The influence of interest groups on greening the skies Bringing aviation in the EU Emissions Trading System

Valeria Majori, 363047

Word Count: 27.459

Rotterdam, July 2012

M.Sc. International Public Management and Policy (IMP)

Faculty of Social Sciences

Erasmus University Rotterdam

1st Supervisor: Prof. Markus Haverland

2nd Supervisor: Dr. Harry Daemen

Abstract

This study investigates diverse theories that explain the influence of interest groups in a particular case concerned with the EU climate change policy. Three theories under examination are: access goods theory, structural characteristics theory and issue characteristics theory. The aim is to show that the newer theory of issue characteristics should not be underestimated along the more established two other theories. This research investigates in an in-depth case study which of these theories better explains the influence of two interest groups in the case of bringing aviation in the European Union Emissions Trading System (EU ETS). The two groups under examination are: European Regional Airlines (ERA) representing the aviation sector and Transport and Environment Federation (T & E) representing environmental interests. The research design applied to this case study is congruence analysis which tests theoretically derived predictions with empirical data, and establishes which theory has a better explanatory power. In addition, for the purpose of this research this design is combined with a method of process-tracing in order to measure interest group influence, and to trace the whole chain of lobbying activities. The study finds that both, structural characteristics and issue characteristics theory better explain the influence of interest groups rather than access goods theory. The conclusion is that while the well-established theory of access goods should not be taken for granted when examining interest group influence, there is a need for further research for testing the newer theory of issue characteristics. It would be crucial for the future research to test this theory in multiple cases as this study considers it applied to only one case, and therefore one of the limitations is that the findings cannot be generalized.

Key words: interest group representation; lobbying; influence; congruence analysis; process tracing; climate change; the EU Emissions Trading System.

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Acknowledgements

First of all, I would like to thank my professor Markus Haverland, for his valuable and constructive comments throughout the writing process which helped me to improve the quality of my research, and inspired me to meet the final deadline in time. I am also thankful to Dr. Harry Daemen who was willing to be the co-reader of this research study. In addition, I would like to thank my master thesis circle colleagues: Lisa Poot and Debolina Sarkar. It was a pleasure to work with them both during the past months and I would like to thank them for all of the valuable and critical comments, and also for their support.

Finally, I would like to express my gratitude to the interviewees: Mr. Leonardo Massetti from European Regional Airlines and Association, and Mr. Bill Hemmings from Transport & Environment Federation. Also, I would like to thank two other interviewees: Ms. Cait Hewitt from European Aviation Federation and Dr. Manfred Treber from German Watch. These interviews were a crucial source for this in-depth study on the influence of interest groups in the case of bringing aviation in the EU Emissions Trading System. I highly appreciate the interviewees’ willingness to contribute to this research and I am thankful for the time and effort they have spent on proving the necessary information.

Rotterdam, July 2012

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Table of contents Abstract1Acknowledgments2List of contents3List of tables5Abbreviations6

1. Introduction....................................................................................................................7 1.1 Introduction.................................................................................................................7 1.2 Problem statement.......................................................................................................8 1.3 Research aim and research question...........................................................................9 1.4 Theoretical and societal relevance............................................................................10 1.5 Research structure.....................................................................................................11

