics like the European Parliament andthe Council, and the various audiencesof stakeholders. According to Schmidt(2008), this is communicative discourse,or the legitimizing function of a speech ortext. In the case of the Commission,legitimacy is also intertwined with issuesconcerning the legal basis for interventionand the scope for EU action in areaswhere prima facie member states seemmore equipped to solve problems.

To sum up then, the IA process anddocument can be examined through the


lenses of the NPF. In this section wemade the case for a narrative analysis.IAs may be manipulated to provide apresentation of self by the Commission,going beyond evidence-based policy intothe territory of norms, values and what anorganization stands for and cares about.Finally, the IA as discourse has a coordi-native function as well as communicativeproperties.

RESEARCH QUESTIONS,SAMPLE, CODING AND DATA

Our project emerged from the narrativeapproach (specifically the NPF), whichsuggests the following research ques-tions: Does the Commission use IAs fornarrative purposes? When this happens,what are the narrative features of IAs,specifically causal plots, doomsday sce-narios, dramatization, heroes and villains,moral reasons for action and other ele-ments associated with narrative policyanalysis? Does the Commission as narra-tor exploit the IA process to offer cer-tain presentations of self and establishnorms? Finally, how do the IAs performin relation to communicative and coordi-native discourse? To answer these que-stions, we provide a suitable sample andoriginate data. The Commission experi-mented with IAs in the period 2003–2005(Allio, 2008). After that, IA has become apretty stable, routine-like feature of pol-icy formulation. This suggests that wedo not need to examine IAs carried outbefore 2006.To analyze a certain number of IAs

in-depth, we did not want to censor oursample. With this in mind, we adoptedthe following three criteria for inclusion:binding versus non-binding proposals(like Communications); low versus highsaliency issues; and DGs that historicallyhave been very close to the smart regu-lation agenda of the EU versus moreperipheral DGs, which have either con-

tested or have simply been less inter-ested in this agenda (Allio, 2008). Thisway we control for whether the appraisalsupports legislative or non-legislativeproposals, the politicization of policyissues, and organizational culture. Thecombination of these criteria provideseight possible combinations in a truthtable that drove our selection of cases.In consequence, we selected eight IAssummarized in Table 1.

In order to analyze these eight IAssystematically, we developed a codingframe (a scorecard) consisting of 23items. In terms of measurement, ourcoding framework contains three typesof items: first, those reporting on thepresence or absence of a narrative fea-ture, resulting in a simple ‘yes/no’ score;second, those presenting informationabout the presence or absence of anarrative feature (‘yes/no’), supportedby extensive qualitative evidence suchas quotations; and, third, those providingqualitative evidence related to specificcategories or ideal types (see, for in-stance, ‘Genre’ or ‘Characters’).

The eight IAs were coded blindly byeach of the three authors, resulting in24 completed scorecards per IA. Thesescores were subsequently aggregatedwith a view to produce one master score-card per case. Across all cases, we wereable to code on average 79 per cent of thevariables. However, due to the aggrega-tion of scores into master scorecards wereached 100 per cent coverage for all IAs.Inter-coder reliability was slightly above90 per cent; cases of conflicting scoreswere resolved in a discursive processamong the authors. It became clear thatthe 2006 IA on mercury is particularlyshort because it draws on extensive IAscarried out for the overall strategy of theCommission on mercury (European Com-mission, 2005a). Hence we coded themercury directive IA taking into accountthe narrative elements that appear in theprevious ‘mercury strategy’ IA.


EMPIRICAL ANALYSIS

The first result is that the IAs have anarrative dimension. This is not a generalfeature, however. The Commission is anarrator, but not always. In five cases thereis a plot – without a plot, we cannot talk ofnarrative structure. Of our three selectioncriteria, only the legally binding nature of

the initiative is moderately associated withthe presence of plots (four cases out offive; saliency occurs in three cases; coreDGs are involved in only two of the fivecases with a plot). Drama or doomsdayscenarios are represented in seven of theIAs. Heroes or villains appear in six.

