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Implementation of public policy : a case study Shanks, Gordon Ross 1983

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IMPLEMENTATION OF P U B L I C P O L I C Y A " C A S E STUDY I by GORDON ROSS SHANKS B . A . , U n i v e r s i t y o f S a s k a t c h e w a n , 1969 M . A . , U n i v e r s i t y o f B r i t i s h C o l u m b i a , 1972 A T H E S I S SUBMITTED I N P A R T I A L F U L F I L L M E N T OF THE REQUIREMENTS FOR THE DEGREE OF DOCTOR OF PHILOSOPHY i n THE FACULTY OF GRADUATE S T U D I E S S c h o o l o f C o m m u n i t y a n d R e g i o n a l P l a n n i n g We a c c e p t t h i s t h e s i s as c o n f o r m i n g t o t h e r e q u i r e d s t a n d a r d THE U N I V E R S I T Y OF B R I T I S H COLUMBIA (c) G o r d o n R o s s S h a n k s , 1983 In presenting t h i s thesis i n p a r t i a l f u l f i l m e n t of the requirements fo r an advanced degree at the University of B r i t i s h Columbia, I agree that the Library s h a l l make i t f r e e l y a v a i l a b l e for reference and study. I further agree that permission for extensive copying of t h i s thesis f o r s c h o l a r l y purposes may be granted by the head of my department or by h i s or her representatives. I t i s understood that copying or p u b l i c a t i o n of t h i s thesis f o r f i n a n c i a l gain s h a l l not be allowed without my written permission. Department of Community and Regional Planning The University of B r i t i s h Columbia 1956 Main Mall Vancouver, Canada V6T 1Y3 Date September 30 r 1983 DE-6 (3/81) ( i i ABSTRACT Students of public policy have, u n t i l recently, centred their attention on the process by which p o l i c i e s are formulated, based on the i m p l i c i t assumption that a well-fbrmulated policy w i l l be f a i t h f u l l y implemented. Disillusionment with policy outcomes in many areas has led to a concern for understanding the factors which influence the implementation of policy. As a f i r s t step, t h i s study develops a theoreti c a l role for an i d e n t i f i a b l e implementation process within a larger public policy process. The study develops two related models. The f i r s t i d e n t i f i e s four s t r u c t u r a l components in the implementation process: policy output, i n i t i a t i o n of implementation, implementation action and information feedback. The second model hypothesizes the important elements which characterize an implementation process and influence the movement from a policy output to a policy outcome. Eight elements are i d e n t i f i e d : implementing actors, policy objectives, resources, interested actors, policy environment, incentives and sanctions, stakes, and rules. The hypothesized linkages among the elements are described. Based upon these two models, the determinants bf policy outcome are posited. In i i i addition to the eight process elements, these include: technical t r a c t a b i l i t y of problem, policy environment, decision-making environment, and uncertainties. The t h e o r e t i c a l framework i s applied to a case study bf the Canada-British Columbia Okanagan Basin Implementation Agreement (OBIA). The stages leading up to implementation of the recommendations bf an e a r l i e r framework planning study are described. The i n i t i a t i o n of implementation culminated in the signing of a j o i n t f ederal-provincial Implementation Agreement which responded to the recommendations of the plan but re-interpreted many bf these. The analysis demonstrates the importance of a pre-implementation phase wherein policy objectives and intentions are re-examined, interpreted, and operationalized prior to implementation action. Action under the OBIA i s described and analysed for four s p e c i f i c cases concerning water quality, water quantity, international aspects, and public p a r t i c i p a t i o n . The empirical conclusions indicate the technical aspects of the OBIA have been implemented according to the obligations of the Agreement. Departures from the Agreement were based on careful technical analysis. Implementation was viewed by the implementbrs as a technical, mechanistic process with l i t t l e regard to s o c i a l value uncertainties. i v The study provides an examination of the u t i l i t y of the th e o r e t i c a l models. It concludes that the hypothesized variables can describe the functioning of an implementation process and provide a comprehensive a n a l y t i c a l picture. The highlights of the conclusions are: the j u r i s d i c t i o n a l breakdown between the federal and provincial governments as interpreted by and reflected in the objectives of the key implementing actors was very s i g n i f i c a n t in shaping the outcome. The s p e c i f i c i t y of the policy output in terms of intentions and a r t i c u l a t i o n of uncertainties had an impact as did the r i g i d i t y of the implementation mechanism. Resource constraints were a s i g n i f i c a n t determinant of outcome, supporting a proposition that resource a v a i l a b i l i t y be c a r e f u l l y analysed in a pre-implementation phase. Interested actors had an influence in proportion to the degree of dir e c t impact implementation measures had upon sp e c i f i c i n t e r e s t s . Uncertainties in technical and quantitative areas appear to have been well managed, whereas value uncertainties were generally not considered. The study evidence suggests i f an implementation process i s i n f l e x i b l e and cannot adapt to changing so c i a l circumstances by embracing uncertainties, i t w i l l become irre l e v a n t , and the current issues w i l l be considered outside of the implementation process. V TABLE OF CONTENTS Page ABSTRACT i i : LIST OF FIGURES x i i l ACKNOWLEDGEMENTS x i i i CHAPTER 1 POLICY IMPLEMENTATION - THE NEGLECTED PROCESS 1 1. 1 PURPOSE OF STUDY 1 1.2 BACKGROUND 5 1.3 A STUDY OF IMPLEMENTATION 8 1.4 THE PUBLIC POLICY PROCESS - THE CONTEXT FOR IMPLEMENTATION 10 1.4.1 P o l i c y Formation Process 13 1.4.2 P o l i c y Output 14 1.4.3 P o l i c y Implementation Process 16 1.4.4 P o l i c y Outcome 19 1.4.5 P o l i c y Environment 21 1.4.6 Summary bf P o l i c y Process 22 1.5 PERVASIVE THEMES - VALUES AND UNCERTAINTY 24 1.5.1 A p p l i c a t i o n of Values 24 1.5.2 Uncertainty 26 1.6 SUMMARY 34 CHAPTER 2 REVIEW OF IMPLEMENTATION AND RELATED LITERATURE 35 2. 1 INTRODUCTION 35 2.2 IMPLEMENTATION AS A TOPIC OF INQUIRY 40 v i TABLE OF CONTENTS - CONTINUED Page 2.3 UNDERSTANDING IMPLEMENTATION 43 2.4 ELEMENTS OF THE IMPLEMENTATION PROCESS 51 2.4.1 P o l i c y Standards and Objectives 53 2.4.2 P o l i c y Resources 58 2.4.3 I n t e r o r g a n i z a t i o n a l Communication 64 2.4.4 C h a r a c t e r i s t i c s bf Implementing Agencies .... 72 2.4.5 D i s p o s i t i o n of Implementors 83 2.4.6 P o l i c y Environment 95 2.5 KIND OF PROCESS 96 2.6 POTENTIAL FOR IMPROVEMENTS TO IMPLEMENTATION PROCESS 99 2.6.1 Implementation A n a l y s i s 100 2.6.2 Implementation Assessment 101 2.7 CONCLUSIONS 114 CHAPTER 3 DETERMINANTS OF POLICY OUTCOME - A BASIS FOR EMPIRICAL RESEARCH 115 3. 1 INTRODUCTION 115 3.2 POLICY IMPLEMENTATION - SOME HYPOTHESES 115 3.3 A STRUCTURE FOR POLICY IMPLEMENTATION 118 3.3.1 P o l i c y Output 120 3.3.2 I n i t i a t i o n of Implementation 124 3.3.3 Implementation Action 128 3.3.4 Information Feedback 129 3.3.5 Summary of Structure for P o l i c y Implementation 132 v i i . TABLE OF CONTENTS - CONTINUED Page 3.4 MODEL OF POLICY IMPLEMENTATION PROCESS 133 3.4.1 Implementing Actors 135 3.4.2 Objectives 143 3.4.3 Resources 145 3.4.4 Interested Actors 146 3.4.5 P o l i c y Environment 150 3.4.6 Incentives and Sanctions 151 3.4.7 Stakes 152 3.4.8 Rules 154 3.5 DETERMINANTS OF POLICY OUTCOME 155 3.6 EMPIRICAL RESEARCH DESIGN 158 3.6.1 Case Study Approach 158 3.6.2 Data A c q u i s i t i o n 162 3.6.3 L i m i t a t i o n s i n the Scope of the Case Study .. 164 CHAPTER 4 DEFINING THE POLICY OUTPUT 167 4. 1 INTRODUCTION 167 4.2 CONDITIONS PRIOR TO THE PLANNING STUDY 169 4.3 A COMPREHENSIVE FRAMEWORK PLANNING STUDY 173 4.3.1 Comprehensive Water Management 177 4.3.2 Study Time Horizon 180 4.3-3 Study Management 181 4.3.4 Study Target Population 182 4.3.5 Requirement for Implementation 184 4.4 STUDY OUTPUT 185 4.4.1 Regional A u t h o r i t y 187 V i i i . TABLE OF CONTENTS - CONTINUED Page 4.4.2 Framework Plan Implementation 190 4.4.3 Water Quantity 195 4.4.4 I n t e r n a t i o n a l Aspects 197 4.4.5 Water Q u a l i t y 199 4.4.6 Monitoring Framework Plan 203 4.5 SUMMARY AND CONCLUSIONS 205 CHAPTER 5 INITIATING IMPLEMENTATION OF THE COMPREHENSIVE FRAMEWORK PLAN 208 5.1 PURPOSE 208 5.2 DEVELOPING AN IMPLEMENTATION AGREEMENT 208 5.3 THE IMPLEMENTATION AGREEMENT 213 5.3.1 Non-Coordinated Water Management - A Change i n Objectives 216 5.3.2 Limited Local P a r t i c i p a t i o n - A Change in I n s t i t u t i o n a l Arrangements 219 5.3.3 Flood Control Works - A Change i n A c t i v i t i e s 224 5.4 STRATEGIES FOR UNCERTAINTY 228 5.5 FACTORS ACCOUNTING FOR CHANGES 230 5.5.1 P o l i c y Objectives 231 5.5.2 P o l i c y Stakes 232 5.5.3 Implementing Actors 241 5.5.4 Interested Actors 246 5.5.5 Decision-Making Environment 249 5.5.6 P o l i c y Environment 253 5.5.7 Resources 254 5.6 SUMMARY AND CONCLUSIONS 255 i x TABLE OF CONTENTS - CONTINUED Page CHAPTER 6 ACTIONS UNDER THE OKANAGAN BASIN IMPLEMENTATION AGREEMENT 259 6. 1 INTRODUCTION 259 6.2 ORGANIZATION FOR IMPLEMENTATION 260 6.3 CASE 1 - WASTE'TREATMENT AND THE REGIONAL AUTHORITY 264 6.3.1 B a s i n Waste Management Plan 277 6.4 ANALYSIS 292 6.4.1 P o l i c y O b j e c t i v e s 293 6.4.2 Implementing A c t o r s 296 6.4.3 I n t e r e s t e d A c t o r s 300 6.4.4 S t a k e s 301 6.4.5 Resources 303 6.4.6 Other F a c t o r s 305 6.5 CASE 2 - ALTERING OPERATING LEVELS ON THE MAINSTEM SYSTEM 307 6.6 ANALYSIS 326 6.6. 1 P o l i c y Output 327 6.6.2 Resources 328 6.6.3 U n c e r t a i n t i e s 329 6.6.4 P o l i c y O b j e c t i v e s 330 6.6.5 Implementing A c t o r s 331 6.6.6 Other F a c t o r s 335 6.7 CASE 3 - THE OSOYOOS LAKE REFERENCE 337 X TABLE OF CONTENTS - CONTINUED Page 6.8 ANALYSIS 3 4 9 6 . 8 . 1 P o l i c y O b j e c t i v e s 3 4 9 6 . 8 . 2 S t a k e s 3 5 0 6 . 8 . 3 I m p l e m e n t i n g A c t o r s 3 5 1 6.9 CASE 4 - PUBLIC PARTICIPATION 3 5 3 6. 1 0 ANALYSIS 3 6 4 6 . 1 0 . 1 I m p l e m e n t i n g A c t o r s 3 6 5 6 . 1 0 . 2 P o l i c y O b j e c t i v e s 3 6 7 6 . 1 0 . 3 I n t e r e s t e d A c t o r s 3 6 8 6 . 1 0 . 4 R e s o u r c e s 3 6 9 6 . 1 0 . 5 O t h e r F a c t o r s 3 7 0 6 . 1 1 SUMMARY AND CONCLUSIONS 3 7 2 CHAPTER 7 SUMMARY AND CONCLUSIONS 3 7 7 7. 1 INTRODUCTION 3 7 7 7 . 2 EMPIRICAL CONCLUSIONS 3 7 7 7 . 2 . 1 P o l i c y O u t p u t 3 7 8 7 . 2 . 2 I m p l e m e n t a t i o n Agreement 3 7 9 7 . 2 . 3 I m p l e m e n t a t i o n A c t i o n 3 8 3 7 . 3 ANALYTICAL CONCLUSIONS 3 8 7 7 . 3 . 1 F a c t o r s R e s p o n s i b l e f o r B a s i c Changes 3 8 8 P o l i c y O b j e c t i v e s 3 8 9 P o l i c y E n v i r o n m e n t 3 9 0 x i TABLE OF CONTENTS - CONTINUED Page Implementing Actors 393 Interested Actors 399 7.3.2 Factors Accounting for Implementation Actions 401 Technical T r a c t i b i l i t y b f a Problem 401 P o l i c y Output 403 Implementing Actors 405 P o l i c y Objectives 408 Resources 409 Interested Actors 412 Stakes 414 Rules :". . . 414 P o l i c y Environment 415 Decision-Making Environment 416 Un c e r t a i n t i e s 418 7.3-3 Indeterminancy b f Process Outcome 421 7.3.4 Further Research 423 7-3.5 C o n t r i b u t i o n b f Study 425 BIBLIOGRAPHY 428 APPENDIX 1 CANADA - BRITISH COLUMBIA OKANAGAN BASIN AGREEMENT APPENDIX 2 OKANAGAN BASIN IMPLEMENTATION AGREEMENT x i i LIST OF FIGURES Page 1.1 A SIMPLIFIED MODEL OF A POLITICAL SYSTEM 11 1.2 MODEL OF POLICY PROCESS 12 2.1 A MODEL OF POLICY IMPLEMENTATION PROCESS 52 2.2 MODEL FOR DOSRAP 107 3.1 STRUCTURE OF POLICY IMPLEMENTATION 119 3.2 MODEL OF POLICY IMPLEMENTATION PROCESS 134 4.1 THE OKANAGAN BASIN 168 4.2 ORGANIZATION STRUCTURE 176 4.3 COMPREHENSIVE FRAMEWORK PLAN MANAGEMENT 182 6.1 IMPLEMENTATION ORGANIZATION 261 x i i i ACKNOWLEDGEMENTS I wish to express my appreciation to Professor Irving K. Fox for his excellent c r i t i c i s m and insights into the questions covered in t h i s study. Thanks are due to many people for providing comments and information during the formulation and undertaking bf the study. In p a r t i c u l a r , the s t a f f s at Inland Waters Directorate, Environment Canada in Vancouver and the Water Resources Branch, B r i t i s h Columbia Department bf Environment, V i c t o r i a gave substantial time for which I am indebted. The study was supported for one year by the Humanities and Social Sciences Research Council. The manuscript was typed many times over by Annette G i r l i n g often under unreasonable conditions and deadlines. Her assistance has been invaluable and i s g r a t e f u l l y acknowledged. F i n a l l y , I would l i k e to sincerely thank my wife, Marilyn, and sons, Gareth and Robert, for a l l bf those weekends and evenings. Without their understanding and encouragement, th i s would not have been possible. 1 CHAPTER 1 POLICY IMPLEMENTATION - THE NEGLECTED PROCESS "Canadians r e a l i z e that i t i s no longer p o s s i b l e to take for granted clean a i r and pure water, the p r o d u c t i v i t y of our s o i l and sea resources, or the charm of the countryside ... This concern has developed i n t o a consensus that environmental management i s a major problem that demands p r i o r i t y a t t e n t ion . Research can c e r t a i n l y devise t e c h n o l o g i c a l answers to t e c h n o l o g i c a l problems. It can also increase the vast array of environmental management s t r a t e g i e s now a v a i l a b l e . The need for t h i s i s evident and the past decade has seen growing p u b l i c demand for c l e a r and strong government i n t e r v e n t i o n . " J. W. M a c N e i l l , Environmental Management, Prepared for The Privy Council O f f i c e , Government of Canada ( 1 9 7 1 , p. 8 ) . 