2. Background - interest representation in the EU.......................................................12 2.1 Definitions of lobbying and types of interest groups................................................12 2.2 Defining influence....................................................................................................13 2.3 Routes to influence - whom to lobby?......................................................................14 2.4 The EU decision-making process: the ordinary legislative procedure.....................153. Theoretical framework...............................................................................................17 3.1 Selection and specification of theories.....................................................................17 3.2 Access goods theory ................................................................................................19 3.2.1 Predictions.............................................................................................................21 3.3 Structural characteristics theory................................................................................21 3.3.1 Predictions ............................................................................................................22 3.4 Issue-characteristics theory.......................................................................................23 3.4.1 Predictions ............................................................................................................244. Research design...........................................................................................................25 4.1 Discussion of available designs................................................................................25 4.1.1 Quasi-experimental design....................................................................................25 4.1.2 Cross-sectional design..........................................................................................26 4.1.3 Case study.............................................................................................................27 4.1.4 Selection of design: case study - congruence analysis..........................................27 4.2 Discussion of available methods for measuring influence.......................................27 4.2.1 Attributed interest method....................................................................................28 4.2.2 Assessing the degree of preferences attainment...................................................28 4.2.3 Process-tracing method.........................................................................................28 4.2.4 Selection of method: process tracing combined with congruence analysis..........29 4.3 Data collection..........................................................................................................29 4.3.1 Desk research........................................................................................................29 4.3.2 Interviews..............................................................................................................305. The case of including aviation emissions in the EU ETS.........................................33 5.1. EU climate change policy and the EU ETS.............................................................33 5.2. The case - Directive 2008/101/EC...........................................................................34 5.3. Identification of relevant interest groups.................................................................356. Process tracing applied to the case............................................................................37 6.1 Preferences of interest groups in regard to the case..................................................37 6.1.1 Transport and Environment (T & E).....................................................................37 6.1.2 European Regional Airlines Association (ERA)..................................................38

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6.2 The final outcome Directive 2008/101/EC...............................................................38 6.3 Comparison of preferences versus the final outcome...............................................39 6.4 The course of political decision-making process......................................................41 6.5 Tracing the lobbying process....................................................................................43 6.5.1 Lobbying the Commission....................................................................................43 6.5.2 Lobbying the European Parliament......................................................................44 6.5.3 Lobbying the Council and additional lobbying...................................................44 6.6 Comparison of the scope of activities.......................................................................45 6.7 Statements concerning the final outcome.................................................................467. Congruence analysis proper – data analysis............................................................48 7.1 Access goods theory.................................................................................................48 7.1.1 Prediction 1: providing information to the right institution..................................48 7.1.2 Prediction 2: scope of information inflow and meetings......................................49 7.2 Structural characteristics theory................................................................................49 7.2.1 Prediction 1: staff and membership size...............................................................49 7.2.2 Prediction 2: more diverse lobbying activities and special lobbying techniques. 50 7.2.3 Prediction 3: status quo versus policy change......................................................50 7.3. Issue-characteristics theory......................................................................................51 7.3.1 Prediction 1: public visibility of the issue.............................................................51 7.3.2 Prediction 2: increasing saliency of the issue.......................................................51 7.3.3 Prediction 3: degree of conflict – forming alliances.............................................52 7.4 Conclusions on congruence analysis proper.............................................................538. Conclusion...................................................................................................................55 8.1 Summing up the research..........................................................................................55 8.2 Answer to the research question and findings .........................................................55 8.3 Recommendations for future research......................................................................57

References................................................................................................................................58Appendix 1: List of interviewed persons (May – June 2012)..............................................63Appendix 2: List of people contacted for an interview........................................................64Appendix 3: Questionnaire for interest groups under investigation..................................66Appendix 4: Questionnaire for other interst groups...........................................................68Appendix 5: List of published position papers by both interest groups............................70

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List of tables

Table 1 Data collection sources for the process-tracing method .............................................32Table 2 Comparison of Transport & Environment preferences versus the final outcome ......40Table 3 Comparison of European Regional Airlines Association preferences versus the final outcome ....................................................................................................................................40Table 4 Number of issues reflected in the final outcome ........................................................41Table 5 Time line of decision-making process in including aviation in to the EU ETS .........42Table 6 Summarizing and comparing lobbying activities .......................................................46Table 7 Staff and membership size ..........................................................................................50Table 8 Results of testing theoretically derived predictions with empirical observations ......53