The fact that the Commission can playthe role of narrator should not be seen

Table 1: Sample

IAs selected (lead DG, yearin which the assessment wasconcluded, reference)

Shorthandname

CoreDG

Highsaliency

Legallybinding

Proposal for a regulationconcerning trade in seal products(ENV, 2008; EuropeanCommission, 2008)

SEALS IA + + +

Communication on a Europeaninitiative on Alzheimer’s diseaseand other dementias (HealthConsumers, 2009; EuropeanCommission, 2009b)

ALZHEIMERS IA + + �

Report on the possibilitiesof further improving theenvironmental characteristicsof recreational craftengines (ENTR, 2007;European Commission, 2007a)

RECREATIONALCRAFTSENGINES IA

+ � �

White paper on sport(EDULCULT, 2007;European Commission, 2007b)

SPORT IA � � �

Protecting Europe fromlarge-scale cyber-attacksand disruptions: enhancingpreparedness, security andresilience (INFOSOC, 2009;European Commission, 2009a)

CYBER IA + �

Directive on a commonconsolidated corporate taxbase (TAXUD, 2011;European Commission, 2011a)

COMMON TAX IA � � +

Directive on restrictions onthe marketing of certainmeasuring devices containingmercury (ENTR, 2006; EuropeanCommission, 2006)

MERCURY IA + � +

Directive on a common systemof financial transaction tax(TAXUD, 2011; EuropeanCommission, 2011b)

FINANCIALTRANSACTIONTAX

� + +


necessarily in opposition to economicanalysis. The TAX IAs are particularlystrong both in terms of narrative andeconomic analysis. One can reason thatevidence-based policy (or, in a narrowerdefinition, economic analysis) does notexclude the narrative dimension. Six ofthe studies contain no CBA – but recallthat the Commission has not assignedpriority to this method. Two of the fourstudies that do deploy some economicanalyses underline the uncertain natureof some of the data they use (MERCURYIA and CYBER IA).Narratively strong IAs can also be

used to bypass the boundary between‘evidence-based’ policy and more politi-cal considerations. Essentially, the IA iswritten by authors taking seriously some‘readers over their shoulders’, often themember states. When this happens, theofficers deploy arguments and evidenceto show that some likely reservationshave already been taken care of. In theCOMMON TAX BASE the Commission en-tered directly into the pre-negotiatingstage by using simulation data to iron outthe possible hostile reactions of revenueauthorities in the member states – theproposal was developed over more than adecade of studies and pilot exercises.Practically, this IA wants to show that thepossible negative reaction of country X hasalready been countered by simulationY. This illustrates that the IA purposeincludes, but goes beyond, providing thesubstantive evidence-based support to adecision. It may also serve to improve onpolicy formulation considering a wide rangeof dimensions, some evidence-based in thesense of economic analysis, some still in asense evidence-based, but related to ex-pectations about the political reactions todifferent options made by the Commission.Pragmatically, it makes sense to operatethis way, instead of bracketing the politicalout of the IA discourse.We should further qualify that the

commitment to evidence-based policy is

associated with candid acknowledge-ments of uncertainty and limitations inthe data, thus generating more oppor-tunities for argumentative-narrative con-siderations. For example, in the CYBERIA, before analyzing the policy optionsit is noted that ‘y trustable data to basethe analysis on are not readily avai-lable’ (European Commission, 2009a:26). The SEALS IA offers another exam-ple. The first paragraph of the ExecutiveSummary starts with:

[I]n line with its commitment to highanimal welfare standards, the EuropeanCommission undertook to conduct anobjective, in-depth analysis of the ani-mal welfare aspects of seal hunting insealing countries y there are only alimited number of studies ythat can beused to evaluate with a high degree ofcertainty the efficacy of the variouskilling methodsythere is reported evi-dence that in practice effective killingdoes not always happen and someanimals are killed and skinned in away, which causes avoidable pain, dis-tress and other forms of suffering.(European Commission, 2008: 8)

But, then much later in the script thelanguage is toned down further still,observing that:

[P]olicy decisions will have to be takenon limited information. EFSA statedclearly that there was a scarcity ofrobust, scientifically peer reviewed data.(European Commission, 2008: 45)

In the absence of a robust evidencebase emphasizing the logic of nece-ssity, narratives are used to connectthe dots and to provide foundations forpolicy action, transforming unconclusiveevidence into problems that are amen-able to human action.

