PART V: LEARNING TO DEAL WITH DEMANDS FOR PARTICIPATION
III. POLICY TRANSFER AND TELECOMMUNICATION REFORM
A. Transfer Mechanisms: Between Learning, Coercion, and Domestic Politics
During the last decade, which has been characterized by economic globaliza- tion, technological innovations, and the growing importance of international institutions, the notion of policy transfer has gained increasing attention in comparative public policy and international relations. A large body of literature has grown, stressing the importance of learning processes and the role of ideas and knowledge in the formulation of national public policy in a globalized context.
Most authors underline the distinction between‘‘voluntary transfer’’
and‘‘coercive transfer’’of policies. Dolowitz and Marsh (2000, p. 13) identify a continuum from the least coercive process of lesson drawing to the most coercive process of direct imposition. While coercion refers to formally or informally imposed change, several concepts have been developed to charac- terize the multiple forms of voluntary policy transfer. The notions of mimetism and normative isomorphism (Radaelli, 2000), lesson drawing (Rose, 1993), policy emulation (Levi-Faur, 2002, 2003), policy learning (Sabatier and Jenkins-Smith, 1993), or perceived necessity and external inducement (Dolowitz and Marsh, 2000) all designate processes of voluntary adaptation. However, these forms of policy transfer can vary between the
mere ‘‘copying of best practices’’ (mimetism or emulation*) and more
profound changes driven by expertise, professionalization, and socialization in (international) epistemic communities, and the redefinition of interests and policy ideas (for an overview, see Stone, 1999). Dolowitz and Marsh (2000, p. 8) raise six major questions for the study of policy transfer processes: Why
* ‘‘The distinction between emulation and learning captures the depth of considerations and seriousness of commitment in introducing policy changes. While emulation involves imitating action that occurs elsewhere, learning involves a redefinition of one’s interests on the basis of newly acquired knowledge’’ (Levi-Faur, 2003, p. 17). Emulation has some advantages in comparison to learning in terms of costs and time, since it is less resource-demanding, quicker in terms of results, more certain with regards to outputs, and less dependent on external resources. This leads Levi-Faur (2003, p. 23) to suggest that‘‘public officials in a weakstate will be more likely to emulate than their counterparts in a strong state.’’
do actors engage in policy transfer? Who are the key actors? What is transferred? From where are lessons drawn? What are the different degrees of transfer? What restricts or facilitates the policy transfer process? We shall draw inspiration from this analytical frameworkin order to identify the specific features of policy transfer that tookplace in each country.
All these authors insist on the increasing importance of international institutions and cross-national learning for domestic policy makers. Evans and Davies (1999), for instance, explicitly insert their conceptualization into a
‘‘multilevel perspective’’in order to stress the respective role of the global, regional, and national sources of policy transfer. Hence, when studying telecom policy reforms in The Netherlands, Austria, and Switzerland, one must also take into account the literature on the Europeanization of EU states, which has some important similarities with the policy transfer litera- ture. Broadly defined as the‘‘domestic assimilation of EU policy and poli- tics,’’Europeanization represents a form of policy transfer from the EU to the national states (see He´ritier et al., 2001; Green-Cowles et al., 2001; Radaelli, 2001; Bo¨rzel and Risse, 2002; Knill and Lehmkuhl, 2002). While the policy transfer literature adopts a more general perspective, the Europeanization literature is centered on the impact of the EU political and institutional frameworkon member states. But similarly to the policy transfer lit-erature, the focus is on what is transferred, who are the‘‘transposing agents’’pushing for the adjustment of domestic policies, what is the degree of transfer, and what restricts or facilitates policy changes (for an application of policy transfer theory to Europeanization in the electricity sector, see Padgett, 2003).
Europeanization mechanisms can be classified in two major categories:
vertical and horizontal, or, in other words, ‘‘coercive’’ and ‘‘normative isomorphism’’(Radaelli, 2001, pp. 124–125). Coercive isomorphism results from both formal and informal pressure exerted by European institutions, whereas normative isomorphism refers to mechanisms of socialization and persuasion of national elites through the development of conceptual models and policy recipes at the European level.* This conceptualization is close to that of a continuum between voluntary learning and coercive transfer by Dolowitz and Marsh (2000). Although some policies can be quite easily
* In a slightly different perspective, which more explicitly takes into account domestic political factors, Bo¨rzel and Risse (2002) distinguish two pathways leading to domestic reforms. First, changes in the international environment foster a‘‘redistribution of resources’’at the domestic level, which affects power relations among political actors and thus opens opportunities for policy reforms. Second, following a more sociological institutionalist approach, the authors stress the importance of‘‘learning processes’’among political and economic elites and the emergence of new‘‘norm entrepreneurs,’’who are expected to promote domestic reforms through an adequate‘‘framing’’of problems and solutions to them.
classified into one category or the other, most national policy reforms responding to the adoption of EU regulations generally include both dimen- sions. The adjustment of national telecom policies clearly involves a coercive dimension for EU member states regarding the compliance of national legislation with EU directives, but it also includes a more normative dimen- sion, which refers to the possible learning process undergone by national political and administrative actors.
Two general remarks should be made on these two bodies of literature.
First, the literature on Europeanization tends to overlooklearning processes and impulses for reform that are independent of the development of EU regulation. As will be shown in the Swiss and Dutch cases, learning processes and voluntary changes can be induced by channels of policy transfer other than formal EU pressure (such as other international organizations or purely economic pressures), or by mainly domestic concerns about the competitive- ness of the national economy (for a similar argument, see Levi-Faur, 2003, who compares EU member states and Latin–American countries).