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Abbreviations

AEA Association of European Airlines

AWG Aviation Working Group

CAN-Europe Climate Action Network Europe

CO2 Carbon dioxide

CEO Corporate Europe Observatory

DG Directorate General

ECCP European Climate Change Programme

ENVI Committee Environment, Public Health and Food Safety Committee

EP European Parliament

ERA European Regional Association

EU European UnionEU ETS European Union Emissions Trading System

IATA International Air Transport Association

ICAO International Civil Aviation Organization

NGO Non-governmental Organization

MEP Member of the European Parliament

NOx Mono-nitrogen oxides

T & E Transport and Environment Federation

UK United Kingdom

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Chapter 1: Introduction

1.1 IntroductionThe phenomenon of ‘lobbying’ has recently drawn attention of social science scholars due to the rising number of actors involved in lobbying activities at both, national and the European levels. As a matter of fact, the Latin word labium means an entrance hall or a lounge, and lobbying refers to the fact that political decisions are also often made in the pre-parliamentarian phase with the aim of balancing different interests of multiple actors (van Schendelen, 2010: 47). Interest groups play a central role in all democratic political systems as they can also be stated to represent civil society, which is vital for democracy due to its ability to build social capital and trust. As pointed out by Hix & Hoyland (2011), civil society in Brussels is more developed, dense, and complex than in any national capital of Europe (Ibid.: 159). This is one of the main reasons why Brussels has attracted a great number of interest groups.

It is often claimed that the politics and policy-making in Brussels can be characterized by the lack of transparency, as it not always clear what actions are performed and how decisions came about. Interest groups try to manage the European Union (EU) policy cycle through their lobbying efforts for their own interests, and this also leads to a unique European lobbying process where openness and transparency of political institutions can be increased due to their involvement. Therefore, lobbying plays a double role as it is an instrument to represent the priorities of interest groups and a way to influence the decision-making process, while at the same time, it is also a solution for the so-called ‘information deficit’ of the EU institutions. Interest groups have a unique role in the European decision-making process as it can be stated that none of the actors possesses too much power in relation to others, and thus, different actors become dependent on each other for different resources (Coen & Richardson, 2009).

Lobbying in Brussels differs from traditional lobbying in the member-states due to its multi-level structure. Lobbying takes places on the multiple levels as the adoption of EU legislation requires involvement of the Commission, the European Parliament (EP) and the Council of Ministers, which means that interest groups would usually target all of these levels. As there are different relationships between these institutions, lobbying one of them does not necessarily render the same results when lobbying another one. In addition, the EP has recently gained more power due to the adoption of the co-decision procedure which means that interest groups also had to adjust their strategies accordingly.

Together with the dynamic development of the European institutions, the launching of the internal market and the wider European integration the amount of interest groups operating at the European level increased considerably, and interest representation has become a widely researched topic. In academia interest group representation has been analyzed from different perspectives, such as: in single policy fields, in relation to democracy theories and European integration, and also in terms of the impact that private actors can have on the European decision-making process. However, the latter issue has been rather poorly researched which is perhaps well characterized by the words of Beyers et al. (2008): much we study little we know. Researching interest groups influence remains a somehow niche field within political science, and according to the authors this is partly due the fact that this issue has been approached through isolated case studies, weak conceptualization of the term influence and one-sidedness of research questions (Ibid.: 1117). Therefore, the essential questions remains: what explains the influence of interest groups?

The focus of this study touches upon the EU environmental policy, and particularly climate change, as it is currently one of the biggest threats facing the planet and it now at the

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top of the political agenda worldwide. It is also one of the top priorities for the EU which has long been a driving force in international climate change negotiations that, for instance, led to the United Nations climate treaties, such as the Kyoto Protocol in 1997. The EU’s initiatives have included mandating the increased use of renewable energy sources, supporting the development of carbon capture and storage technologies, and launching the European Climate Change Programme (ECCP) in 2000. The latter one led to the adoption of new measures and policies, including the EU Emissions Trading System (EU ETS), which is perceived as a key tool for reducing greenhouse emissions in an environmentally friendly and cost-effective way (European Commission, 2012a).

The EU has recently also decided to mitigate the climate impacts of the aviation sector by including aviation in the EU ETS with the Directive 2008/101/EC, or the so-called Aviation Directive. Aviation currently contributes about 2 per cent of global carbon emissions, and the challenge is to maintain economic benefits of the aviation sector while also tackling its environmental impacts. With this decision the EU is imposing a cap on CO2

aviation emissions from all international flights that arrive at or depart from an EU airport from January 2012, which means that aircrafts will have to surrender emissions permits to match the emissions produced during the flights. However, as much as 85 per cent of the allowances based on the 2004-2006 average emissions of aircrafts will be given free of charge, while 15 per cent will be auctioned between different sectors (the EP & the Council, 2008).