Cognitive dimensions are nested intodeeper-level core norms. Consistent withthe claim that the EU texts project


both ‘the EU as it’ and ‘the EU-topia’ (theEU as it ought to be, see Nicolaidis andHowse, 2002), we found the core normof integration is extended beyond tradeand markets. Integration – the IAs argue- brings together communities of profes-sionals, researchers, and people beyondthe boundaries of the nation-state. Inte-gration brings down barriers betweencountries, and ought to be considereda valued aim in EU-level action: this normis represented in all of the IAs, to someextent. The ALZHEIMER IA exemplifiesnot only the cognitive but normativeimportance of developing and coordinat-ing EU communities of practice:

[I]n addition, the main added-value ofcollaborative health research at Com-munity level is obtained from trans-national cooperation, the integrationof relevant activities and participants,and the concentration of Europeaneffort on fewer priorities. In particular,EU health research brings down bar-riers between countries, via multi-national consortia and coordination ofnational funding programmes; enforcescooperation between different typesof organisations: universities, researchcentres, hospitals, SMEs, large compa-nies, foundations, or patients’ organi-sations. With its increased focus ontranslating basic discoveries into clini-cal applications (translational resea-rch), it also promotes cooperationbetween scientific disciplines, bringingtogether researchers, engineers, clini-cians and industrialists. (European Com-mission, 2009b: 16, emphasis added)

But, there is a deeper, and funda-mentally more political, sense in whichnormativity enters many of the IA texts.The IAs in our sample provide severalassertions along the line that action byindividual member states is inefficient,fragmented and inconclusive, and there-fore EU-level coordination brings coher-ence and a ‘single voice’ into policy

action. By itself the fact that EU-actionmeans a ‘single voice’ is a tautology, theproblem being whether subsidiarity isviolated or not. In the SEALS case,however, the IA is candid about usingthe appraisal not so much to establishnorms, but to increase the credibility ofthe Commission:

[T]he aim of this initiative is in line withthe Commissions’ strategic objectivesand better regulation principles notablyto provide effective and efficient mea-sures, ensure a high level of legalcertainty across the EU, and thushelp to strengthen the Community’scredibility in the eyes of its citizens.(European Commission, 2008: 20)

Let us now turn to our question aboutcoordinative and communicative discou-rse. Consider coordination first. DGs, theSecretariat General, and the IAB interactin the preparation of the assessment. TheSPORT IA was particularly proud of the‘strong collegial approach’ involving noless than 17 DGs in the preparation andevolution of the document. The ALZHEIMERIA is also instructive. Developed by theHealth and Consumers DG in associationwith the Directorates-General for Employ-ment, Social Affairs and Equal Opportu-nities (DG EMPL), Research (DG RTD) andJustice, Freedom and Security (DG JLS),plus the supervision of the SecretariatGeneral, this is clearly a rich policy formu-lation network that looks very differentfrom the autonomous baronies of thepast. Indeed, the IA steering group metformally three times to coordinate onform and content of the ALZHEIMERIA. This point towards the claim thatthe ALZHEIMER IA is able to reflect thepreferences of different constituencies:public health, employment, the promo-tion of research across the EU, fairnessand rights.

Five of our IAs used endorsements ofexpert groups to underline the credibility


of the policy action proposed. Forexample, in the ALZHEIMER IA, theofficers in charge of policy formula-tion orchestrated a panel of experts onAlzheimer disease and dementia, whichwas convened eight days before theIA was sent to the IAB for scrutiny.The IA is very transparent on how thepanel was used to build legitimacy – andmore importantly still to endorse theneed for more action at the EU level inthis field, as shown by the final part of thissentence:

