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Public Consultation in the EU Climate Change Policymaking: A Case Study of the Environmental Action Programme

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The European Union (EU) has sought to strengthen democratic legitimacy in policymaking by promoting participatory governance. Since 2015, the EU has officially included public consultation in its legislative process. However, the extent to which this mechanism influences climate policy remains underexplored. This study examines the decision-making process of the Eighth Environmental Action Programme (EAP) as a case study, analyzing key actors involved in public consultation, the major issues they raised, and the extent to which their input influenced the final policy text through text analysis. The findings reveal three key patterns. First, stakeholder representation in public consultation was highly imbalanced, with NGOs and industry groups dominating participation, while individual citizens, academia, and public authorities remained significantly absent. Second, participation was geographically skewed toward Western European countries, particularly from Belgium, Germany, and Austria, whereas input from Eastern European countries was minimal, indicating geographical disparities in engagement. Third, a stark contrast emerged between industry groups and NGOs regarding policy priorities. Industry respondents emphasized “economic growth,” while NGOs focused on “climate change,” and academia and public authorities prioritized “enforcement” and “monitoring.” Although public consultation played a crucial role in agenda-setting by incorporating diverse stakeholder perspectives, its impact on the final policy text was limited. The final decision was primarily shaped by institutional negotiations between the European Parliament and the Council of the European Union. The Parliament, aligning with NGOs and academia, advocated for binding climate targets, whereas the Council prioritized policy flexibility and feasibility. This study provides an in-depth analysis of the 8th EAP as the first environmental action programme to formally integrate public consultation. By tracing the entire policymaking process, it empirically assesses the role and limitation of public consultation in EU climate policy. The findings contribute to broader discussion on participatory governance in the EU.

Abstract

The European Union (EU) has sought to strengthen democratic legitimacy in policymaking by promoting participatory governance. Since 2015, the EU has officially included public consultation in its legislative process. However, the extent to which this mechanism influences climate policy remains underexplored. This study examines the decision-making process of the Eighth Environmental Action Programme (EAP) as a case study, analyzing key actors involved in public consultation, the major issues they raised, and the extent to which their input influenced the final policy text through text analysis. The findings reveal three key patterns. First, stakeholder representation in public consultation was highly imbalanced, with NGOs and industry groups dominating participation, while individual citizens, academia, and public authorities remained significantly absent. Second, participation was geographically skewed toward Western European countries, particularly from Belgium, Germany, and Austria, whereas input from Eastern European countries was minimal, indicating geographical disparities in engagement. Third, a stark contrast emerged between industry groups and NGOs regarding policy priorities. Industry respondents emphasized “economic growth,” while NGOs focused on “climate change,” and academia and public authorities prioritized “enforcement” and “monitoring.” Although public consultation played a crucial role in agenda-setting by incorporating diverse stakeholder perspectives, its impact on the final policy text was limited. The final decision was primarily shaped by institutional negotiations between the European Parliament and the Council of the European Union. The Parliament, aligning with NGOs and academia, advocated for binding climate targets, whereas the Council prioritized policy flexibility and feasibility. This study provides an in-depth analysis of the 8th EAP as the first environmental action programme to formally integrate public consultation. By tracing the entire policymaking process, it empirically assesses the role and limitation of public consultation in EU climate policy. The findings contribute to broader discussion on participatory governance in the EU.

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