The issue of including aviation in the EU ETS is of controversial character as different parties have expressed their dissatisfaction and concerns with this decision. While environmental interests voiced their opinion that the adopted measures are not strong enough and will actually lead to increased emissions, the aviation industry pointed out that the measures will burden the aviation sector and the European single market, while also causing an ‘international legal mess’ (Phillips, 2008). The EU’s main trade partners, such as, China and the United States have also condemned it for potential hidden agenda of protectionist policies (Pisany-Ferry, 2012). In addition, the EU ETS has been criticized for its failure as according to some reports in reality it has rewarded major polluters with windfall profits, and it undermines the efforts to cut pollution and to achieve sustainable economy (CEO, 2011).

The aim of this research is to shed light on the poorly researched topic of interest group influence while taking the issue of inclusion of aviation in the EU ETS as its case study. The following two sub-sections will indicate the problem statement, elaborate on the aim of this research and present the central research question. This will be followed by description of the theoretical and societal relevance of this research study, and finally, the structure of this paper will be explained.

1.2 Problem statementA relatively wide scope of issues concerning lobbying has been previously researched in academia, such as: the Europeanization of the EU policy process; the nature of EU lobbying and how business interests appear to be better represented than other interest groups; access strategies to the EU institutions; the choice of which institutions to target; and different routes for approaching the EU policy-process. As pointed out above, researching actual interest group influence has somehow remained a niche field (Beyers et al., 2008).

Dur (2008a, 2008b, 2008c) acknowledges that due to inherent difficulties in measuring interest group influence, only few studies have addressed the question of influence and policy consequences of interest representation before. According to him, measuring influence of interest groups remains a complicated task due to three distinct problems: the existence of different channels of influence, counteractive lobbying, and the fact that influence can be

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wielded at different stages of policy making. With regard to the first problem, the measurement mostly neglects the possibility that influence can be exercised through a variety of channels. Second, even though the outcome of policy might not be close to a lobbying group’s interest, it does not necessarily mean that the group lacked influence, rather it could be explained by the fact that it had to counter the interests of another groups. Third, it is difficult for a research to measure influence and to track influence attempts at all stages of policy process.

Mahoney (2007) notes that scholars have been long avoiding the question of interest group influence, and have been focusing on different lobbying related phenomena instead. These phenomena are: formation and organization of interest groups, their access strategies to policy-makers, and their lobbying activities. Instead of studying influence per se, Mahoney investigates the so-called ‘lobbying success’. According to her it can give a sense of who is winning or losing in policy-making process, and an understanding of the reasons behind it. However, lobbying success does not always prove influence of a group, as an outcome might be in line with one’s preferences even though no action was taken to bring that outcome. Furthermore, she argues that factors at three different levels determine the final success of interest groups: institutional, issue-specific and interest group characteristics.

Also Bouwen (2004) states that measuring influence is rather problematic, and due to this fact he is, instead, focusing on studying the access of business interests to the EU institutions. He admits that access does not necessarily imply influence, but it can be claimed that a close relationship exists between the two as power cannot be reached without access. Bouwen proposes a theoretical framework that explains the access of different organizational forms of business interests to the European institutions. The degree of access to these institutions is explained with a theory of supply and demand of access goods. The most important access good is usually information which is crucial for the EU institutions in policy making processes, and every institution has is own type of information that it most requires. Therefore, if an interest group can provide demanded access goods to the right institution, in return, it can access the policy-making process which can possibly lead to influence.