[T]he Panel broadly endorsed the im-pact analysis and options considered bythe Commission, whilst also providingmany references and data that enabledto more clearly define the context of theproblem in the field of Alzheimer’sdisease and dementia, to further devel-op the option of a platform for voluntarycooperation at European level, and toreinforce the impact analysis of Com-munity action in this area. (EuropeanCommission, 2009b: 4)

The CYBER IA goes further still –actually including a photograph of expertworkshops convened on the subjectwhich is labeled as ‘consensus develop-ment at experts’ workshop’. Two furthertechniques are central in the Commis-sion’s coordination of elite action. Thefirst concerns the identification of actorscharacterized as ‘villains’ – perpetratorsof the policy problem – and how theyrelated to the Commission as policyarchitect. Five IAs identified actors thatcan be categorized as villains. What isnotable here is that the vast majorityof the villains were presented as actorsor forces that did not respect the tradi-tional nation state boundaries – illnessand time (ALZHEIMER IA); transnationalcriminal networks (CYBER IA; SPORT IA),and non-EU countries where seal cullingmanagement systems are ‘underdeve-loped’ (SEALS IA). Thus, with thesevillains to confront, the Commission – as

supranational entity – becomes the lynch-pin in policy construction, problem analy-sis, and stakeholder mobilization.

The second narrative technique usedas a rallying call to policy elites concer-ned the presentation of time and crea-tion of policy urgency. In five cases fromour IA sample, temporal language orallusions to time were deployed to engen-der a sense that policy action shouldnot be delayed. For example, in theCYBER IA:

‘cyber-attacks have risen to an unpre-cedented level of sophistication y.ICTinfrastructures are under constant at-tack and if Europe does not prepareitself the impact would be much moresevere’ where the field is marked by a‘phenomenal growth’. (European Com-mission, 2009a: 3)

Similarly, in the COMMON TAX BASEIA tax obstacles are now ‘more and moreevident and detrimental’ (European Com-mission, 2011a: 14) and in the ALZHEIMERIA, the shadow cast by the future increasein illness rates and health costs of theageing population is an ever-presenttheme in the text.

As well as enabling the Commissionto coordinate policy construction andpresent itself to its policy partners, dis-cursive narratives have wider communi-cative functions. The Commission mustnot simply gather ideas and evidence

‘ywith these villains toconfront, the

Commission – assupranational entity –

becomes the lynchpin inpolicy construction,

problem analysis andstakeholder

mobilization’.


that go into the problem and policysolution being proposed; it must alsogenerate a sense of legitimacy for policyaction, and locate it within the biggerpicture of what that action means forthe EU project as a whole (or the EU-topia, Nicolaidis and Howse, 2002). Inher analysis of the institutional dimensionof interactive discourse, Schmidt notesthat the balance of coordinative andcommunicative discourse is, in part, afunction of the institutional make-up ofthe political system being studied. In amulti-actor, highly compound systemsuch as the EU where power is dispersed,we would expect coordinative discourseto dominate (Schmidt, 2006). However,the concentration on communicative dis-course in our sample of IAs was striking.The Commission does not exploit IAs tocommunicate directly with the Europeanpublic. However, the IAs are platforms torehearse arguments and legitimize itsown involvement in the issue at hand, aswell as the actual substance of the policybeing proposed.Drama is key in constructing a sense

of legitimacy. Dramatic tension is injec-ted in seven IAs through use of bothemotive language in relation to who isaffected by a problem and what will belost if no action is taken – these takethe form of what we term ‘doomsdayscenarios’ where the worst case scenariosare either remembered or postulated.The use of the doomsday scenario isfound where the Commission justifies itsproposal for action in the CYBER IA byemphasizing how ‘vital’ that sector isfor all segments of society evoking thelogic of learning from a past ICT secu-rity failure. With these villains to con-front, the Commission – as supranationalentity – becomes the lynchpin in policyconstruction, problem analysis and stake-holder mobilization:

[D]iscussions after the Estonian attacksuggest that the effects of similar

events can be limited by preventativemeasures y..[T]he Commission, fullyrespecting the subsidiarity principle,is ideally placed to coordinate sucheffortsy. (European Commission,2009a: 4)