1.1 PURPOSE OF STUDY Environmental management as a p u b l i c o b j e c t i v e does not seem to a t t r a c t the wide coverage and generate the pu b l i c enthusiasm that i t did only a few years ago. There are undoubtedly numerous hypotheses that could be put forward as po s s i b l e explanations for why the "environment" has sl i p p e d on the pu b l i c agenda. A c a r e f u l a n a l y s i s would, however, re v e a l that many of the environmental problems and concerns which surfaced in the pu b l i c consciousness i n the 1960s and 1970s are s t i l l very r e a l and, i n many cases, much more s e r i o u s . Moreso than ever, i t i s important to understand the processes by which these problems are addressed and d e a l t with . Planners have g e n e r a l l y been considered to be l e g i t i m a t e l y involved in addressing p u b l i c issues through the planning process by which a l t e r n a t i v e plans are formulated to achieve s p e c i f i c p u b l i c o b j e c t i v e s . In i t s most basic f o r m u l a t i o n , the planning model i n c l u d e s : (a) problem d e f i n i t i o n i n c l u d i n g statements of values and o b j e c t i v e s ; (b) information concerning the problem; (c) a l t e r n a t i v e s o l u t i o n s ; (d) an accepted plan or course of a c t i o n ; and (e) implementation of the plan. This planning model as a problem s o l v i n g methodology also recognizes the i t e r a t i v e nature of the process and normally l i n k s the implementation phase back to the information generation phase. The l o g i c i s obvious; during implementation, information gaps become evident which may lead to a d i f f e r e n t array of s o l u t i o n s and choices or even might serve to s h i f t or a l t e r process o b j e c t i v e s . Through a s e r i e s of i t e r a t i o n s , the process should move toward desired ends. This i s , of course, a very s i m p l i s t i c d e s c r i p t i o n of the planning process. Very r e a l questions, such as whose values and o b j e c t i v e s are or ought to be pursued; who determines what information w i l l be brought to bear ; who i s involved in formulating a l t e r n a t i v e s and in whose i n t e r e s t ; how are m i n o r i t y or opposing i n t e r e s t s considered and accounted; and so on, demonstrate that the processes which operate w i t h i n t h i s b asic model re q u i r e d e t a i l e d understanding. The purpose of t h i s study i s to add some a d d i t i o n a l i n s i g h t s to the already s u b s t a n t i a l understanding of t h i s complex process, s p e c i f i c a l l y i n the area of implementation. The basic normative premise of t h i s study i s not very r e v o l u t i o n a r y or bold but as a normative statement seems d e f e n s i b l e ; i t i s that the process of environmental management as p r a c t i s e d in Canada can be improved, understanding gained through research can be applied to the p r a c t i c a l s i t u a t i o n s f a c i n g s o c i e t y and improvements can be made. Even t h i s statement r e s t s somewhat on shaky ground; who i s to say what i s better or i s an improvement. I t i s tempting to o u t l i n e the features of a good or adequate process for environmental management against which to measure current or past performance. This would, however, go w e l l beyond the bounds of s c i e n t i f i c a n a l y s i s i n t o ideology, philosophy and p o l i t i c s . This study cannot, and does not intend t o , comment on the r i g h t n e s s or adequacy of the p o l i c y process or any po r t i o n thereof. What i t can do i s analyse the process to under stand : (a) those v a r i a b l e s which are important i n s t r u c t u r i n g and moving the process and speculate how these could be influenced to change the p o l i c y outcome; and (b) the methods by which information i s generated and evaluated, values are accounted for and d e c i s i o n s are taken and implemented. I t i s quite d e f e n s i b l e to analyse a p o l i c y process from the viewpoint of how i t might be modified i f a p a r t i c u l a r outcome i s d e s i r e d . This does not lead to a conclusion that a process should be changed because i t would produce a b e t t e r outcome. A p o s i t i v e a n a l y s i s provides process p a r t i c i p a n t s with information as to how to a f f e c t the outcome. I t i s also l e g i t i m a t e to analyse the methods employed i n a process to determine t h e i r e f f e c t i v e n e s s i n achieving the o b j e c t i v e . Again, t h i s does not question the o b j e c t i v e but rather brings information to bear which can suggest improved ways of achieving the o b j e c t i v e , for example, at a lower cost i n time or money, or with l e s s f i l t e r i n g and/or d i s t o r t i o n , e t c . While the u l t i m a t e o b j e c t i v e of the study, to improve the environmental management process, r e s t s upon a normative premise, the more l i m i t e d o b j e c t i v e of i n c r e a s i n g understanding can be defended as an a n a l y t i c a l undertaking. The study w i l l go about i n v e s t i g a t i n g the p o l i c y / p i a n n i n g process i n the f o l l o w i n g manner. I t w i l l consider the nature of the p u b l i c p o l i c y process and s p e c i f i c a l l y focus on the r o l e of implementation. I t w i l l argue that implementation has been neglected as a f i e l d of i n q u i r y but that s u b s t a n t i a l i n s i g h t s i n t o improved management can be gained through understanding how the various elements in the implementation process i n t e r r e l a t e to produce a p o l i c y outcome. The s t u d y w i l l a d o p t a c a s e s t u d y a p p r o a c h t o a p p l y t h e g a i n s i n t h e o r e t i c a l k n o w l e d g e r e l a t i n g t o i m p l e m e n t a t i o n and t o d r a w o u t c o n c l u s i o n s w h i c h may i n c r e a s e t h e g e n e r a l u n d e r s t a n d i n g o f t h e r o l e o f i m p l e m e n t a t i o n and t h e f u n c t i o n i n g o f t h e p l a n n i n g and p o l i c y p r o c e s s e s . W h i l e t h e c a s e s t u d y w i l l i n v o l v e a n a l y s i s o f a p a r t i c u l a r e n v i r o n m e n t a l managemen t s i t u a t i o n , i t i s n o t i n t e n d e d a s an i n - d e p t h s t u d y o f t h e s u b s t a n t i v e i s s u e s o f t h a t s i t u a t i o n b u t u s e s i t o n l y a s a means o f i l l u s t r a t i n g s p e c i f i c p o i n t s r e l a t e d t o a g e n e r a l u n d e r s t a n d i n g o f p o l i c y i m p l e m e n t a t i o n . 1 . 2 B A C K G R O U N D I f t h e 1960s and e a r l y 1970s w e r e c h a r a c t e r i z e d a s a t i m e o f a w a k e n e d and h e i g h t e n e d a w a r e n e s s o f e n v i r o n m e n t a l c o n c e r n s , t h e mid-1970s t o t h e p r e s e n t , b a s e d upon t h e e x p e r i e n c e , m i g h t be s e e n a s a t i m e o f s u b s t a n t i a l and i n c r e a s i n g d i s i l l u s i o n m e n t a s t o t h e a b i l i t y o f g o v e r n m e n t t o d e a l e f f e c t i v e l y w i t h e n v i r o n m e n t a l p r o b l e m s . The r e a s o n s f o r t h e c o n f i d e n c e c r i s i s a r e o b v i o u s l y c o m p l e x , b u t o n e f a c t o r a p p e a r s p a r t i c u l a r l y r e l e v a n t t o p l a n n i n g c o n c e r n s , and t h i s i s t h e r a t e o f c h a n g e i n s o c i e t y . E . S . Quade (1976, p . 3) s u c c i n t l y makes t h e a r g u m e n t : " I n t h e p a s t , when e v e n t s moved more s l o w l y , t h e c o r r e c t i v e e f f e c t s o f e x p e r i e n c e p l a y e d a much l a r g e r r o l e t h a n t h e y do t o d a y . T h r o u g h t r i a l and e r r o r and p o l i t i c a l g i v e and t a k e , i t was p o s s i b l e f o r p u b l i c o f f i c i a l s t o d e v e l o p p o l i c i e s t h a t t o o k 6 into account the objectives, estimates, and values of everybody in society, or at least everybody who had influence. This i s no longer the case; technology and events move so rapidly that natural t r i a l and error - give and take processes can become too catastrophe-prone for comfort before the process approaches completion - not only war, but population pressure, resource shortages, and environmental deterioration are in t h i s category." Bertram Gross ( 1 9 7 1 ) in reference to th i s phenomena notes that in recent years there has been a marked acceleration in the rate of change. He points to acceleration in technological change, for instance, where not only are there more inventions and discoveries than ever before but the time lags between them and their p r a c t i c a l application and d i f f u s i o n have become much shorter. Many of the technologies and so c i a l i n s t i t u t i o n s George Orwell was saving for 1984 were already f l o u r i s h i n g in the 1 9 7 0 s , well ahead of the mark. Does t h i s acceleration in the rate of change mean that society must become a captive of i t s own processes and therefore simply move according to s h i f t s in uncontrolled forces of change or can change be managed? A number of writers have addressed th i s question in recent years arguing that society must gain control (cf. Ferkiss, 1 9 6 9 ; Galbraith, 1 9 7 3 ; Jantsch, 1 9 7 5 ; Michael, 1 9 7 3 ; Vickers, 1 9 7 0 ) . The most prevalent method suggested for gaining control i s to manage by planning. A basic premise of those advocating management by planning i s that a l a i s s e z - f a i r e approach to the future i s e s s e n t i a l l y impossible. There i s no longer a choice i n the matter ; the question i s not one of management versus no management, rather i t i s one of who w i l l manage and in whose i n t e r e s t . Only a few years ago, i t would have been incumbent upon the w r i t e r of a planning t h e s i s to present and defend the i d e o l o g i c a l arguments for p u b l i c planning versus the idea of s o c i a l change being achieved through an i n t e r p l a y of unfettered market-type f o r c e s . The major i d e o l o g i c a l arguments concerning planning took place i n the period surrounding World War I I , engaging such w r i t e r s as K a r l Mannheim (1951), Von Hayek (1967, r e - i s s u e d ) , Barbara Wooton (1945) and K a r l Popper (1945), i n what has been termed i n planning c i r c l e s as the Great Debate. While the debate may not have been so conclusive as to s i l e n c e one or the other s i d e , western democracies (among many others) have embraced a model of s u b s t a n t i a l p u b l i c planning to achieve o b j e c t i v e s defined as being i n the p u b l i c i n t e r e s t . Dahl and Lindblom (1953, p. 5) captured the essence of the argument which has seen planning e s t a b l i s h e d as a fundamental facet of modern s o c i e t y : "Plan or no plan? Everyone b e l i e v e s in planning in the l i t e r a l sense of the word; and, for that matter, everyone b e l i e v e s that n a t i o n a l governments should execute some plans for economic l i f e . No 8 one favours bad planning. Plan or no plan i s no choice at a l l ; the pertinent questions turn on particular techniques: Who s h a l l plan, for what purposes, in what conditions, and by what device?" 1.3 A STUDY OF IMPLEMENTATION Given the fundamental need for planning, i t i s tautological that improved planning w i l l result in improved management and therefore in improved soc i e t a l outcomes. How, then, i s a study directed to improved public planning and management to be approached; what facet of t h i s immensely complex subject should be considered? There are c l e a r l y many avenues of study which could generate f r u i t f u l r e s u l t s . Modern students v of public policy have attacked t h i s question in various ways using a variety of tools from every conceivable d i s c i p l i n e . But, by and large, the attack has centred on the process by which plans and p o l i c i e s * are formulated. Relatively l i t t l e attention has been focussed on the process whereby these p o l i c i e s are implemented. There appears to be a bias in policy studies toward the position that i t i s the process of deciding upon a policy which i s *For sake of brevity, the term policy w i l l be used to denote p o l i c i e s and plans as the products of authoritative public deliberat ion . c r i t i c a l . The i m p l i c i t argument i s that, i f a policy i s well defined through a v a l i d process, then the desired policy outcome w i l l surely follow. Centuries ago, Robbie Burns provided the c l a s s i c refutation of t h i s argument in his l i n e s r e f e r r i n g to the problems of the best l a i d plans of mice and men. Not only how a policy i s defined and decided upon i s important but also how i t i s implemented would appear to have a s i g n i f i c a n t bearing on the outcome. It follows that public management [the set of which environmental management i s a member] can probably be improved through improved policy implementation. A study of policy implementation ought to y i e l d s i g n i f i c a n t benefits in understanding the overal l policy/planning process and in establishing the role and importance of implementation in that process. Ideally, such a study would provide p r a c t i c a l guidance on the implications of modifying key elements of existing i n s t i t u t i o n a l arrangements to produce alternative outcomes. To achieve t h i s objective, the study must address s p e c i f i c questions: (a) i s implementation a separate and definable process? (b) i f so, how does i t relate to other parts of the public policy process? (c) what i s the d e f i n i t i o n and nature of t h i s process? (d) of what elements i s i t composed? and (e) how do these elements interact to produce a policy outcome? 