1.3 Research aim and research questionAs pointed out above, research concerned with interest group influence shows considerable gaps in establishing what leads to successful influence on EU policy-making, and this still remains an important question in political science research. Therefore, the aim of this study is to narrow down this gap and to improve our understanding of what factors are decisive and affect influence exerted by interest groups. This will be investigated by testing three theories which have been previously used in academia for explaining influence attempts and success. These theories are: access goods theory, structural characteristics theory and issues-characteristics theory. Predictions derived from these theories will be tested against empirical data by applying a research design called congruence analysis. The aim is to establish which of these theories has better explanatory power when it comes to influence of interest groups in the case of lobbying the Directive 2008/101/EC as of bringing aviation in the EU ETS... The results of this case study can provide valuable insights to interest groups influence research. However, a case study design also has its limitations, as focusing on only one case diminishes external validity and does not allow generalization. Therefore, the objective is not to generalize, but to trace activities of interest groups on a process level in an in-depth assessment of one particular case of bringing aviation in the EU ETS, and to show what factors lead to influence.

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Followed by the research aim the central research question is:

Which theory better explains the influence of interest groups in the case of bringing aviation into the EU Emissions Trading System (ETS)?

1.4 Theoretical and societal relevancePrevious academic literature points out that the EU lobbying is both diverse and complex. The gradual transfer of regulatory functions from member states to the EU institutions (e.g. product quality, health and safety, environmental standards) has greatly contributed to the Europeanization of interest groups. With the development of the single market and the growth of political institutions in the EU, Brussels has become a focus point for lobbying activities, and this process has become one of the researched topics in political science (Bennett, 1999).

Theoretically, relevant research contributes to arriving at a better understanding of the studied phenomena. The research is theoretically relevant if it can ‘’contribute to the specific scientific discourse and to the advancement of the knowledge produced by it’’ (Lehnert et al., 2007:25). The present research is theoretically relevant as it can contribute to the discourse of interest group lobbying and influence, especially because it has a strong theoretical emphasis due to the application of congruence analysis method. This research will test political science theories empirically, and the aim is to give a better understanding of what determines the influence of interest groups on the EU decision-making. Taking into account the problem statement mentioned above that few similar in-depth studies have been conducted in the past, this research can serve as a valuable addition to the theoretical discourse on interest groups and their influence.

With regard to societal relevance, according to Lehnert et al. ‘’socially relevant research furthers the understanding of social and political phenomena which affect people and make a difference with regards with explicitly specified evaluative standards’’ (Ibid.: 27). As there is a demand for transparency and democracy at the EU level, and as lobbying is an important part of Europe’s civil society, it is societally important to understand what role interest groups play in the decision-making process and whether they can influence it to some extent. Hence, trying to answer the question of interest group influence is highly relevant for both, debates on the democratic legitimacy of the EU, and our understanding of policy-making in this entity. Explanation of policy outcomes and democratic legitimacy depends on how much influence interest groups have, and how influence is distributed among them.

The current research would also benefit interest groups themselves, and especially the newly established ones, as the findings intend to show what factors matter and should be taken into consideration when attempting to influence decision-making processes at the EU level. Moreover, this study is concerned with environmental policy, and particularly with the issue of climate change, which is a societally relevant issue as it affects all the citizens of the EU member states, and it also transcends the EU borders affecting the whole world.

1.5 Research structure

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Chapter 2: Background - interest representation in the EU2.1 Definitions of lobbying and types of interest groups

One of the earliest research definitions of ‘lobbying’ is given by Milbrath who considered lobbying as a communication process, and he was the first to analyse it from the viewpoint of communication studies. As he put it ‘’communication is the only means of influencing or changing a perception; the lobbying process, therefore, is totally a communication process’’ (Milbrath, 1960: 32). Lobbying or interest representation, are generally defined as the attempted or successful influencing of legislative or administrative decision by public authorities. A lobbyist or interest representative can refer to an individual or organization that tries to influence policy, but is not trying to be elected (Koeppl, 2001: 71). Van Schendelen (2010) uses the term ‘lobbying’ in its neutral or technical meaning as ‘’the build-up of unorthodox efforts to obtain information and support regarding a game of interest in order to eventually get a desired outcome from a power holder’’ (Ibid.: 48). He defines a lobby group as a pressure group that acts in this way. In this context, unorthodox refers to non-institutionalized patterns of behaviour, and is often considered uncertain or even risky regarding its effects.

