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Evaluating Integrated Impact Assessments

Final Report Summary - EVIA (Evaluating Integrated Impact Assessments)

The analysis of potential impacts of new policies before their adoption is a standard tool of governmental practice in industrialised countries. Impact assessment (IA) - often also referred to as Regulatory impact assessment (RIA) - typically describes a problem, identifies policy measures, assesses possible effects and describes options to achieve the policy objectives in a most efficient way. IAs are usually conducted by the rule-making department. The aim is to improve the overall quality of regulation by rationalising the process of policy making. By making available information on possible costs and benefits and stimulating an early interdepartmental coordination, decision-makers should be enabled to choose the policy option with the greatest benefits and lowest costs. IA procedures vary from country to country, both regarding the level of institutionalisation and regarding the scope of analysis.

Although the traditional objective of reducing regulatory burden is clearly still present - and reinforced in some countries - we observe that in many countries IA has been broadened towards an inclusion of generic objectives such as environmental concerns, competitiveness and sustainability. Such an integrated perspective aims to reveal conflicts between objectives and to identify win-win solutions. It further requires the integration between different sectoral assessment procedures. For some years, efforts have been made to establish new forms of integrated IA that allow for a comprehensive assessment of all possible impacts of new legislation, including unintended side effects and the assessment of interlinkages between different issues of concern. The introduction of these integrated approaches has been met with considerable interest and also great expectations. However, there has also been criticism that the integration of different issues of concern into a single assessment procedure may run the risk of a capacity overload.

Based on these findings, we argue that addressing these structural barriers requires a rethinking of IA - not just in terms of institutions and methods, but also of its functions, processes and limitations. While the diversity of national assessment approaches and contexts makes it impossible to set out simple recommendations that apply in all countries, we propose a number of conclusions for the further development of IA. It is legitimate and appropriate that Member States pursue different objectives through IA and that they adapt procedures to suit their national contexts. On the other hand, the multi-level nature of policy-making requires better linkages between IA at different levels.

We therefore see a strong potential for the EU as a platform to improve connections between IA at European and at national level, to promote broadening of assessments beyond direct economic costs, and to support efforts to improve implementation. The EU has a role to play in helping clarify what the Member States may expect from this tool and in encouraging governments to systematically support implementation. The adoption of a common set of regulatory quality indicators would be an important step towards understanding the magnitude and effects of the current diversity and to identify areas in which convergence is desirable.

The trend to move responsibility for IA to higher levels of hierarchy and to introduce central quality control can be a useful strategy to strengthen the procedure. It is, is, however, important that this is complemented with an improvement of administrative capacity. Creating institutions in the core executive is of little value if resources (budget, time and responsibility) for policy formulation and IA are not delivered to departments. Mechanisms for quality control also need to adopt a sufficiently wide notion of 'quality' (including process issues and the full range of impacts covered by the procedure).

In some countries, the evidence-based dimension of policy formulation is usefully combined with the political dimension of negotiation and bargaining. In others, the fragmentation of the political system makes it difficult to strengthen the role of evidence. IA procedures alone will not change the basic dynamics of political decision-making. If the purpose is to increase the space for evidence-based policy formulation, governments have to appreciate the magnitude of this task and make efforts to make the necessary wide-ranging institutional changes.

We have often encountered the expectation that there is a clear 'division of labour' between assessment and politics. IA should provide the 'answer' and identify the best policy option, then disappear from the scene to let politicians do the bargaining. In our view, this idea is misleading. IAs do not give a single answer, but frame problems, scope solutions and uncover possible side-effects of policy measures. They do not disappear from the scene, but remain a reference point in political bargaining and support ex post evaluation of policies. In short, IAs should support the decision making throughout the whole policy cycle.

Integrating cross cutting issues through IA is a challenging task. On the one hand, a broad scope of the assessment is important to avoid that policies create new problems through the solution of old ones. On the other hand, integration can lead to capacity overload, confusion and irrelevance in the decision process. Ultimately, the right balance cannot be prescribed by guidelines but has to be found in individual assessments. Overall, it seems useful to define an overall broad scope, but to implement it through targeted analytical methods and tools. Rather than pursuing the over-ambitious - and in many cases misleading - objective of full integration in a single methodology, IAs should connect and compare different impacts.

The project results and conclusions will be published in a 'Handbook impact assessment'. The aim of the book is to provide a broad overview of conceptual foundations of and practical experiences with IA. It builds on a unique empirical basis of research on IA procedures and practices in all EU Member States. The book is addressed to both the academic community and to IA practitioners. It does not provide practical guidance for those directly involved in individual assessments, but a source of information and reflection for those studying, designing and implementing IA procedures.

Further dissemination activities include a number of academic papers that are currently under review and the dissemination of the policy paper. Together with other projects in the field of IA, a pooling of case studies will be explored.