10 As a means of setting and establishing the context for the study, the remainder of t h i s chapter w i l l be devoted to an , exploration of the f i r s t two questions: i s implementation a separate process, and i f so, how does i t relate to other parts of the policy process. To deal with the other key questions on a theore t i c a l basis, the next chapter of the study w i l l cover the implementation l i t e r a t u r e . This l i t e r a t u r e review w i l l be used in the t h i r d chapter as a basis for developing a d e f i n i t i o n of the implementation process and for hypothesizing the elements and interactions which are important in determining a policy outcome. The theory w i l l then be "tested" in a case study analysis. 1 . 4 THE PUBLIC POLICY PROCESS - THE CONTEXT FOR IMPLEMENTATION Where does implementation f i t in the larger policy process? In considering this question, the study w i l l present and discuss a simple conceptual model of the policy process which describes the major components and attempts to characterize the important questions regarding the linkages between these. Starting with basic concepts, i t i s assumed that the policy process i s part of the p o l i t i c a l system. Interactions within t h i s system are distinguished from a l l other kinds of s o c i a l interactions in that they are predominantly oriented toward the authoritative a l l o c a t i o n of values for a society (Easton, 1 9 7 9 , p. 2 1 ) . Because the p o l i t i c a l system is so 1 1 d e f i n e d , t h e r e a r e c o n c e p t u a l b o u n d a r i e s b e t w e e n what i s p o l i t i c a l and what i s n o t . That w h i c h i s n o t i s c a l l e d t h e ' e n v i r o n m e n t ' . But t h e s e b o u n d a r i e s a r e n o t c a s t i n s t o n e . As E a s t o n ( 1 9 7 9 , p. 6 7 ) a r g u e s : "We do n o t need t o c o n c l u d e t h a t ( b o u n d a r i e s ) , o n c e e s t a b l i s h e d , a r e e t e r n a l l y f i x e d . I f i t s h o u l d t u r n o u t t h a t o w i n g t o some m i s t a k e n i n t e r p r e t a t i o n o r l a c k o f i n s i g h t , i n o r d e r t o i m p r o v e o u r u n d e r s t a n d i n g o f t h e s y s t e m , we must i n c l u d e w i t h i n i t some e l e m e n t p r e v i o u s l y a s s i g n e d t o t h e e n v i r o n m e n t , we a r e f a c e d w i t h no c r i s i s . We s i m p l y r e d e f i n e t h e s y s t e m t o meet o u r a n a l y t i c a l n e e d s . Each t i m e t h a t we e n l a r g e o u r s y s t e m we  s i m u l t a n e o u s l y s h r i n k t h e e n v i r o n m e n t . " ( E m p h a s i s added .) F i g u r e 1 . 1 d e p i c t s E a s t o n ' s s i m p l i f i e d f l o w m o d e l o f a p o l i t i c a l s y s t e m s h o w i n g t h e e n v i r o n m e n t o f t h e s y s t e m and i t s i n t e r a c t i o n s w i t h t h e p o l i t i c a l s y s t e m . FIGURE 1 . 1 A S I M P L I F I E D MODEL OF A P O L I T I C A L SYSTEM Demands a. c The political system and actions Decisions S o u r c e : D. E a s t o n ( 1 9 6 5 ) p. 1 1 2 The environmental management p o l i c y system with which t h i s study i s concerned i s only a part or a sub-system of the p o l i t i c a l system, because obviously not everything included i n the p o l i t i c a l system has a d i r e c t bearing on environmental p o l i c y . Based upon the work of Easton and Ranney (1968), Figure 1.2 i s put forward as a model representing that part of the general p o l i c y process thought to be us e f u l i n understanding the environmental management p o l i c y process. Five major components are defined: (1) P o l i c y formation process; (2) Pol i c y output; ( 3 ) P o l i c y implementation'process ; (4) P o l i c y outcome; and (5) P o l i c y environment. FIGURE 1.2 MODEL OF POLICY PROCESS P O L I C Y E N V I R O N M E N T P O L I C Y J O U T C O M E The following discussion w i l l consider these fiv e components from the viewpoint of determining the relationship between each and the implementation of policy. 1.4.1 Policy Formation Process This process, which can be roughly equated with what i s often thought of as the decision-making process, can and usually does involve an extremely complex set of interactions to r e s u l t in the formation of a policy. Substantial scholarly e f f o r t has gone into describing policy formation processes ( c f . Bauer and Gergen, 1968; Simon, 1957; Hartle, 1979). These e f f o r t s have generally been concerned with questions of r a t i o n a l i t y and e f f i c i e n c y in decision-making with r e l a t i v e l y l i t t l e e f f o r t directed toward questions of ef f i c a c y . The decision-making l i t e r a t u r e amply demonstrates that the policy formation process involves many level s and much of what appears on the surface cannot be taken at face value. For example, i t i s generally not adequate to simply accept an o f f i c i a l statement of policy as the actual policy intention. Accepted theory states that a multifaceted decision process usually r e s u l t s in a decision taken for a variety of reasons directed to a variety of purposes ( c f . Lindblom, 1959). The research problem i s to determine who i s involved in making the policy (the values represented) and what the real i n t e n t i o n s are. This i s not to suggest a cl a n d e s t i n e p l o t e x i s t s i n every p o l i c y process but rather that very often decision-makers make d e c i s i o n s that may produce an array of consequences, many of which may be unintended or i n c i d e n t a l to the intended purposes. I t i s important in terms of improving p o l i c y performance to know what was and what was not intended. Of i n t e r e s t to the study of implementation i s the extent to which the decision-making process i n f l u e n c e s the method and process of implementation and v i c e versa, and the extent to which i m p l e m e n t a b i l i t y i s considered in determining the p o l i c y . 1.4.2 P o l i c y Output The p o l i c y output i s the product of a p o l i c y formation process, r e s u l t i n g in what would commonly be termed a p o l i c y . To understand f u l l y the content of a p o l i c y , i t must be considered in terms of the problem i t addresses and the method by which i t proposes to solve t h i s problem. The d i c t i o n a r y d e f i n i t i o n of a p o l i c y i s 'a d e f i n i t e course of act i o n adopted for a designated purpose'. On the b a s i s of t h i s d e f i n i t i o n , a p o l i c y embodies wi t h i n i t a stated or implied theory or hypothesis about a means-end r e l a t i o n s h i p . For research purposes, i t i s c r i t i c a l to be able to define the hypothesis that i s to be tested through the process of implementation. An example from water resources management w i l l serve to i l l u s t r a t e t h i s p o i n t . A p o l i c y might be adopted to attempt to reduce f l o o d damages on a r i v e r f l o o d p l a i n . The p o l i c y could be f u r t h e r s p e c i f i e d to include that i t w i l l be implemented by e s t a b l i s h i n g a system of dykes along the r i v e r . This p o l i c y output embodies the hypothesis t h a t , i f the dykes are constructed to p a r t i c u l a r s p e c i f i c a t i o n s , then a defined degree of f l o o d p r o t e c t i o n w i l l be afforded to the a d j o i n i n g lands. Consideration of the p o l i c y output i n t h i s manner f a c i l i t a t e s c l e a r ex post e v a l u a t i o n . I f , i n June, lands, that were thought to be protected, are flooded, research i n t o the s h o r t f a l l can proceed by d i s s e c t i n g the hypothesis. Were the dykes constructed to the standard implied in the p o l i c y ? Was some degree of p r o t e c t i o n provided, a l b e i t l e s s e r than a n t i c i p a t e d ? Is the hypothesized r e l a t i o n s h i p between dykes and p r o t e c t i o n v a l i d ? Did the p o l i c y i m p l i c i t l y assume s t r u c t u r a l methods of f l o o d c o n t r o l are the most e f f e c t i v e means of reducing flood damages? These and other r e l a t e d questions flow from the p o l i c y when i t i s seen i n the l i g h t of an " i f - t h e n " hypothesis. From a p r a c t i c a l viewpoint, however, i t must be remembered t h a t , while the p o l i c y output defines the wishes of the policy-makers, i t remains an a b s t r a c t i o n u n t i l a c t u a l l y implemented. Action i s required to b r i n g the p o l i c y into the mode where behavioural responses and effects can be observed. Since the effects of a policy are c e r t a i n l y as interesting and important as policy intentions, i t i s obviously important to understand policy as i t i s implemented as well as how i t was intended. 1.4.3 Policy Implementation Process This i s the process which turns a policy, an intended action, into concrete r e s u l t s . It can be thought of as a test of the hypothesis referred to in the previous section. Ideally, the policy statement which i s equated with the policy output f u l l y explains the intentions with respect to a particular problem. In such a case, implementors know what is to be implemented and are able to evaluate the extent to which success i s attained. R e a l i s t i c a l l y , t h i s i s rar e l y the case, and implementors may not be aware of the f u l l intentions of policy-makers and therefore might interpret a policy in terms of their own objectives or their perceptions of the policy-makers' objectives. It may well be that the policy implemented (or the hypothesis tested) i s not the one intended by the policy-makers. Even i f the implementors are aware of the policy-makers' intentions, they s t i l l may not implement the policy in accordance with the instructions i m p l i c i t in the policy statement. It i s conceivable that the implementation organization would pursue i t s own objectives which may c o n f l i c t with those of the policy-makers and thus subvert the intentions of the policy-makers and frustrate attainment of the real or ostensible objectives. Going back to the flood control example, the policy of constructing dykes i s obviously not self-implementing. Appropriate s i t e s must be designated, structures must be designed and actually b u i l t , and cost-sharing formulae generally must be negotiated. It i s conceivable that substantial changes over the o r i g i n a l policy intentions could r e s u l t because of implementation procedures. Physical l i m i t a t i o n s in s p e c i f i c s i t e s may rule out protection to the degree anticipated by policy-makers. Cost-sharing negotiations may modify the scale of the works projected and thus greatly reduce the overall effectiveness of the p o l i c y . It i s possible that inter-agency r i v a l r y may cause a particular aspect of the policy to receive r e l a t i v e l y more attention than others to the detriment of the t o t a l solution. In a society characterized by p l u r a l i s t decision-making, i t i s quite l i k e l y that there i s not a unique set of intentions respecting any policy. The values and objectives of the various participants in a policy formation process do not need to converge in terms of implementation expectations in order for them to arrive at an agreed-upon policy. This complicates the task of implementation and seems to precipitate a separation in kind between policy formation and policy implementation. In analyzing i n s t i t u t i o n a l arrangements, i t i s c r i t i c a l to define structural aspects of the arrangements which lead to s p e c i f i c conclusions. For example, does a p l u r a l i s t decision-making process require a p l u r a l i s t implementation process wherein the intentions behind the policy process need to be re-examined i t e r a t i v e l y by the implementation participants in order to produce f a i t h f u l implementation of the policy hypothesis? Or, a l t e r n a t i v e l y , does a p l u r a l i s t decision-making process purposely leave the implementation of decisions (however they are arrived at) to a separate technical or professional process as a kind of safety valve, providing an outlet for the resolution of uncertainties which w i l l be viewed by those impacted quite separately from the process by which decisions were o r i g i n a l l y taken? These kinds of questions point to a strong theoretical linkage between policy formation and policy implementation. This study w i l l need to be concerned with defining that linkage. In addition to the question of the linkage to policy formation, the i n t r i c a c i e s of the implementation process i t s e l f require an understanding of who i s involved with implementation and therefore the range of values represented, the procedures used to interpret policy (e.g., i t e r a t i v e with the policy-making participants, mechanistic, technical/ professional, e t c . ) , the process by which implementation action i s undertaken, and the evaluation procedures used to test the attainment of policy objectives. In a study of implementation, i t w i l l be important to determine the r e l a t i v e importance of these variables in order to appreciate the potential for their manipulation to produce alternate outcomes . 