It can be claimed that there are two types of interests, those defending concentrated interests and those defending diffuse ones. Against the pluralist theory assumption that opposing groups will naturally have equal access to power, Olson (1965) gives a reasonable explanation of why this is not necessarily the case. Hix & Hoyland draw on a ‘logic of collective action’ problem coined by Olson which refers to the fact that while there are high incentives to join a group where membership will give benefits only for the members of the group (private interests), there are low incentives to join a group with benefits for society as a whole (public interests). Diffused interests are generally believed to be less influential as they

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have to face a ‘collective action problem’, this means that members of a group can simply ‘free ride’ at the expense of others and it is more difficult for them to get organized than for concentrated interests (Hix & Hoyland, 2011: 160). Moreover, these interests are expected to be less endowed with crucial resources, such as expertise and money. Business groups which belong to concentrated interests can also benefit from their structural power, as they can threat to relocate investment and employment across borders to gain influence. By contrast, those groups defending diffuse interests may have an advantage whenever they can make use of grassroots members and the possession of the ‘moral high ground’ (Dur & de Bievre, 2007b: 6).

In order to overcome biased outcomes two alternative 2.2 Defining influence

A considerable obstacle in empirical research on interest group power and influence is the lack of agreed definitions of the two terms: influence and power. Power can be understood as a property, capability of an actor or a causal concept. In addition, different ‘faces of power’ can be distinguished, the first one concerned with who wins and who loses in a situation, while the second one refers to an ability to set an agenda and to keep unwelcomed issues off the table. The third face refers to one’s capacity to make one’s genuine interests or preferences look different from the formally stated interests. Dur argues that a possible solution for overcoming difficulties in studying these different phases is rather focusing on a certain one (Dur, 2008b: 1221). This study will follow the definition of influence given by Dur (2008b) who states that it can be understood as the ability of interest groups to shape political decisions in line with their preferences (Dur, 2008a: 561). Therefore, the necessary condition for influence attainment would be the convergence between an interest group’s preferences and policy outcome. The so-called ‘control of the outcomes’ approach assumes that actors have clear preferences over outcomes, and Dur & de Bievre (2007) consider it as the most sound route towards assessing influence. However, sometimes actors may not have or voice clear preferences at the beginning of policy process, or might change them due to the interaction with other actors. As Michalowitz (2007) points out in her empirical study, the so-called directional influence seems highly unlikely which refers to interest group’s aim to change the core of the legislative act. On the other hand, technical influence is more likely to take place which refers to the situation when interest groups invoke a mind change in the decision-makers and do not necessarily get their preferences to the policy outcome (Ibid.: 136). Mahoney (2007) notes, that often scholars can have a simplistic view on influence that suggests a zero-sum game between different actors. However, in reality the opposite non-zero-sum game characterized by a compromise, which means that multiple players can win, is much more common. She gives an example of an environmental regulation proposal where environmental groups are expected be in the opposition to the industry representatives. What is often the outcome is that ‘’a regulation gets passed, but it is watered down’’ (Ibid.: 37). This means that environmental groups have been successful to some degree as the regulation legislation gets passed, but at the same time, the industry groups saved in revenue as more of their references were included in the final outcome. Hence, when assessing influence it is recommendable to consider ‘’what they sought and what they got, allowing room for degree of success’’ (Ibid.: 37). As the proposals from the Commission almost invariably lead to a policy outcome, for this reason interest groups need to work to modify the proposal at an early stage and are more likely to attain partial lobbying success at that stage. This is somehow different in comparison to the lobbying activities in the United States where a proposal can be still ‘silenced’ at later stages of policy-making (Ibid.: 39).

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2.3 Routes to influence – whom to lobby?

According to Greenwood (2007) what makes the EU distinctive, is its multi-level context and the way how it shapes interest representation, and how the EU institutions are actually dependent on outside interest groups. There is a highly structured environment in which private and public interest operate and institutions try to channel their contribution to systemic input and output legitimacy. The roles of interest groups span from the framing of issues and agenda setting issues, contributory thinking, detailed input to drafts, consideration of measures and policy implementation, and political participation.