Second, despite its usefulness and systematic character, the analytical frameworkof Dolowitz and Marsh (2000) remains mainly descriptive, and does not provide explanatory hypotheses for possible cross-national differ- ences in policy transfer processes. In particular, domestic economic and political characteristics are often insufficiently taken into account in the policy transfer literature.* The Europeanization literature more explicitly introduces political and institutional factors as elements likely to favor or impede policy changes induced by EU regulations. Thus, international or European reforms are supposed to affect the structure of opportunities and constraints domestic actors are confronted with, and, as a result, the preferences of these actors (He´ritier, 2001, p. 53). In a more cognitive perspective, the international or supranational regulations are expected to have a framing effect and to provide new ideas and understandings to domestic actors (Bo¨rzel and Risse, 2002).y
The following conceptual framework(Table 1) presents the factors we consider as mostly relevant for the understanding of policy transfer mecha- nisms in the telecom sector.
Two structural factors are expected to affect national actors’ config- urations and to facilitate policy reforms. First, besides its coercive dimension
* For a critique of lacking conceptual precision in the analytical framework of Dolowitz and Marsh, see James and Lodge (2003).
y Whether those actors whose preferences or ideas are in line with international evolutions will be able to bring about domestic policy reforms depends on the institutional structure of the decision-making process (veto points) and on the distribution of power among actors in each country.
linked to the necessity of compliance of national regulations with EU direc- tives, EU membership is supposed to facilitate voluntary domestic reforms because member states are associated with European decision making and because of the existence of‘‘epistemic communities’’at the EU level involving representatives from numerous policy sectors in the member states. Second, the varieties of democratic corporatist structures lead to different domestic political configurations. In the liberal corporatist countries, the presence of a strong export-oriented economic sector exposed to international competition is expected to favor the emergence of claims for telecom liberalization, whereas we expect such claims to remain much less important in the social version of corporatism. Such claims can, in turn, stimulate the emergence of national norm entrepreneurs. In this sense, we follow the distinction made by Bo¨rzel and Risse (2002) between domestic political and economic actors urging for reform, on one hand, and norm entrepreneurs, on the other hand.
The former are defined according to a rationalist institutionalist perspective of change, and the latter according to a sociological institutionalist approach.
Domestic actors calling for policy change mostly come from the political arena. They are considered as rational and goal-oriented, using their resources to satisfy clearly defined interests. Norm entrepreneurs, in turn, mostly come from the administrative arena. They do not so much pressure policy makers to initiate change, but rather seekto persuade actors to redefine their interests and to become involved in learning processes.*
Table 1 Explanatory Factors for the Mechanisms of Policy Transfer in the Telecom Sector
* In a similar vein, Jobert (1992) distinguishes between ‘‘arenas,’’where actors compete to maximize their interests, and‘‘fora,’’where actors engage into mutual learning.
B. Multilevel Processes in Telecom Sector Reforms
In Europe and more specifically in the three countries under scrutiny, public monopolies under state supervision have in the past been the central actors for the provision of telecommunication services. Since the beginning of the 1980s, however, the telecom sector has been facing profound transformations around the world. These changes, driven by technological innovations, market liberalization, and ideological shifts among political authorities, have been combined with the emergence of new regulations at the international and national levels.
In the EU, the Commission played a crucial role in giving the impulses for a‘‘step-by-step’’liberalization of the telecommunication sector, outlined in the famous green paper on the common market for telecommunications of 1987 (for an overview, see Sandholtz, 1998; Schmidt, 1998). Sandholtz (1998) speaks of the formation of a‘‘supranational regime’’in this policy field within the EU under the impulse of the Commission.* However, this supranational push for liberalization was only possible with the tacit approval of the major member states (Schneider, 2001; Thatcher, 2001). From the end of the 1980s onward, efforts to create a European market for telecommunications were concretized through the adoption of a large body of EU regulations and jurisprudence concerning mainly four aspects of telecommunication policy:
the liberalization of services, the nondiscriminatory access of new operators to existing infrastructure (interconnection), the definition of the universal service, and the separation of operational and regulatory functions of the market regulator (Slominski, 2002). Even if the transposition of EU directives into national law leaves some degree of freedom to domestic adaptation, member states tend to converge in telecom policies, characterized by liberal- ization, partial privatization, and creation of a new regulatory framework (Eliassen and Sjovaag, 1999).
In all three countries under scrutiny, there was initially a certain degree of ‘‘misfit’’between the new EU regulations adopted since the end of the 1980s and domestic legislation. Just before the‘‘full competition’’directives came into force on January 1, 1998, the three countries had profoundly reformed their telecommunications legislation in line with EU directives.
However, and despite the importance of EU regulations, the mechanisms of transfer from the EU to the national level cannot be interpreted as a simple
* In a more sophisticated analytical framework, Levi-Faur (1999, 2004) distinguishes different regimes with respect to the EU policy process: no EU regime, informal regime, inter- governmental regime, and supranational regime. These four categories highlight the different degrees of EU influence on national policies. Different regimes can coexist within the same policy domain.
‘‘download’’from the EU to the member states. Other factors independent of the European evolution, such as technological innovations, economic liber- alization, learning among national elites, or domestic political impulses, also account for national telecom policy reforms. Telecom policy reform should then be primarily conceived as a‘‘multilevel process’’(Evans and Davies, 1999), which implies global, European, and national sources of policy changes. In the next part, we will show how the reform processes differed across countries and we shall focus on factors specific to each country under scrutiny to explain these different paths.
IV. DIFFERENT MECHANISMS OF CONVERGENCE