1.4.4 Policy Outcome The actions embodied within the implementation process would normally produce tangible results and effects called the policy outcome. As alluded to in the previous section, the actual outcome could d i f f e r from the intentions defined in the abstract policy output. The outcome provides the basis for an objective measure of the degree to which the policy, as defined in the output, has been implemented [assuming the policy i s not changed in the process of implementation]. It also provides the basis for a measure of a related aspect, the degree to which the policy impacts upon the problem to which i t has been applied. It i s quite conceivable that a policy could be flawlessly implemented but have r e l a t i v e l y l i t t l e impact upon the problem. While this i s not an implementation question per se, i t i s important to 20 keep in mind that e f f e c t i v e implementation of a policy does not necessarily r e s u l t in e f f e c t i v e action respecting the policy problem. I l l u s t r a t i n g the concept of a policy outcome using the previous example, the anticipated degree of flood control provided by the dyking program may not have materialized when tested under the conditions of a flood. Or perhaps the actual severity of the flood may have been greater than considered possible in the policy design. In such cases, the policy outcome d i f f e r s substantially from that which was anticipated by the policy output. What could cause this? Were there uncertainties which existed but were not accounted for in the formation or implementation processes; were the wrong variables in the hypothesis manipulated; was the hypothesis proved incorrect by the policy outcome; did the implementors choose not to f a i t h f u l l y implement the policy? Each of these questions i l l u s t r a t e s the importance of considering the substance of the policy outcome for comparison with the output and the problem d e f i n i t i o n . To guage the importance of implementation actions, an explanation of any variance between these i s in order. This explanation should involve analysis of the variables considered c r i t i c a l in policy implementation and, to some extent, the consideration given to implementation in problem d e f i n i t i o n and policy design within the policy formation process . 21 1.4.5 Policy Environment As noted e a r l i e r , i t i s a basic concept of systems analysis that a l l phenomena outside of the s p e c i f i c system under examination are considered to be the system's environment. This concept p a r t i a l l y explains the notion of a policy environment, although what i s intended i s somewhat more s p e c i f i c . Most public p o l i c i e s are directed toward particular segments of the population or target groups, even though some of these groups may be very large, such as the low-income, the eld e r l y , the wealthy, etc. The policy environment re f e r s , in part, to the target groups and their related a c t i v i t i e s . Those affected by a policy are invariably involved in shaping the outcome, even though perhaps very i n d i r e c t l y . The impactees manifest symptoms of the impact, but i t depends upon the process feedback loops as to whether these manifestations result in positive policy change or in f r u s t r a t i o n . It seems l i k e l y that, i f the impacts are s i g n i f i c a n t , either positive or negative, the environment w i l l impinge on the policy system to some extent. Clearly, the perceived strength of the impact would be a major determinant. In addition, i t could be expected that the "power" and resources of the impacted groups would be a factor in determining the amount of influence on the implementation of a polic y . In a d d i t i o n to the r o l e of the p o l i c y t a r g e t groups, the events surrounding any p a r t i c u l a r p o l i c y system would seem to exert an i n f l u e n c e on the p o l i c y process. I t seems reasonable that the behaviour of the actors i n p o l i c y formation or implementation would be influenced to some degree by the s e r i e s of events o c c u r r i n g in the wider s o c i e t y . This i s a very complex subject area as evidenced, for example, i n the observed tendency for s o c i a l movements to gain a c c e p t a b i l i t y i n a wide range of s o c i a l circumstances and c u l t u r e s . While the d e t a i l s of p o l i c y environment e f f e c t s may i n t o t a l be extremely complex, i t i s nonetheless important to recognize the existence of t h i s set of v a r i a b l e s and to be open to accepting t h i s concept as part of a p o t e n t i a l explanation i n a given p o l i c y process outcome. 1.4.6 Summary of P o l i c y Process The foregoing d i s c u s s i o n , based upon the model i l l u s t r a t e d in Figure 1.2 (p. 10), leads to the conclusion that p o l i c y implementation i s i d e n t i f i a b l e as a d i s t i n c t component of a l a r g e r p o l i c y process. The d i s c u s s i o n suggests that many of the v a r i a b l e s important i n formulating a p o l i c y are also key i n implementation, such as the values represented by the p a r t i c i p a n t s , the range of values represented, the information generation and evaluation procedures employed, and others. But there are aspects which c l e a r l y define two separate processes. Policy formulation i s the act of creating a policy, generally involving the interplay of competing values and objectives and resulting in a consensus decision on what to do, but not necessarily agreement on how or why i t i s to be done. Implementation involves acting on the po l i c y , and t h i s action manifests policy impacts. The decision on how to carry out a policy cannot be avoided, and as the impacts become evident, the various reasons for why the policy was formed may also become clear. The two evaluation touchstones in the process, policy output and policy outcome, help us to see the linkages between formulation and implementation. If the output c l e a r l y defines policy intentions and f o r c e f u l l y lays out implementation procedures, implementation can be straightforward [e.g., many t r a f f i c laws f a l l into t h i s category]. If, however, policy intentions and implementation guidance are minimal or even s l i g h t l y ambiguous, a myriad of i n s t i t u t i o n a l and behavioural variables can come into play and the outcome becomes much less determinate. If the outcome does not match the intentions of the policy, however defined, through a comparison of output and outcome, then a n a l y t i c a l procedures can be undertaken to dissect the problem. This can concentrate on implementation decisions and procedures on the one hand, and policy formation on the 24 other, and the i n t e r p l a y of these through feedback channels. The p o l i c y environment may impinge on both the formation and implementation processes. 1.5 PERVASIVE THEMES - VALUES AND UNCERTAINTY The above d i s c u s s i o n on the p o l i c y process i s , of course, only i n t r o d u c t o r y and serves but to whet the appet i t e for an in-depth look at the v a r i a b l e s at play. I t merely demonstrates the u t i l i t y of studying implementation and serves as a r a t i o n a l e for l i m i t i n g the scope of the a n a l y s i s . It sets the stage for fu r t h e r a n a l y s i s by suggesting important r e l a t i o n s h i p s which can be subjected to research. In p a r t i c u l a r , the d i s c u s s i o n points to what appears to be two pervasive themes or dimensions in understanding implementation and i t s r o l e i n the p o l i c y process; these are: (a) the a p p l i c a t i o n of values, and (b) d e a l i n g with u n c e r t a i n t i e s . These w i l l be discussed in a p r e l i m i n a r y manner at t h i s point to help guide a review of the l i t e r a t u r e and the subsequent development of a theory of implementation. 1.5.1 A p p l i c a t i o n of Values The p u b l i c p o l i c y process i n v o l v e s the a p p l i c a t i o n of values (among other things) to questions of p u b l i c i n t e r e s t and concern. A major question i n p o l i c y l i t e r a t u r e has centred on whose values ought to determine the p o l i c y output. Policy-making could be viewed as a mechanistic exercise i f the objectives were simple and straightforward (ignoring, for the moment, major uncertainties). The thing that makes public policy-making so d i f f i c u l t i s not only the fact that outcomes are d i f f i c u l t to predict but also the fact that there i s frequently only vague agreement (or no agreement) on what the outcome should be. It was suggested in the previous discussion that the policy formation stage does not necessarily d e f i n i t i v e l y guide the implementation of po l i c y . Frequently, decisions must be made during implementation which have the substance and force of policy choices. Such choices are not often purely technical [value-free] in nature and therefore involve the application of values to the alternatives open to those making the decisions. It i s , therefore, c r i t i c a l to consider how values are or can be brought to bear at the implementation stage. This l i n e of reasoning leads to the proposition that a comprehensive study of implementation must consider two kinds of questions related to values. F i r s t , are implementation procedures and strategies designed to optimize [that i s , minimize the s h o r t f a l l between output and outcome] in l i g h t of the presumed values/objectives of the implementors? Or, second, are the processes of implementation organized so as to r e f l e c t the range of values of the legitimate participants; i . e . , the public which i s impacted by the policy and therefore has a legitimate interest in the outcome? In terms of the l i t e r a t u r e and theory, e x p l i c i t consideration must be given to behavioural factors that determine who i s involved in the implementation process and how these actors can be expected to perform. It can be expected that the particular behaviour of those involved w i l l influence or determine the policy outcome. Equally important, the neglect or non-involvement of major value stances in the implementation process w i l l be a determinant in the outcome. In terms of a positive analysis, i t i s s u f f i c i e n t to determine whose values govern the outcome. From a normative viewpoint, i t i s necessary to establish whether the values pursued are appropriate. As noted at the outset, by and large t h i s study w i l l be r e s t r i c t e d to a positive approach. However, some concluding statements at the completion of the study w i l l be made regarding some of the options available should alternative arrangements be considered desirable. 1.5.2 Uncer tainty Environmental p o l i c i e s invariably involve substantial uncertainties. The discussion of the policy process suggests that, i f uncertainties exist in the policy output, i t w i l l be in the implementation stage where these uncertainties must be resolved or at the very least accounted for in concrete ways in terms of their impact upon the policy outcome. Understanding how uncertainty i s dealt with in the implementation process i s c r i t i c a l to understanding the functioning of the process in terms of feedback as uncertainties are resolved and how t h i s resolution in turn leads to new action. The discussion above concerning values can be p a r t i a l l y conceptualized in terms of uncertainty. One of the major uncertainties a f f e c t i n g any public implementation process i s how values w i l l have changed over time and thus perhaps s h i f t the d i r e c t i o n of the policy outcome from that which might have occurred in the absence of a value s h i f t . The point w i l l be further elaborated in the following discussion. Uncertainties are defined as the u n p r e d i c t a b i l i t i e s in factors which aff e c t the success or di r e c t i o n of a course of action. There are d i f f e r e n t kinds of uncertainties with variances in both nature and degree. A clear explanation of these w i l l be useful for further analysis related to policy implementation . 