The relation between interest groups and the EU institutions is an interdependency which explains the growth of the groups and the widening of the EU competences. Actors who wish to participate in the European policy process can choose between different ‘routes’ of influence, while national route refers to the use of national contacts and national governments, the European route supposes direct targeting of the EU institutions themselves. As this research only focuses on the European route to influence, what follows below is a short description on how and when different EU institutions can be targeted by interest groups (Ibid.: 21).

The Commission is a crucial venue for lobbying activities due to its central role in the EU legislative process. It is an agenda-setter and has a formal right to initiate legislation by drafting legislative proposals. The drafting takes place in the first phase is the first phase of the legislative process and requires a substantial amount of technical and political information. Due to its relatively small size and lack of internal resources it needs input from interest groups in terms of expertise and information and it can have formal as well as informal meetings with groups (Greenwood, 2007). Lobbyists acknowledge the fact that as long as no formal documents are produces during the formulation stage, changes to proposals can be made much easily before it reaches the level of public political discussion (Bouwen, 2009: 20). The EU legislation originates from the Commission’s responsible Directorate Generate (DG) where a civil servant from a technical department drafts a proposal. There are currently twenty-four DGs. Therefore, a ‘drafting period’ and targeting technical civil servants of the Commission is crucial for influencing policy making. Civil servants are relatively open to external groups as they try to draft technical and expertise-based proposals in order to portray the EU decision making as successful as possible, and they are seeking to increase the competences of the Community. In addition, the Commission has a technically-oriented structure which is small in its capacities and resources compared to national bureaucracies (Koeppl, 2001: 75-76).

The European Parliament (EP) is the EU’s only directly elected political organization and as it has recently gained more legislative power, it has become a more attractive venue for interest groups to target. The EP has competency to amend the Commission’s proposals, and in the same way as interest groups can serve as a source of information to the Commission, this is also the case for the EP. It is not only the supply of information that interest groups can provide, but they also offer it a degree of independence from the other institutions. Even though, the plenary session of the EP has a final saying on legislation, the legislative work takes place before that in the specialized standing committees. As all legislative proposals and other documents have to be considered in these committees, they are an excellent venue for influence seeking interest groups.

In the first stage a proposal is passed to a leading committee which appoints a Rapporteur from its members to prepare a draft report on the proposal. As the Rapporteur can draw upon the resources of his own political group, both he and his political groups can be targeted by interest groups. After this, amendments to the proposal are discussed in the plenary and influence attempts become a little bit more challenging. As the Commission is the

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institution which already drafts a detailed technical proposal, the type of information that the EP needs is less technical and is more concerned with a European perspective as in how it would influence Europe and its citizens as a whole (Pollack, 1997: 581; Greenwood, 2007: 36-38).

The Council and the European Council are powerful actors of the EU, but the similarity of their names sometimes leads to confusion, even though in reality they are separate bodies with their own distinct decision-making roles. The Council (recently increasingly together with the EP) is the chief decision-making body, and the European Council takes the strategic decisions that shape the future of Europe. The literature reveals that they are the least accessible venue choices and there is little evidence that both of them would be widely lobbied, especially in comparison to the Commission and the EP. This is also, perhaps, due to the Council’s ‘’long-standing and often repeated reputation of being the most secretive and least accessible of the EU institutions’’ (Hayes-Renshaw, 2009: 70).

This negative perception tends to be applied also to the European Council. However, Hayes-Renshaw suggests that while both are less accessible than the other institutions, they are not completely ‘inaccessible’. Instead, interest groups can and do approach them at a number of different levels and entry points. The general recommendation would be to lobby them as early as possible as the function by gradually accumulated agreements is often based on compromises, it becomes harder to change the agreements as the dossier progresses further and further. In order to influence decisions of the Council one has to lobby national governments which requires having information that concerns member states’ interests and internal market, and that could facilitate the intergovernmental bargaining process (Ibid.: 86-87).