The issues considered are often mun-dane low politics matters, but they arediscursively linked to grandiose declara-tions and solemn texts. This discursiveanchorage perhaps brings more leverageto the proposal or simply tries to mag-nify issue relevance. One key techniquedeployed to give policy a sense of orienta-tion within the wider EU project is tolink it to previous directives, declarationsand Treaties. In the SPORT IA, facedwith no competence in the area, theCommission’s policy scope is presentedas follows:

[T]he interaction between sport and EUlaw as well as the role of sport withinEU policies y has not been addressedin a comprehensive manner and needsto be illustrated in order to give orien-tation on how to take into accountthe existing texts at EU level that relateto sport. (European Commission,2007b: 9)

In some cases, the Commission movesbeyond justifying action in legal termsalone. For example, in the SEALS IAthe Commission pressed home the ideaof policy action as its part of a legalcommitment to particular animal welfarestandards but also as its moral duty bothto seals as sentient animals and also to anexpectant European public noting the‘high level of public concerns regardinganimal welfare aspects of seal hunting’(European Commission, 2008: 6). TheSPORT IA offers a similar concern – by notbecoming involved and pushing a policyforward, the Commission would be guiltyof not living up to its responsibilities andpromises to the EU public’ (EuropeanCommission, 2007b: 20).


When the coordinative and communica-tive narratives techniques are combined,the result is akin to the Commissionadopting different personae or presen-tations of self (Goffman, 1959). TheCommission, like other organizations per-forming in a dense environment, engagesin the strategic presentation of self,and the manipulation of frames. FrankSchimmelfennig (2001) made this claimdrawing on Goffman (1959), and withreference to the overall behavior withinthe international community. Since weare concerned with the Commission, whatmatters is how this organization intro-duces a presentation of itself as respon-sive to its policy partners, other EUinstitutions and EU citizens. This self-presentation may be less or more impor-tant than others (such as presentingthe Commission as an organization dedi-cated to evidence-based policy), follow-ing Goffman (1959) much depends onthe ‘definition of the situation’. The IAalso provides the opportunity to suggesta presentation of self as ‘evidence-ledorganization’. But also, depending on thesubject matter, the Commission can pre-sent itself as an upholder of certain valuesand beliefs in governance, the market,and human rights.In our analysis, we found multiple

presentations of self (see table in theAppendix). Space constraints prevent usfrom outlining each of the personae, butthree of the recurrent ones are exploredhere in more depth. The first was expec-ted and is present in every case: sincethe IA process is informed by the smartregulation agenda and evidence-basedpolicy ideal, the Commission presentsitself as an evidence-based organiza-tion dedicated to the dispassionate scru-tiny of empirical evidence to meet theexpectations of its European public. Avariation of this presentation is the calm,responsible, gentle giant – quite evidentin the COMMON TAX BASE, MERCURY,SEALS AND ALZHEIMER IAs. For example,

the COMMON TAX BASE IA argues thatthe Commission took responsibility fordirect corporate tax coordination at leastsince 1992, and lists with pride allthe initiatives, studies, and proposals inthe two decades since that date. TheCommission is committed to evidence-based policy, but this commitment isreinforced by a long-standing responsi-bility as custodian of the single market.Given this responsibility, the Commis-sion does not follow the vagaries ofpolitical mood. Instead, it cumulatesevidence for the ‘good cause’, study afterstudy, communication after communica-tion, proposal after proposal. Similarlyin the MERCURY case, the Commission isconscious of its position as a signifi-cant exporter of mercury and the con-sequences of further additions to theglobal pool.