1.5.2.1 Kinds of Uncertainty The most common type of uncertainty i s lack of  information or knowledge. It i s also the easiest to remedy, and some might argue that t h i s i s not uncertainty at a l l . Lack of information simply means that s u f f i c i e n t e f f o r t has not been expended to acquire the information, not that i t i s unknowable. For purposes here, however, this w i l l be considered uncertainty because in many instances, i f not most, policy i s formulated under conditions that force a decision before complete information can be secured. Additionally, i t must be remembered that information acquisition has a real cost which must be accounted for in the decision calculus. It i s conceivable that policy-makers would develop a policy under less than f u l l information on the assumption that the marginal cost of acquiring the information was higher than the marginal return to the policy process. This sort of decision i s usually based upon the perception of an outcome probability derived from the current stock of information. Lack of information type of uncertainty can be erased by the expenditure of resources to acquire the necessary information. In many cases, however, substantial time lags exist between the time of deciding to obtain the information and the actual acquisition of the data in a useable form. For example, basic research may have to be undertaken to f i l l some gaps in knowledge. Therefore, while t h e o r e t i c a l l y simple, t h i s kind of uncertainty can cause considerable p r a c t i c a l d i f f i c u l t y . The policy process response in such situations, as suggested above, i s to view the future in 29 probablistic terms, making a decision based on the probable outcomes given the information currently a v a i l a b l e . In theory, i f the research i s undertaken, the information flowing from i t can be fed into the policy process, probably during the implementation stage. The information i s compared with anticipated/projected information and adjustments are made accordingly. Posing substantially more d i f f i c u l t y for policy-makers are the more genuine uncertainties that cannot be eliminated except through the passage of time. Quade ( 1 9 7 6 , p. 2) c i t e s an example which admirably demonstrates the uncertainties associated with environmental policy in what appeared to be a rather straightforward problem and solution: "... Consider the problem of c o n t r o l l i n g southern C a l i f o r n i a ' s photochemical smog. The contribution of automobiles to th i s problem was recognized more than twenty years ago, when Haagen-Smith showed how unburned hydrocarbons and oxides of nitrogen were both required for the photochemical reactions which produce smog. It was decided very early to try and control hydrocarbons as being easier. It was also decided at the same time by the other authorities that health problems might be associated with the existing emission l e v e l s of carbon monoxide, which has no known connection with smog. Regulations resulted curbing both carbon monoxide and unburned hydrocarbons. The natural response of the automobile industry was to raise the flame temperatures in engines to maintain the so-called high performance of cars, thereby increasing the emission of the oxides of nitrogen and largely cancelling the benefit of the regulation of hydrocarbons. If we include the increase in car population, we find that smog has not been reduced at a l l . " This example i l l u s t r a t e s the point that u n c e r t a i n t i e s e x i s t r e s p e c t i n g the i n t e r a c t i o n of v a r i a b l e s which cannot be predicted i n advance. One could have hypothesized the response of the automobile i n d u s t r y and made p o l i c y ' a c c o r d i n g l y , but the passage of time would be required to t e s t the a c t u a l response of the system to the p o l i c y . Quade (1976, p. 214) d i v i d e s passage of time u n c e r t a i n t i e s i n t o two types. The f i r s t , s t o c h a s t i c  u n c e r t a i n t i e s , i n v o l v e s random events, many of which can be reduced to a r i s k s i t u a t i o n by computing a p r o b a b i l i t y d i s t r i b u t i o n of the p o t e n t i a l outcomes. Flood c o n t r o l i s the c l a s s i c case of u n c e r t a i n t y t r e a t e d as r i s k . Records over long periods of time are used to determine the p r o b a b i l i t y of p a r t i c u l a r kinds of n a t u r a l occurrences happening. For example, stream flow records over time are used to p r e d i c t the r e t u r n i n t e r v a l of a given amount of water, f o r example, once i n 100 years. Whether t h i s s o rt of r e - d e f i n i t i o n of un c e r t a i n t y to r i s k i s u s e f u l or even e f f e c t i v e i n the long run i s another question. The second type, for which p r o b a b i l i t i e s cannot be c a l c u l a t e d , are c a l l e d r e a l u n c e r t a i n t i e s . These can be fur t h e r s u b - c l a s s i f i e d i n t o s t r a t e g i c u n c e r t a i n t i e s that are 31 due to ignorance about factors under the control of another decision-making unit (the smog example above), and environmental uncertainties involving factors under natural control. An example of strategic uncertainty might be how the fi s h i n g industry might react to the imposition of new equipment regulations cannot be determined in advance because those imposing the regulations have no real knowledge as to how important fi s h i n g industry decision-makers, e.g., individual fishermen, w i l l behave in response. They may ignore the regulations, they may appeal for changes, they may change their behavior in seemingly unrelated areas and so on. In noting the response to treating flood situations, i t was questioned how useful i t i s to consider the problem in terms of p r o b a b i l i t i e s . It may be more appropriate to view the matter as one of environmental uncertainty. It cannot be known in advance, or at least not very far in advance, what the weather pattern w i l l produce in terms of flood waters, and consequently, only after the fact i s the uncertainty l i f t e d . But the event does not a l t e r , in any way, the environmental uncertainty for the future. This being the case, much d i f f e r e n t policy responses than those commonly applied would probably be forthcoming, but that's a topic for another and quite d i f f e r e n t study. 32 1.5.2.2 Response to Uncertainty The example on flood c o n t r o l r a i s e s a d e f i n i t i o n a l problem i n environmental p o l i c y a n a l y s i s concerning u n c e r t a i n t i e s . Because there i s a strong d e s i r e to " s o l v e " the problem at hand, the way a problem s i t u a t i o n i s defined i s important i n d i r e c t i n g i t s r e s o l u t i o n . Two things can happen. The f i r s t r e s u l t s i n devoting most of the a n a l y t i c a l e f f o r t toward q u a n t i t a t i v e c a l c u l a t i o n to the neglect of l e s s q u a n t i f i a b l e or q u a l i t a t i v e aspects of the i s s u e . As Quade (1976, p. 216) points out: " U n c e r t a i n t i e s that can be c a l c u l a t e d i n one way or another tend to absorb the a t t e n t i o n of an analyst a l l out of proportion to t h e i r importance. One reason i s that to take them i n t o account properly can be such a challenge to h i s ingenuity. This sometimes leads to the neglect of the more serious u n c e r t a i n t i e s that are not s t o c h a s t i c i n nature, the r e a l u n c e r t a i n t i e s . " The second r e l a t e d point i s that a n a l y s t s tend to view the problem from the perspective of q u a n t i f i c a t i o n and often apply, for example, p r o b a b i l i t i e s to phenomena that are not a c t u a l l y amenable to such a for m u l a t i o n . Defining a s i t u a t i o n i n v o l v i n g u n c e r t a i n t y as s t o c h a s t i c when i t i n f a c t i s more r e a l i s t i c a l l y a problem of environmental u n c e r t a i n t y can lead to serious e r r o r s and questionable or misleading p o l i c y c o n c l u s i o n s . I t should be recognized, however, that s t a t i s t i c a l a n a l y s i s does provide a means of rec o g n i z i n g environmental u n c e r t a i n t y which can be a p p l i e d . It was suggested in the f i r s t section of t h i s chapter that public policy processes have not been very successful in anticipating and responding to change in a manner which has created a desirable future. This amounts to being i n e f f e c t i v e in dealing with uncertainty. Why does t h i s appear to be the case? I n i t i a l indications suggest that the policy process i s more or less i n e f f e c t i v e because i t does not s o l i c i t / r e c e i v e and/or use adequate information on changes in the policy environment (that portion of the world impacted by the policy) which occur as uncertainties are resolved over time. Stated another way, i n s t i t u t i o n s tend not to take account of deviations from the path charted in the policy formulation process (at least not in the short run), even though t h i s path i s based upon uncertainties. Such deviations are termed policy ' f a i l u r e s ' and the process i s geared to succeed, not to f a i l . This suggests a b u i l t - i n bias against correcting for the resolution of uncertainties. Given the prominence in environmental policy situations, c r i t i c a l questions involve consideration of how policy processes respond to uncertainty and how t h i s response might be improved. The answers l i e at the very heart of policy analysis for much of the relevance of the policy process depends upon them. 34 1.6 SUMMARY This chapter provides the basis for a study of policy implementation as part of a concern for understanding the environmental management policy process. It argues that r e l a t i v e l y l i t t l e attention has been paid to implementation and that a study of t h i s ought to yield s i g n i f i c a n t benefits in a better general understanding of public policy processes. The arguments in t h i s chapter lead to the proposition that a d i s t i n c t implementation process can be defined within a larger policy process. Two pervasive themes, the application of values and the presence of uncertainties, were defined as major organizing variables for understanding implementation . The next stage of the analysis i s to develop further the concept of an implementation process. What variables or factors are important in determining the process, and how does i t s o l i c i t and process information on policy performance? As a step toward structuring research to consider these questions, a comprehensive review of the l i t e r a t u r e concerned with policy implementation follows. This l i t e r a t u r e assessment w i l l be used to define s p e c i f i c models of the implementation process which w i l l be "tested" in an empirical case study. 35 CHAPTER 2 REVIEW OF IMPLEMENTATION AND RELATED LITERATURE 2.1 INTRODUCTION In 1973, Pressman and Wildavsky wrote: "There i s (or there must be) a large l i t e r a t u r e about implementation in the s o c i a l sciences - or so we have been told by numerous people Nevertheless, except for the few pieces mentioned in the body of t h i s book, we have been unable to find any s i g n i f i c a n t analytic work dealing with implementation. How s h a l l we persuade others that i t i s f r u i t l e s s to look for a l i t e r a t u r e that does not ex i s t , or that we cannot connect our work with nonexistent analyses by others: i t i s a l i t t l e l i k e searching for the l i t t l e man who isn't there. While we cannot hope to provide conclusive evidence we do hope to be persuasive beyond the mere assertion that there i s no analytic l i t e r a t u r e on  implementation." (Emphasis added.) In the years since t h i s pronouncement, a few studies s p e c i f i c a l l y concerned with policy implementation have been published so that a body of l i t e r a t u r e on the subject i s beginning to emerge. Even so, i t must be recognized that, although the number of published studies i s growing, the present l i t e r a t u r e i s s t i l l of a modest siz e . The l i t e r a t u r e review for t h i s study i s considered to be comprehensive with respect to the subject of policy implementation in the s o c i a l sciences. It i s recognized that questions of policy implementation are of d i r e c t concern to legal scholars and there exists a substantial legal 36 l i t e r a t u r e on t h i s subject. This has not been reviewed here because i t i s concerned largely with s p e c i f i c legal questions for which the writer does not have the background to judge competently the substance and c a l i b r e of the arguments. From discussions with legal experts, i t would appear that the thrust of t h i s study does not c o n f l i c t with the legal l i t e r a t u r e on points respecting policy implementation. In the past f i v e or so years, a great deal has been written about regulation reform in Canada. This l i t e r a t u r e w i l l not be reviewed in the study even though regulation i s a widely used mechanism for implementing public policy. There are two main reasons for t h i s exclusion. On the one hand, regulation studies are to a very large degree concerned with the substantive issues of particular regulations, for example, the impacts of egg marketing regulations on economic e f f i c i e n c y or the price impacts of air c a r r i e r regulations. These studies are not concerned with the factors that shape implementation decisions. On the other hand, the regulation studies which do address decision-making questions are invariably concerned with the process of developing regulations. There i s scant attention paid to what happens after the regulation i s adopted. It would appear that these studies follow the t r a d i t i o n of assuming that a policy/regulation well-constructed w i l l be f a i t h f u l l y implemented. This i s in no way intended as a c r i t i c i s m of the regulation studies. They provide excellent analysis of the important questions centred on developing new or revised regulations. This study should be viewed as a complementary work. It i s being undertaken precisely because most studies of implementation mechanisms do not consider the factors which influence how p o l i c i e s are actually implemented.