political advocacy in disguise?
According to risk governance scholars simple risks are rare. That is, risks for which both the probability of a threat materializing and a concrete assessment of its consequences only constitute a marginal category of risks confronting public decision-makers. Instead, public decision-makers face risks that are complex (no linear casual mechanism), uncertain (consequences and effect sizes are unknown) and ambiguous (multiple contested and diverse perspectives exist in society regarding the severity and wider implications of risks) (Renn et al 2011; van Asselt and Renn 2011). This implies, first, that risks are scientifically hard to grasp and, second, that they are to a large extent in the eye of the beholder because of diverging human and political interpretations of risks.
According to risk governance scholars, such societal challenges require the involvement of all interested and affected parties to enable inclusive and effective decision-making. Yet, the obvious need for non-state stakeholder engagement also raises important questions: how to balance and assess the different information offered by non-stakeholders? And, would such engagement offer non-stakeholders the opportunity to spin a risk?
With these general questions as starting point we set out, in a joint MA thesis project, to investigate the role of non-state stakeholders in risk governance. We addressed multiple issues associated with this theme, including the extent to which non-state stakeholders are involved throughout the multiple stages of the risk governance process, which voices are heard in the process, to what extent risks can be strategically exploited by non-state stakeholders to suit their own interests and to what extent a risk turning into a crisis leads to strategic behaviour by non-state stakeholders.
Does the involvement of stakeholders vary throughout the stages of risk governance?
While the necessity of including stakeholders within the risk governance process is emphasized within risk governance theory, empirical testing of these assumptions is lacking. Thus, Hannah Kroes focused in her thesis on testing these assumptions within the setting of the European Commission, using the theoretical expectations of risk governance theory, supplemented with stakeholder engagement literature. This research resulted in the following findings. Risk governance affects how stakeholders are involved, not which stakeholders are involved. Kroes found a significant association between consultation instruments (how stakeholders are involved) and risk governance stages. However, the stages in which this involvement took place were not always expected based on theory. For example, while there was no expectation of stakeholder involvement in scientific risk assessment, in practice most of the stakeholder involvement was found in this stage, as opposed to the others. In general, while expected based on theory, Kroes found no significant association between risk governance stages and stakeholder types.
Is stakeholder engagement in risk governance biased?
Stakeholder involvement is a crucial element of risk governance because it allows policymakers to compile an overview of societal interests concerning potential risks in legislation. However, Van Hunen demonstrates in her study that in public consultations a bias exists in stakeholder representation (inequality in representation between interest groups in stakeholder consultations), which could affect the variation of input of risk perceptions and possibly influence policymaking. Her research focuses on whether the level of salience and policy type are associated with the level of bias in stakeholder representation in open consultations of the EC. Both associations have been analysed according to two stakeholder classifications: group type (citizen groups, firms, etc.) and geographical orientation ((sub)national, European, international). The data and Van Hunen’s research did not support such associations except for a weak association between policy type and stakeholder group’s geographical orientation.
Which voices are actually heard in risk governance?
In the EU, public health is one of today’s „hot button“ issues, touching upon democratic legitimacy and the (perceived) high level of influence wielded by professional stakeholders. Bartz’ thesis set out to ask how the input of different sets of stakeholders is reflected in the EU’s consultation regime by investigating the consultations held by the European Commission for a recommendation proposed to tackle vaccine hesitancy. Evaluating the consultation (using R software) with stakeholders and citizens showed that survey groups were talking in different languages, focusing on differing aspects of the issue. Remarkably, the legislative proposal was very similar in language and sentiment to those expressed by the survey group of stakeholders. This indicates that the Commission, in this case, listens to stakeholders more than to citizens, showcasing a mobilisation bias and a need for expertise. The Commission’s approach to risk governance is ticking the boxes of our contemporary understanding of risk governance by engaging stakeholders and citizens, but not all voices are heard in quite the same way.
To what extent are risks strategically exploited by non-state stakeholders?
Starting from the assumption that uncertainty in risk governance is of subjective nature, Zull theoretically deduced that stakeholders might be able to exploit such uncertainty to their own advantage. Applying a media and document analysis, scrutinising the discussion about glyphosate in the EU, resulted in strong evidence that strategic stakeholder framing enabled the exploitation of scientific uncertainty and consequently lead to the mobilisation of the public as well as the conveyance of specific frames to decision-makers. In light of the overwhelming scientific uncertainty and the likely exploitation of stakeholders, it might be reasonable for decision-makers to look into alternative approaches to deal with high uncertainty in the risk governance process.
Would non-state stakeholders behave strategically if risks turn into crises?
In her thesis, Griesenbrock explored the relationship between stakeholder framing and policy change in the context of the fipronil affair in 2017 – a case with high salience and a huge level of conflict. The crisis exploitation literature suggests, that framing contests between stakeholders influence policy outcomes. By means of a media analysis, Griesenbrock assessed the strategic behaviour of defenders and attackers of the status quo to explain why the food scarce did not result in a major policy change. The evaluation of framing patterns unravelled that change advocates used strategic framing more often than change opponents. They underlined the need for change by stressing the event significance, focusing blame, and referring to the interests of the European public. However, the defensive forces outnumbered the progressive voices. Furthermore, proponents of change suggested only few and vague policy alternatives and failed to mobilize public opinion, which were identified as the main reasons for the lack of change.
All of these master thesis projects show that risk governance, similar to other types of public decision-making and governance processes, heavily depends on the involvement of non-state stakeholders. At the same time, the findings also indicate that non-stakeholder involvement requires appropriate institutional arrangements to render the process both inclusive and effective. Also, and in the same vein as ‘normal stakeholder engagement,’ responsiveness of public officials, or public institutions more generally, is a crucial element in ensuring a legitimate process. In all, while it might be challenge in itself to properly do so, inclusive and effective stakeholder engagement is a core aspect of democratic decision-making both in normal ánd in risky times.
Renn, O., Klinke, A. and van Asselt, M. (2011), ‘Coping with Complexity, Uncertainty, and Ambiguity in Risk Governance: A synthesis’, Ambio, A journal of the Human Environment, 40(2): 231-246
Van Asselt, M. and Renn, O. (2011), ‘Risk Governance’, Journal of Risk Research, 14(4): 431-449