But there are also other presenta-tions of self that are less in line with theevidence-based policy agenda. Four IAsshow a diligent, responsive agent, in tunewith the expectations of governmentaland non-governmental actors, as well ascitizens. Indeed, the SPORT IA has awhole section entitled ‘a clear politicaldemand’ (Section 3.2.3.1). But, it is inthe discussion relating to taking the ‘NoAction’ option that this responsive perso-na is most explicit:

[N]o action would finally mean not draw-ing any lesson from the repeated callsby governmental and non-governmen-tal actors to better promote sport at EUlevel, and to raise the visibility of thesocial and economic potentials of sport.(European Commission, 2007b: 22, ouremphasis)

Another example is the RECREATIONALCRAFTS ENGINES IA, where it is arguedthat the identification of the problemas one of improving on emission wasmade by the European Council and theParliament, who ‘have requested theCommission to report on the possibilities


of further improving the environmentalcharacteristics of recreational marineengines’ (European Commission, 2007a:2). Thus, here the Commission is againdepicted as a diligent and responsiveinstitutional citizen.

DISCUSSION ANDCONCLUSIONS

While previous research has focused onthe quality of IAs as tools for evidence-based policy and smart regulation, wehave explored a different perspective,drawing on the framework developed byRoe (1994) and, recently improved byJones and McBeth (2010). We foundempirical evidence that the Commis-sion has used IAs to promote its narra-tives. However, there are also casesin which the Commission has limited orno interest in narrating. Future researchwill have to explore the conditions thattrigger or hinder a narrative mode. Byconsidering the narrative dimension, wewere able to find that the IA is a usefultool to bypass the boundary betweentechnical and political appraisal of pro-posals. We found evidence that the IAsmay usefully address political concernsand enter the pre-negotiation stage soto speak. Given that a current theme inthe political discussion is about the inde-pendence and technical objectivity of theIAs, our evidence suggests a completelydifferent perspective. Instead of seek-ing unrealistic aseptic ‘essays’, we shouldreason that this tool may also improveon policy formulation by addressing poli-tical concerns via empirical analysis andreasoned argumentation. This makes theIA more interesting and useful to deci-sion-makers (like the Commissioners)and elected politicians in the EuropeanParliament and the Council. Perhaps itmakes sense to operate this way, insteadof bracketing the political out of the IAdiscourse. This might be noted with the

following caveat: the bridge between thetechnical and the pre-negotiating stageshould be built upon evidence, otherwisethe credibility of the whole exercise willsuffer irremediably.

The Commission may or may notexploit IAs to produce economic analysisof legislation or to stick to other stan-dards (such as consultation, problemdefinition, examination of alternativesto traditional regulation) of what is nowcalled smart regulation (European Com-mission, 2011c). To establish this, oneneeds research designs of the type usedin the past by evaluators and acade-mics (The Evaluation Partnership, 2007;Fritsch et al, forthcoming). But no matterhow engaged the Commission is withsmart regulation, it is engaged with causalplots, doomsday scenarios, heroes andvillains. It also makes use of the IAs toestablish norms and provide differentpresentations of self, in order to increaselegitimacy. Future research could estab-lish whether the use of IA to presentpersonae and to establish norms is aunique feature of the Commission, or italso affects other producers of IAs, suchas US federal executive agencies andUK departments. To do this, one has toextend the analysis to samples fromcountries like the UK and the US.

Narrative techniques are deployedquite skillfully by the Commission, atalented writer who can write in differentgenres. Specifically, we found examplesof the problem-solving handbook; thethriller story; the manifesto for policyaction, and the thematic essay. The lessinteresting cases (from a narrative pointof view) belong to the flat ‘homework’genre or the ‘revise and resubmit’ essay,when the IAB makes critical remarks andthe main preoccupation of the authors isto show compliance with the IAB suggestions rather than engaging with thenarrative. The ultimate aim of this articlehas been to generate evidence leadingother researchers to generate hypotheses.


Tentative avenues for more research onpolicy narratives in the field include thetype of policy arenas and readers-stake-holders, the role of narratives in creatingtarget populations for the Commission,and the interplay between economic ana-lysis and narrative analysis.

Acknowledgements

We presented draft versions of the articleat the UK Political Studies Association

Conference, Belfast, 3-5 April 2012 andat the Berlin Conference on the HumanDimensions of Global EnvironmentalChange, 5–6 October 2012. We are grate-ful to Mathias Delori and Anna Durnovafor extensive comments on an earlydraft. Research was supported by theEuropean Research Council’s grant no.230267 for the project of Analysis ofLearning in Regulatory Governance,ALREG (http://centres.exeter.ac.uk/ceg/research/ALREG/index.php).