* *The reader i s referred to the following studies for an overview of recent regulation l i t e r a t u r e in Canada: G. Bruce Doern, "Rationalizing the Regulation Decision-Making Process: The Prospects for Reform", Working Paper No. 2 , Economic Council of Canada, Ottawa, 1979; Robert D. Cairns, "Rationales for Regulation", Technical Report No. 2 , Economic Council of Canada, Ottawa, 1980; Michael J. Trebilock, et a l . , "The Choice of Governing Instruments: Some Applications", Technical Report No. 12, Economic Council of Canada, Ottawa, 1981 ; Hushron, Ogilvie Assoc. Ltd., "An Assessment of the Effectiveness of Government Decision-Making Processes in the F i e l d of Occupational Health and Safety", Technical Report No. 5 , Economic Council of Canada, Ottawa, 1981 ; Science Council of Canada, Regulating the Regulators,  Science Values and Decisions, Minister of Supply and Services, Ottawa, 1982; Economic Council of Canada, Reforming Regulation, Minister of Supply and Services, Ottawa, 1981; The reader i s also referred to Fred Thompson and L. Jones, Regulatory Policy and Practices, Praeger, New York, 1982. This work i s concerned with issues in the United States, but i t provides numerous th e o r e t i c a l insights applicable to Canadian conditions. With the p r e v i o u s l y stated caveats, as of mid-1982, a l l m a t e r i a l s d i r e c t l y r e l a t i n g to implementation published i n book form and i n a v a i l a b l e academic j o u r n a l s were i n c l u d e d ; and as w e l l , e f f o r t s were made to obtain r e l e v a n t unpublished m a t e r i a l referenced in published papers and monographs. The o v e r a l l impression i s that the l i t e r a t u r e i s very uneven and poorly s t r u c t u r e d i n t h e o r e t i c a l and conceptual terms. I t i s simply not p o s s i b l e to produce a s i n g l e accepted v e r s i o n of implementation r e a l i t y from the l i t e r a t u r e . The few w r i t e r s who have addressed implementation questions have been very s e l e c t i v e i n t h e i r arguments, and none can be said to be comprehensive. Even now, one cannot b r i n g together the diverse points of view and present a status quo opinion or even a s t a t e - o f - t h e - a r t . Enough work has not yet been published to provide a r e a l i s t i c b a s i s for doing t h i s . Alexander (1982, p. 134), a f t e r reviewing f i v e of the most recent renderings on implementation, asks the question: "... does t h i s l i t e r a t u r e , i n c l u d i n g i t s l a t e s t increment reviewed here, add up to a body of theory which can e x p l a i n why some a c t i o n s i n a p a r t i c u l a r set of circumstances produce c e r t a i n outcomes?" And h i s answer: " I suspect - a s u s p i c i o n which our authors seem to share - that we are s t i l l far from such a theory." 39 What then can be expected? The l i t e r a t u r e w i l l be used to raise what are considered to be the central issues of policy implementation research and w i l l be discussed with a view to ide n t i f y i n g p r a c t i c a l research questions and dire c t i o n s . The presentation w i l l be comprehensive in that a l l of the central points raised in the l i t e r a t u r e w i l l be considered and structured into s p e c i f i c arguments concerning various aspects of implementation. The arguments w i l l be summarized in the chapter following the review and used to develop a model of the implementation process. Nakamura, et a l . (1980, p. 1,090) summarize the context: "The l i t e r a t u r e on policy implementation i s a new and growing one. While particular case studies of governmental programs have been with us for some time, the e x p l i c i t focus on 'implementation' as a research perspective has not. This l i t e r a t u r e i s new because i t addresses a common core of policy questions through the adoption of a common perspective. The major and d i s t i n c t i v e concern of implementation research i s to produce pr e s c r i p t i v e , or policy-relevant, studies." It should be noted that the l i t e r a t u r e on implementation per se does not cover a l l of the aspects which seem important in advancing our understanding in t h i s area. Relevant questions respecting individual and organizational behaviour, including s e l f - i n t e r e s t , perceptions, role expectations and r a t i o n a l i t y , w i l l be covered through a review of some public choice theory and organizational l i t e r a t u r e . Three general sections w i l l be presented i n c l u d i n g the i n t r o d u c t i o n of implementation concerns i n t o the p o l i c y a n a l y s i s l i t e r a t u r e , important elements of the implementation process, and approaches for improving upon current p r a c t i c e s . 2.2 IMPLEMENTATION AS A TOPIC OF INQUIRY While not a b s o l u t e l y c e n t r a l to the a n a l y s i s , i t i s i n t e r e s t i n g to note that only very r e c e n t l y has implementation been recognized as a bona f i d e process worthy of s c h o l a r l y concern. This r e c o g n i t i o n seems to be based on a n a l y s i s of what appear to be i n c r e a s i n g l y i n t r a c t a b l e s o c i e t a l problems. A p o l i c y a n a l y s i s framework which excludes or does not c o n s c i o u s l y i n c l u d e implementation i s incomplete, and as Hargrove (1975) argues, serious c o n s i d e r a t i o n of the r o l e of implementation may provide the "missing l i n k " . Concern for the question of implementation has appeared in the l i t e r a t u r e covering a range of substantive p u b l i c p o l i c y i n t e r e s t s . For example, Fox (1976, p. 756), i n an overview a n a l y s i s of water management i n s t i t u t i o n s , s t a t e s : "one of the major problems evident i n the United States and Canada i s the d i f f i c u l t y of designing implementation arrangements which achieve p o l i c y o b j e c t i v e s " . In the s o c i a l p o l i c y area, Williams (1976) s t r e s s e s that "the l a c k of concern for implementation i s c u r r e n t l y the c r u c i a l impediment to improving complex operating programs, p o l i c y a n a l y s i s and experimentation i n s o c i a l p o l i c y areas". Some general reasons why implementation has not been adequately researched and considered are put forward i n the l i t e r a t u r e . Berman (1978) argues that s i g n i f i c a n t s h o r t f a l l s from the expectations of many for the environmental p o l i c i e s of the 1960s r e s u l t e d because planners focused on t r a n s l a t i n g the best and b r i g h t e s t ideas i n t o p u b l i c p o l i c i e s but not on implementing these p o l i c i e s . Why not? Van Meter and Van Horn (1975, p. 450) suggest that t h i s neglect may r e s u l t from a deep-seated b i a s . They argue t h a t : "The implementation process i s assumed to be a s e r i e s of mundane d e c i s i o n s and i n t e r a c t i o n s unworthy of the a t t e n t i o n of scholars seeking the heady s t u f f of p o l i t i c s . Implementation i s d e c e p t i v e l y simple; i t does not appear to involve any great i s s u e s . Most of the c r u c i a l p o l i c y issues are often seen to have been resolved i n p r i o r d e c i s i o n s . " Pressman and Wildavsky (1974) demonstrate the f o l l y of accepting such assumptions: "we are s u r p r i s e d about (implementation) f a i l u r e s because we do not begin to appreciate the number of steps i n v o l v e d , the number of p a r t i c i p a n t s whose preferences have to be taken i n t o account, the number of separate d e c i s i o n s that are part of what we 42 t h i n k of as a s i n g l e one".* Alexander ( 1 9 8 2 , p. 1 3 5 ) argues that "complexity ... i n h i b i t s smooth implementation of p o l i c i e s , however c l e a r l y s t a t e d , and l i m i t s our understanding of what went wrong". In a d d i t i o n , and perhaps more important, p o l i c y implementation has been avoided by schol a r s because of the methodological d i f f i c u l t i e s posed. Van Meter and Van Horn (1975, p. 451) point out t h a t : " R e l a t i v e to the study of p o l i c y formation, the an a l y s i s of the implementation process r a i s e s serious boundary problems. I t i s o f t e n d i f f i c u l t to define the r e l e v a n t a c t o r s . Furthermore, many of the v a r i a b l e s needed to complete an implementation study are d i f f i c u l t - i f not impossible - to measure. Unlike l e g i s l a t i v e and j u d i c i a l arenas where votes are often recorded, d e c i s i o n s i n an a d m i n i s t r a t i v e s e t t i n g are fre q u e n t l y d i f f i c u l t to i s o l a t e . " The consensus i s c l e a r ; implementation has been neglected but i s an important t o p i c and worthy of study. It i s , however, complex and d i f f i c u l t to analyse. Undaunted by these warnings, some w r i t e r s have attempted to understand the process. The next s e c t i o n w i l l consider these w r i t i n g s . *The a r i t h m e t i c of complexity i s impressive. As Behn ( 1 9 8 0 ) points out, i f there are only ten points i n an implementation process where something could go awry, then even with only a 10 percent chance of error or f a i l u r e at each of these, the cumulative odds that the implementation process w i l l succeed are only 35 percent. 43 2.3 UNDERSTANDING IMPLEMENTATION The general purpose of the implementation process i s obvious; i t i s to implement p o l i c i e s . As noted e a r l i e r , a policy (defined in the output) i s an abstraction u n t i l i t i s actually implemented. Assuming that the purpose of a policy i s generally to bring about certain effects or outcomes, i t i s reasonable to analyse a policy, at least i n i t i a l l y , in terms of i t s success in bringing about anticipated outcomes. Any s h o r t f a l l between anticipated and actual outcomes i s usually termed 'policy f a i l u r e ' , and c l e a r l y there can be degrees of policy f a i l u r e . The dominant question to be asked after a case of policy f a i l u r e has been diagnosed i s why did the policy f a i l ? Williams (1976) derives three related categories of policy f a i l u r e , as follows: (1) Failure of Theory - A s p e c i f i c program i s carried out, but t h i s program does not activate the causal process that i t was hypothesized would have culminated in the intended goals. (2) Failure of Program - A program i s undertaken, and i t sets the presumed causal process into motion, but the process does not cause the desired e f f e c t s . (3) Failure of Specification - Related to number one, t h i s refers to the case when a policy may be accurately defined in program terms, but i t s implementation i s not sp e c i f i e d . Specification could include what i s to be done, how i t i s to be done, what organiza-t i o n a l changes are possible or expected, what s p e c i f i c expectations exist, and so on. 4 4 Of these three, only f a i l u r e of s p e c i f i c a t i o n i s related to the implementation process. Even so, i t would seem that f a i l i n g to specify the implementation of a policy does not necessarily lead to policy f a i l u r e . More accurately, assuming neither of the other two conditions ex i s t , what might lead to f a i l u r e would be carrying out a program in a manner contrary to the objectives of the policy. This typology of policy f a i l u r e i s useful, however, because i t d i r e c t s analysis to questions of policy substance within the context of action. In order to conclude either a f a i l u r e of theory or program, the analysis considers the policy [transformed into program] as carried out. It i s not possible to argue that a program did not activate a hypothesized causal process unless there i s data on how the program was implemented. One must be sure that the program was actually implemented in accordance with the expectations of those hypothesizing the particular causal process. The category ' f a i l u r e of s p e c i f i c a t i o n ' might usefully be renamed and redefined as f a i l u r e of implementation. This would refer not to nonspecification of what i s to be done, how i s i t to be done, etc., but rather what was done and how did t h i s relate to the expectations of the policy output. Such a r e d e f i n i t i o n moves the a n a l y t i c a l d i r e c t i o n from a preoccupation with decisions taken in the policy formation stage to a view that decisions taken during actual implementation of a policy can play a dominant role in i t s success or f a i l u r e and b a s i c a l l y d i r e c t events to an outcome. This i s not to say that the policy formation stage is not important. Clear s p e c i f i c a t i o n of implementation in the policy output would usually ease the process of acting on the policy (but not nec e s s a r i l y ) . Overt f a i l u r e of s p e c i f i c a t i o n leaves open the important questions and the variables of the implementation process are forced into play. Irrespective of the l e v e l of s p e c i f i c a t i o n , however, in any implementation involving even a very few actors and decision points, a process involving human beings representing value positions must be entered into, and thi s being the case, an e s s e n t i a l l y p o l i t i c a l process i s involved. Eugene Bardach ( 1 9 7 7 ) reviews the l i t e r a t u r e with respect to the concept of implementation as p o l i t i c s . He argues: "Implementation p o l i t i c s i s , I believe, a special kind of p o l i t i c s . It i s a form of p o l i t i c s in which the very existence of an already defined policy mandate, l e g a l l y and legitimately authorized in some prior p o l i t i c a l process, affects the strategy and t a c t i c s of the struggle. The dominant effect i s to make the p o l i t i c s of the implementation process highly defensive. A great deal of energy goes into maneuvering to avoid r e s p o n s i b i l i t y , scrutiny, and blame." (p. 37 ) 4 6 Bardach (1977, p. 38) argues that what goes on in the policy formation stage i n i t i a l l y a f fects the implementation stage. He points out that: "Die hard opponents of the policy who lost out in the adoption' stage seek, and fi n d , means to continue their opposition when, say, administrative regulations and guidelines are being written. Many who supported the o r i g i n a l policy proposal did so only because they expected to be able to twist i t in the implementation phase to suit purposes never contemplated or desired by others who formed part of the o r i g i n a l c o a l i t i o n . " * This characterization Bardach c a l l s "implementation as pressure p o l i t i c s " . It i s clear from the empirical evidence that pressure p o l i t i c s does describe some of the dynamics of the implementation process, but he points out the danger of making i t the central organizing concept because i t does not account for the d i f f i c u l t i e s encountered when there i s agreement on objectives. Lindblom's (1959) d e f i n i t i o n of a good decision i s one that can be agreed upon. This notion of policy-making has held a great deal of sway in recent thinking and, in terms of effectiveness, i s c l e a r l y at odds with Bardach's description of implementation. There are obvious problems with t h i s decision r u l e ; for instance, the decision may not include or *This i s a resu l t of what Fox (1982b, p. 1) c a l l s cognitive c o n f l i c t defined as deriving from a difference in judgement or understanding of what the consequences of a policy or program w i l l be. take account of important int e r e s t s . More importantly, however, with respect to implementation, i s the fact that i f individual actors or groups reached a consensus based upon divergent objectives, that i s , the same decision but with d i f f e r e n t intended r e s u l t s , then the consensus would tend to f a l l apart as the actual policy outcome i s r e a l i z e d . It i s not necessarily a good decision at a l l i f the agreements are based upon divergent objectives. Recognition of thi s problem was f i r s t discussed in the l i t e r a t u r e by Bunker ( 1 9 7 0 ) . Bunker, in fact, suggests that a simple massing of assent i s a l l that i s required for successful implementation. He proposes to do thi s by locating a l l actors p o t e n t i a l l y involved in the implementation task in a three-dimensional space defined by the variables: issue salience, power resources, and agreement. These, when i d e n t i f i e d , are combined and added to get some estimate of the required values for a minimum ef f e c t i v e c o a l i t i o n to achieve implementation. Bardach takes great issue with t h i s approach arguing f i r s t l y the actual d i f f i c u l t y of the method; for example, ident i f y i n g those groups p o t e n t i a l l y involved with the implementation task. There may be some p r a c t i c a l l i m i t a t i o n s , but generally, the problem would not appear to be insurmountable. But more importantly, he rejects the notion that c o a l i t i o n s are important in implementation. As stated before, Bardach argues that implementation does not resemble the p o l i c y adoption process c h a r a c t e r i z e d by c o a l i t i o n s but r e s u l t s i n "defensive p o l i t i c s " , wherein actors are more concerned with what they might lose rather than what might be gained. It would seem, however, that t h i s p o i n t , while important, should not be overstated. There are many instances where there i s agreement on the p o l i c y and the o b j e c t i v e s , but implementation problems s t i l l e x i s t . Bardach (1977, p. 42) argues that "implementation p o l i t i c s i s d i s t i n g u i s h e d from po l i c y - a d o p t i o n p o l i t i c s by the c h a r a c t e r i s t i c absence of c o a l i t i o n s and the c h a r a c t e r i s t i c presence of fragmented and i s o l a t e d maneuvers and countermaneuvers". But t h i s need not be g e n e r a l l y s u b s t a n t i a b l e . I t does not f o l l o w that because the c o n f l i c t over the terms of a p o l i c y on which agreement i s made or withheld i s c r i t i c a l to implementation processes, that c o a l i t i o n s cannot e x i s t or be forged. In f a c t , the opposite would seem more l i k e l y . . As i t becomes more obvious that a p o l i c y outcome i s moving in a p a r t i c u l a r d i r e c t i o n , c o a l i t i o n s i n support of or against that d i r e c t i o n could more ably be formed because much of the u n c e r t a i n t y i s removed. I t has long been observed that i n d i v i d u a l s (or groups) r a r e l y perceive t h e i r s e l f - i n t e r e s t i n the a b s t r a c t and, consequently, are driven to a c t i o n only upon the r e a l i z a t i o n of r e a l or consequential impacts. I t i s often p o i n t l e s s to ask someone to p r i o r i z e h i s values, but i t i s u s u a l l y quite obvious to both the observer and the value holder when some ac t i o n n e g a t i v e l y impacts a h i g h l y regarded value. David Lowenthal (197?, p. 1 2 9 ) makes t h i s p o i n t : "... you cannot express l u c i d opinions about t h i n g s u n t i l you have experienced them. Many personal preferences are inchoate, d i f f u s e , i r r a t i o n a l , and can hardly be formulated c o n c r e t e l y even to our s e l v e s . Views about the environment are not the only ones that are d i f f i c u l t to communicate, but many are of t h i s nature. That i s why a t t i t u d e s are often e x p l i c i t l y stated only a f t e r an environmental d e c i s i o n has been acted on - a d e c i s i o n that s i g n i f i c a n t l y changes the world people l i v e i n and forces them to take conscious note of the m i l i e u . " When a p o l i c y i s being implemented, the impacts of that p o l i c y or the immediacy of impacts become very evident. Consequently, i t can be expected that those a f f e c t e d by the actions w i l l m o b i l i z e according to t h e i r perceived i n t e r e s t s . (This point w i l l be elaborated l a t e r i n a d i s c u s s i o n of s e l f - i n t e r e s t motivations i n the s e c t i o n e n t i t l e d ' d i s p o s i t i o n of implementors' .) Hargrove (1975, p. 110) points out that the short time horizon of both the general p u b l i c and p o l i t i c i a n s r a r e l y y i e l d s the p e r s i s t e n t w i l l necessary for implementation, and as a consequence, contrary to Bardach's argument, i n t e r e s t groups t y p i c a l l y have more i n f l u e n c e over the implementation than the p o l i c y formation stage of p o l i c y . Those groups who lose the p o l i c y b a t t l e can n u l l i f y or even reverse p o l i c i e s as they are implemented. 50 In support of t h i s p o i n t * , Bardach (1977, p. 51) s t a t e s : "The implementation process i s ... c h a r a c t e r i z e d by the maneuvering of a large number of semi-autonomous a c t o r s , each of which t r i e s to gain access to program elements not under i t s own c o n t r o l while at the same time t r y i n g to e x t r a c t better terms from other actors seeking access to elements that they do not c o n t r o l . " The r e c o g n i t i o n of awakened or thwarted i n t e r e s t s as having an important r o l e i n implementation adds an i n t e r e s t i n g and c h a l l e n g i n g dimension to understanding the process. I t suggests t h a t , while the p o l i c y formation process and output may i n f l u e n c e implementation, i t by no means c o n t r o l s or determines how the process w i l l evolve. C l e a r l y , u n c e r t a i n t y r e s p e c t i n g outcomes w i l l be a major c h a r a c t e r i s t i c of the process. A n t i c i p a t i n g Bardach, what we have i s a whole new b a l l game. Bardach agrees that u n c e r t a i n t y i s pervasive and argues to a p r o p o s i t i o n that the outcome of an implementation process i s indeterminate and therefore by d e f i n i t i o n u n p r e d i c t a b l e : "(This) leads us to a c r i t i c a l i n s i g h t about the implementation process: the maneuvers of the several p a r t i e s both express c o n f l i c t and create i t *There does not seem to be any t h e o r e t i c a l b a s i s for arguing that these actors need to be semi-autonomous. The argument concerning the process would p r e v a i l even i f the actors were groups. I n t e r e s t groups, la r g e or s m a l l , g e n e r a l l y cannot represent themselves as groups and, t h e r e f o r e , r e q u i r e s p e c i f i c r e p r e s e n t a t i v e s . These r e p r e s e n t a t i v e s can then f u n c t i o n as Bardach's semi-autonomous a c t o r s . 51 and with every maneuver aimed at reducing i t there i s the associated r i s k of a c t u a l l y making matters worse. In an important sense, t h e r e f o r e , much of the implementation process moves along 'out of c o n t r o l ' , d r i v e n by complex forces not of any party's making ." Bardach's l i t e r a t u r e review leads him to the conclusion a n t i c i p a t e d above that the implementation process can be described using the metaphor of a game. He suggests i t has u t i l i t y as a s t r u c t u r i n g metaphor: " I t d i r e c t s us to look at the p l a y e r s , what they regard as the stakes, t h e i r s t r a t e g i e s and t a c t i c s , t h e i r resources for p l a y i n g , the r u l e s of play (which s t i p u l a t e the c o n d i t i o n s for winning), the r u l e s of ' f a i r ' play (which s t i p u l a t e the boundaries beyond which l i e fraud or i l l e g i t i m a c y ) , the nature of the communications (or lack of them) among the p l a y e r s , and the degree of u n c e r t a i n t y surrounding the p o s s i b l e outcomes. The game metaphor also d i r e c t s our a t t e n t i o n to who i s not w i l l i n g to play and for what reasons, and to who i n s i s t s on changes i n some of the game's parameters as a c o n d i t i o n for p l a y i n g . " The metaphor of implementation game i s indeed u s e f u l for the d i r e c t i o n i t provides. I t w i l l , i n f a c t , be used as a guide to the l i t e r a t u r e c o n s idering elements of the implementation process serving as a check for missing components. 2.4 ELEMENTS OF THE IMPLEMENTATION PROCESS The b a s i s for the d i s c u s s i o n on the important elements that compose the p o l i c y implementation process and shape p o l i c y outcomes i s contained i n an a r t i c l e by Van meter and Van Horn (1975). Their statement i s summarized in the form 52 of a model, a diagram of which i s shown i n Figure 2.1. The model p o s i t s s i x v a r i a b l e s which shape the li n k a g e s between p o l i c y and performance. Each of the elements of the model w i l l be d e f i n e d , and the s i g n i f i c a n t features and questions h i g h l i g h t e d . To t h i s s k e l e t o n , arguments developed i n other w r i t i n g s w i l l be added with a view to developing a more comprehensive implementation process model. FIGURE 2. 1 A MODEL OF THE POLICY IMPLEMENTATION PROCESS Source: D. S. Van Meter and.C. E. Van Horn (1975) f 53 2.4.1 Policy Standards and Objectives Given the purpose of the implementation process i s to implement policy, i t i s fundamental to understand c l e a r l y what a policy i s intended to achieve. Without t h i s , i t i s not possible to determine the degree to which a policy has actually been implemented. To compete successfully in any game, the players need to know the object of play. In b i l l i a r d s , for example, i t does not matter how many h i t s i t takes to put the b a l l in the hole, so long as you are the f i r s t to accomplish t h i s ; in golf, i t i s very important to minimize the number of h i t s . The objective does make a difference. In some cases, understanding the objective i s not a problem, but often in the public policy arena, there i s , as Mead (1977, p. 137) c a l l s i t , the problem of the "lack of self-evident goals". A study of federal education projects in the United States (Nakamura, 1980, p. 1,096) concludes that "time, resource and information constraints lead policy-makers to i n i t i a t e vague p o l i c i e s which implementors are expected to define". This suggests that policy formation i s only a f i r s t step in actual policy d e f i n i t i o n . It i s recognized that ambiguity in objectives may be delib e r a t e l y fostered by policy-makers in order to transfer r e s p o n s i b i l i t y for any impacts [perhaps thought to be negative] to those responsible for implementation. If the objectives of the policy are not clear, the implementors are 5 4 forced to make an interpretation which can permit policy-makers s u f f i c i e n t verbal f l e x i b i l i t y i f the res u l t s do not measure up to the expectations of whoever. In research terms, th i s requires in-depth analysis of what i s actually expected of the implementation process by policy-makers and implementors a l i k e . Some recent l i t e r a t u r e does not f u l l y support the generally accepted position (cf. Lowi, 1969) which argued for the normative imperative that policy-makers should d e f i n i t i v e l y state the intent of p o l i c i e s prior to implementation . Rawson (1980, p. 1,109) argues the r e a l i t y of implementation with respect to the need for clear d i r e c t i o n : "The models of the policy implementation process that have been posited frequently c i t e organizational goals as an important independent variable in explaining the l e v e l of implementation success. Most research asserts that successful implementation requires a c l e a r l y stated organizational goal. ... one requirement for successful implementation i s (the) basic policy decision contains unambiguous policy d i r e c t i v e s . ... Such models are, by d e f i n i t i o n , oversimplifications of r e a l i t y . In r e a l i t y , the relati o n s h i p between organizational goals and the implementation process i s far more complex. If policy analysts are to contribute to the optimizing of public p o l i c i e s , i t i s essential that relationships such as t h i s one be scrutinized in great d e t a i l . By examining the relat i o n s h i p between goals and implementation success and f a i l u r e , a better understanding of the conditions necessary for successful implementation may emerge." 