Notes

1 Individual Directorates-General have additional guidance documents that add to the single templatebut do not substitute it.

2 We are grateful to Janice Morphet for suggesting this characterization.

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APPENDIX

Table A1: Analysis of Impact Assessments

MERCURY IAdraws on a large2005 IA for theCommunication onmercury strategy

RECREATIONALCRAFTENGINES IA

SPORT IA SEALS IA ALZHEIMER IA CYBER IA COMMON TAXBASE IA

FINANCIALTRANSACTIONTAX IA

ID SEC(2005) 101 SEC(2007) 819 SEC(2007) 932/2 SEC(2008)2290

SEC(2009) 1040 SEC(2009) 399 SEC(2011)315

SEC(2011) 1102

Lead DG Environment Enterprise Education andculture

Environment Healthandconsumers

Informationsociety andmedia

Taxation andcustomsunion

Taxation andcustoms union

DGs involved Lead DG,plus SG Lead DG only 17 DGs Lead DG only 4 DGs 11 DGs + SG Lead DG only 6 DGs + SGType Directive Communication White paper Regulation Communication Communication Directive DirectiveLength Long Short Short Long Short Long Long LongTriggered byEP and Council

Yes Yes No No Yes No Yes No

Problem Health-related Environmental Political:Extendingregulatorycompetences ofthe Commission

Normative:Respondingto normativebeliefs heldby Europeancitizens

Informationbase: Lack ofcoordinationamong memberstates when itcomes tosharing researchfindings andinformation

Security-related: Lack ofcoordinationamong memberstates

Technical:Tax barriers

Political: Lackof coordinationamong memberstates

Identity/Presentation ofSelf

Evidence-basedorganization;Diligent agent;Gentle civilized

Evidence-basedorganization;Diligent agent

Evidence-basedorganization;Strategic actorlooking for policy

Evidence-basedorganization;Diligent

Evidence-basedorganization;Gentle civilizedglobal power

Evidence-basedorganization;Strategicactor able

Evidence-basedorganization;Gentle

Evidence-basedorganization;Diligent agent;Custodian of the

european

political

science:2

01

3narrating

impact

assessment

inthe

europeanunion

18

global powerconcerned withfairness;Foresightful actor

spill-overs;Horizontalorganizationable to respondeffectively oncross-cuttingissues to anexpectant publicand stakeholders

agent;Gentlecivilizedglobal powerconcernedwith fairness

concernedwith fairness;Possiblerepository ofdata and bestpractice;PromotingNGOs;Oriented tonew cutting-edgeresearch

to crossover theboundariesbetweentechnicaland political

civilizedglobal powerconcernedwith fairness;Organizationoriented tolong-termgoals

single market;Fairness-oriented

Types ofevidence

Inconclusivequantitativeevidence relatedto health andeconomic impacts

Evidence andconsultation

No empiricalevidence, yetstatementsmaking the casefor a politicalcommitment ofthe Commission

Qualitativestudies,manyof them non-scientific, andconsultation

Values andcollectiveresponsibility

Evidence insupport of apoliticalcommitment toovercomefragmentedaction

High numberof variousstudiesaggregated inonedocument

Economicanalysis andpoliticalcommitment

Characters Consumers,artisanal miners,producers andtraders, fishingindustry, industrialsectors such aspower generation

Industry,environmentalagencies,individual firms

Citizens, minors,athletes, sportNGOs, sportfederations,domestic policy-makers

Animals, EUcitizens, non-EU citizens,localcommunities,huntingcountries

Patients and theirfamilies, NGOs,researchers,residential carestaff

Business,citizens, publicadministrations

Businessfirms,revenueauthorities,jobholders

Financial sector,revenueauthorities,different incomegroups

Causal plot Yes No No Yes No Yes Yes YesHeroes or villains No No Yes

Hero: EuropeanCommissionresponding topublic andstakeholdersVillains:

YesHeroes:sentient sealsVillains:countrieswith weakenforcement

YesHeroes: patients,their families,carers,researchersVillains:

YesHero: EuropeanCommissionVillains: thosewho perpetrateattacks

YesHero:EuropeanCommissionhas identifiedproblem longtime ago

YesHero: EuropeanCommissionprotecting singlemarket andhandling theeconomic crisis

claudio

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Table A1 (continued )

MERCURY IAdraws on a large2005 IA for theCommunication onmercury strategy

RECREATIONALCRAFTENGINES IA

SPORT IA SEALS IA ALZHEIMER IA CYBER IA COMMON TAXBASE IA

FINANCIALTRANSACTIONTAX IA

criminalsencouragingdoping

and trainingor withinsufficientdata

Alzheimer’s;time

with fairnessVillains: greedybankers

Meta-narrative No No No YesSecondarynarrative:seal huntingas dark,mysteriousbusiness, EUaction is alsoneeded toimprove ourknowledge

No No No YesMain narrative:raising income,secondarynarratives focuson protecting thesingle marketfrom distortionandfragmentation

Metaphors No No No No No Yes Yes NoExpertEndorsement

No No No Yes Yes Yes Yes Yes

Conflict YesDistributional issues

YesDifferent positionsregarding scope ofaction

No YesDistributionalconflictamongmemberstates

YesLack ofconsensus onethical issues

No No YesPolarizedopinionsdepending onaffectedness

Type of supportfor choice

Economic analyses,studies fromtoxicology andmedicine

Compliance costs,environmentalimpact assessments

No empiricalevidence

Descriptiveevidence,norms,analysis ofcurrentcompliance

Norms Evidence fromec. data,consultation andcase studies

Economicanalysis andconsultation

Economicanalysis

european

political

science:2

01

3narrating

impact

assessment

inthe

europeanunion

20

Criteria Cost-effectiveness MCA focusing onefficiency,effectiveness andconsistency

Reasoninginformed bystrategiccommitment ofthe Commission

Reasoninginformed byqualitativeempiricalevidence anddata

Qualitativereasoning

Qualitativereasoning

Maximum netbenefit in amacro-economicoutlook

Assessments ofvarious impactsfollowingdifferent criteria

Dooms Yes No Yes Yes Yes Yes Yes YesDrama/Emotive Yes No Yes No No Yes Yes NoTemporalUrgency

No Yes Yes No Yes Yes Yes No

Wider questions Yes No Yes No No Yes No NoRebut Yes Yes Yes Yes Yes Yes Yes YesConclusion No No No Yes Yes Yes No YesGenre Handbook for

problem solvingHomework forproblem solving

Manifesto Handbook forproblemsolving

Essay on a theme Thriller Handbook forproblem-solving

Manifesto

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About the Authors

Claire A. Dunlop is a Senior Lecturer in political science at the Department of Politics at theUniversity of Exeter, in the UK. Her research interests centre upon the politics of expertise,epistemic communities, risk governance and the science–policy interface. Most recently, shehas published research articles in Political Studies, Regulation and Governance, Journal ofEuropean Public Policy, Policy Studies, Policy Sciences and Public Management Review.

Oliver Fritsch is a Lecturer at the Department of Politics of the University of Exeter and affiliatedwith Exeter’s Environment and Sustainability Institute. He is also the editorial office managerof the European Journal of Political Research. His main research interests are public sectororganisations and organisational reform, stakeholder and civil society involvement in policymaking, as well as environmental politics. He has recently published peer-reviewed articlesin Public Money & Management, Environment and Planning A, Ecological Economics,Environmental Policy and Governance, and Environmental Management.

Claudio M. Radaelli is Professor of Political Science and Director of the Centre for EuropeanGovernance at the University of Exeter. His research interests cover the fields of regulation,Europeanization, and policy analysis. He co-edited Research Design in European Studies(Palgrave, 2012, with Theofanis Exadaktylos), Politics in Italy (Berghahn Books, 2013, withAldo di Virgilio) and co-authored Research Design in the Social Sciences (Sage, 2013, withMartino Maggetti and Fabrizio Gilardi).


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