55 What t h i s says i s that we cannot be sure that a clear d e f i n i t i o n of objectives necessarily r e s u l t s in better or more f a i t h f u l implementation. One can envisage a situation where overzealous concentration on defined policy objectives during implementation could lead to less than optimal results such as in the case of a clear s h i f t in values from the time of policy formation to implementation. There can undoubtedly be degrees of c l a r i t y in terms of stated objectives. Courtner (1976), in her analysis of the United States National Environmental Policy Act, notes that, not only i s adopted policy not self-executing, administrators must apply the policy to a problem, but in so doing, they exercise d i s c r e t i o n as to how and to what extent their actions comply with statutory provisions and policy-makers intentions. It i s obviously better to have a good idea of what was intended, but no matter how clear the policy-makers may think the objectives have been spelled out, implementors s t i l l have to apply their own process to these objectives, and in some sense, the outcome of the process w i l l r e f l e c t the c h a r a c t e r i s t i c s of the implementation participants. Courtner makes the point that "because of interactions in the administrative system during the implementation process, actual policy impacts may d i f f e r s i g n i f i c a n t l y from the l e g i s l a t i v e a r t i c u l a t i o n of objectives". Interactions between participants w i l l invariably cause some consideration of the objectives of implementation and result in some form of accepted d e f i n i t i o n irrespective of the c l a r i t y of stated objectives . Related to the question of determining objectives i s the problem of defining an abstract policy into an operational mode so that i t can be implemented. It was suggested e a r l i e r that a policy can be usefully thought of as an " i f - t h e n " hypothesis. Pressman and Wildavsky (1973) argue that the implementation problem relates to the a c t i v i t y after the i n i t i a l policy conditions have been achieved and that lack of implementation should not refer to f a i l u r e to get going but to the i n a b i l i t y to follow through. It i s helpful in t h i s regard to distinguish between policy and program. A program consists of governmental action i n i t i a t e d in order to secure the attainment of objectives. It exists when the " i f " conditions of the policy hypothesis have been f u l f i l l e d . The word program thus s i g n i f i e s the conversion of a hypothesis into action. There are problems with viewing implementation as starting only after i n i t i a l conditions have been met. It suggests that program d e f i n i t i o n i s part of the policy formation process rather than implementation. Logical l y , I think t h i s i s incorrect. Policy output, the d e f i n i t i o n of the policy, i s a more reasonable cut-off point. The process of p u t t i n g that p o l i c y i n t o operation includes i t s r e d e f i n i t i o n i f necessary i n t o o p e r a t i o n a l terms and i s the f i r s t step i n implementation. Thinking back to Bardach's d e s c r i p t i o n of die-hard opponents of a p o l i c y who l o s t i n the adoption stage but seek and f i n d means to continue t h e i r o p p o s i t i o n when a d m i n i s t r a t i v e r e g u l a t i o n s and g u i d e l i n e s are being w r i t t e n , supports the view of p o l i c y o p e r a t i o n a l i z a t i o n as a feature of implementation. The e m p i r i c a l a n a l y s i s of t h i s study w i l l show i t to be a very c r i t i c a l f i r s t step. While p o l i c y o b j e c t i v e s can perhaps be purposely vague, o p e r a t i o n a l [program] o b j e c t i v e s cannot. The process of d e f i n i n g an o p e r a t i o n a l program must r e s u l t i n s p e c i f i c o b j e c t i v e s p e r m i t t i n g implementation and, i d e a l l y , e v a l u a t i o n as w e l l . McLoughlin (1974) argues that the v a r i a b l e s used i n c o n t r o l of a p o l i c y must be compatible with those of a p o l i c y ; (McLoughlin uses the word plan but p o l i c y i s interchangeable i n the context) and a l l key v a r i a b l e s used in the p o l i c y must be measurable by those c o n t r o l l i n g (implementing) i t . P o l i c i e s / p l a n s can be implemented only i f measures of a c t u a l d i s t r i b u t i o n s of these v a r i a b l e s are a v a i l a b l e to be compared with the p o l i c y i n t e n t i o n . Thus, two concurrent problems must be faced: the p o l i c y must be s p e c i f i e d at an o p e r a t i o n a l l e v e l and performance i n d i c a t o r s for the o b j e c t i v e s must be s p e c i f i e d ( i f implementation i s to be evaluated). In sura, the statement of p o l i c y o b j e c t i v e s i s of importance to the implementation process. This forms the b a s i s for the d e f i n i t i o n of o p e r a t i o n a l and thus implementable o b j e c t i v e s . But we should not expect a d i r e c t r e l a t i o n s h i p between the two. The r e d e f i n i t i o n of the p o l i c y i n v o l v e s i n t e r a c t i o n s of process actors and thereby renders the outcome somewhat indeterminate. The f a c t o r s which are thought to be important i n i n t e r a c t i o n w i l l be discussed i n the l a t e r s e c t i o n concerned with ' d i s p o s i t i o n of implementor s'. 2.4.2 P o l i c y Resources The concept of p o l i c y resources includes the e f f o r t committed and/or expended to achieve the p o l i c y r e s u l t s . I t includes the more v i s i b l e aspects such as l e v e l of funding and personnel commitment to a program as w e l l as i n c e n t i v e s that might encourage e f f e c t i v e implementation. I t can be expanded to include l e s s obvious aspects such as the p r i o r i t y given the p o l i c y w i t h i n the l e g i s l a t i v e , p o l i c y or implementation o r g a n i z a t i o n . Mead (1977, p. 122) r a i s e s the question of attempting to define misuse of resources. Implementation problems a r i s e because agencies have to coordinate t h e i r a c t i o n s with other 59 agencies that have d i f f e r e n t goals and procedures. The e f f o r t to work together consumes resources, but each agency may commit more resources to defending i t s t u r f against the incursions of others than i s r a t i o n a l from an o v e r a l l s o c i a l point of view. An implementation process which can be designed to structure cooperation/competition constructively can probably make better use of the policy resources and di r e c t them toward the policy goals rather than interorganizational goals. While not discussed in the policy l i t e r a t u r e , i t would seem that the mechanism used to implement the policy might be an important component of the policy resources components. There i s some water resources l i t e r a t u r e concerned with implementation mechanisms, but there i s c e r t a i n l y no comprehensive evaluation of the range of implementation mechanisms. One of the contributions of t h i s study might be to consider the degree to which the mechanism affects the outcome of the implementation process. As background for this question, from the available l i t e r a t u r e , six general categories of implementation mechanisms can be i d e n t i f i e d , as follows: ( 1 ) Regulation - Regulation i s the predominant mechanism used to implement public policy. This involves regulating the a c t i v i t i e s of public and private enterprises and individuals generally through the application of negative rules such as minimum o r maximum r e q u i r e m e n t s . W h i l e t h i s g e n e r a l m e c h a n i s m i s w i d e l y a p p l i e d , t h e r e a r e numerous k i n d s o f r e g u l a t i o n . E x a m p l e s i n c l u d e l a n d use z o n i n g , p o l l u t i o n d i s c h a r g e p e r m i t s and f l i g h t t i m e r e s t r i c t i o n s . ( 2 ) E c o n o m i c I n c e n t i v e s - I n a m a r k e t economy, i t i s g e n e r a l l y c o n c e d e d t h a t a p p l i c a t i o n o f e c o n o m i c i n c e n t i v e s b a s e d upon m a r k e t - t y p e i n f o r m a t i o n i s t h e most e f f i c i e n t means o f d i r e c t l y i n f l u e n c i n g p r i v a t e e n t e r p r i s e s and some p u b l i c o r q u a s i - p u b l i c o n e s a s w e l l . The p r a c t i c a l a p p l i c a t i o n o f t a x a t i o n and s u b s i d i e s t o a c h i e v e e n v i r o n m e n t a l p o l i c y o b j e c t i v e s h a s , h o w e v e r , n o t been p a r t i c u l a r l y e f f i c i e n t o r e f f e c t i v e ( c f . S t e p h e n s e n , 1 9 7 7 ) . A m a j o r r e a s o n c i t e d i s t h e i n h e r e n t d i f f i c u l t y f a c e d i n d e v e l o p i n g a sound s y s t e m t h a t a c t u a l l y g e n e r a t e s t h e d e s i r a b l e r e s p o n s e s i n t h e m a r k e t p l a c e . (3) P r o p r i e t a r y - P u b l i c a c q u i s i t i o n and d i r e c t p u b l i c d e v e l o p m e n t a l a c t i o n c a n be u s e d t o i m p l e m e n t p u b l i c p o l i c y . W h i l e t h i s m e c h a n i s m i s o f t e n t h o u g h t t o be a p a n a c e a , i n p r a c t i c e p u b l i c a g e n c i e s a r e o f t e n s u b j e c t t o p o l i t i c a l c o m p r o m i s e , i n t e r n a l c o n f l i c t s , i n t e r a g e n c y r i v a l r y , e t c . , and a r e o f t e n v e r y d i f f i c u l t t o c o n t r o l o r d i r e c t i f their developmental actions c o n f l i c t with environmental policy. The ongoing c o n f l i c t between the federal Ministry of Transport and Department of Environment over expansion of the Vancouver International Airport i s an example of serious problems a r i s i n g under a situation of t o t a l public owner ship. ( 4 ) Class and Individual Legal Standing - In instances where environmental impairment i s alleged to have occurred, an American mechanism used to implement pollution abatement p o l i c i e s has been to grant certain classes of c i t i z e n s and individuals standing before the courts to seek s p e c i f i c damages from pollutors. While these mechanisms have not been used in Canada, i t would be interesting to speculate on their u t i l i t y for implementing policy. (5) Vesting Property Rights in Common Property  Resources - The 'tragedy of the commons' i s that i t is in every common owners individual economic interest to exploit a common property resource to the greatest extent possible with the long-term result that the resource becomes seriously degraded. Vesting some ownership rights in such resources (for example, exclusive use) can be used in some instances as a means of providing particular groups or individuals with a long-term economic interest in a resource and thus help ensure e f f e c t i v e long-term management. An application of t h i s mechanism i s the entry r e s t r i c t i o n s invoked with respect to the west coast commercial salmon fishery [cf. Christy and Scott ( 1 9 6 5 ) and Dales ( 1 9 6 8 ) ] . ( 6 ) Education/In format ion - Altering public perceptions and/or attitudes through education and information programs i s often used as a p r i n c i p a l means of implementing environmental policy. An example i s the dissemination of flood hazard information to those l i v i n g on flood plains. Heberlein ( 1 9 7 3 ) suggests, however, that t h i s mechanism may be overrated and, i f used, ought to be integrated with other mechanisms. In considering the effectiveness or impact of an implementing technique, the standard approach has been to test how well i t meets the immediate management objectives. This i s c e r t a i n l y an important consideration, but in many instances, i t may not be the most important one. As noted in Chapter 1 , p r i o r i t i e s may change so that an important question with regard to any implementing mechanism i s whether i t f a c i l i t a t e s adaptation to changing p r i o r i t i e s so that inordinate costs are not incurred because i t fosters continued production of an inappropriate set of services or makes erroneous adaptations; i . e . , uses are changed when soci a l preferences do not warrant i t . The design of implementation processes requires therefore that mechanisms be adopted which not only bring about immediate re s u l t s but also f a c i l i t a t e the modification of p o l i c i e s to r e f l e c t new s o c i a l p r i o r i t i e s . For example, a mechanism for the purpose of implementing a policy to maintain a supply of a g r i c u l t u r a l land must not only be capable of establishing a g r i c u l t u r a l use in the f i r s t instance, but i t must also structure a process to consider f u l l y future c o n f l i c t s such as a professed need to s h i f t the land to urban uses. Policy resources are linked to at least three other components of the model i l l u s t r a t e d in Figure 2 . 1 . The type and extent of resources committed to implementation d i r e c t l y affect the strength of interorganizational communication. Simi l a r l y , the di s p o s i t i o n of implementors may be influenced by the l