2.4 EU decision-making process: the ordinary legislative procedureThe ordinary legislative procedure, previously known as the co-decision, entered into force with the Lisbon Treaty making it the norm for most of the policy areas. The increased use of this procedure means that the influence of MEPs has substantially increased during the early stage of the legislation development, as now the EP and the Council have equal weight in deciding on the outcome of final legislation. This procedure applies to eighty there areas of the EU legislation including most environmental measures with a few exceptions, such as, town and country planning, management of water resources etc. The procedure starts with the Commission’s ‘right of initiative’ which means that it puts forward a legislative proposal. The proposal is a result of extensive consultation process which is usually accomplished through: impact assessments; reports by experts; consultation of national experts and international and/or non-governmental organizations; and also consultation among the different Commission departments to ensure that all the relevant aspects are included. After the Commission’s proposal the EP and the Council issue their formal positions in turns. In case there are no major disagreements, the act (be it directive, regulation or decision) can be adopted after one reading. However, often there are conflicts in opinions and both institutions will hold second readings. If at the end of these readings there are still disagreements, the ‘Conciliation Committee’ is assembled in order to negotiate a compromise text. This takes a form of ‘behind closed doors’ meeting including the EP, the Council and also the Commission. If the outcome of the meeting is an agreement it will be a ‘joint text’ which should be later formally adopted at individual meetings of the EP and the Council. However, if an agreement is not reached and it is then left to the Commission to bring forward a new proposal. In order to avoid a long conciliation process, the EP and the Council work hard behind the scenes in the Committees and the Working Groups in order to reach common positions before the main plenary or the Council meeting. In certain situations,

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also informal trialogue discussions after the first reading between the Commission, the EP and the Council are possible in order to reach a compromise deal (the Commission, 2012).

Chapter 3: Theoretical frameworkThis study applies congruence analysis as its research design. This type of design first derives predictions from relevant theories, after which they are tested by using empirical evidence. The aim is to provide empirical confirmation for the explanatory power of one theoretical approach compared to other theoretical approaches. Due to the choice of this particular design a chapter on the theoretical framework usually begins with the most important theories in a research field. There are two well established theories that are prevalent in the literature on interest group influence and that will be discussed below: theory of access goods and structural characteristics theory. However, as the theoretical aspiration of this study is to show that newer and less prominent theories are also useful in explaining influence, the recently proclaimed theory of issue-characteristics will be used as the third theory. For each theory a set of predictions is identified in this chapter and is later empirically tested in Chapter 7. As in congruence analysis causal inference is usually not based on co-variation among variables and not on the comparison between cases, predictions and observations do not need to be transferred into measurement tools, or the so-called indicators. The relevant criterion for judging the quality of predictions and empirical evidence is their

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concept validity (Blatter & Haverland, 2011: 30). The below predictions qualify this criterion as they express the meaning of the abstract conceptualization of the theories in a truthful manner. When it comes to the access goods theory it will be tested whether providing right information to the right institution and the amount of crucial information that is being provided matter. In regard to the structural characteristics theory, it will be tested whether monetary resources, more diverse lobbying activities and lobbying for status quo instead of radical policy change make a difference for lobbying success. Finally, in regard to the issue characteristics theory it will be tested whether public visibility of the issue, increasing saliency of the issue as a strategy and building stronger alliances also plays a role................... Before turning to the description of selected theories and theoretically derived predictions it is necessary to justify the selection of theories by reflecting on the theoretical discourse and on theoretical aspirations of the author. In addition, possible trade-offs stemming from the decision on how many theories will be selected has to be taken into account.

3.1 Selection and specification of theoriesWhile it is accurate to say that a large part of interest group literature has for long remained un-researched, there are some well established theoretical ambitions. The theory-oriented literature on interest representation includes: the corporatist-pluralist debate; studies on collective action; studies on European governance; and the Europeanization of interest groups (Woll, 2006: 458). As these four branches do not exactly touch upon the influence itself, the most recent research is instead focusing on the evolution of interest representation. At the same time, it is also paying attention to the logic, the conditions that determine who lobbies which entity, and the effect of lobbying. However, even though one of the central concerns in academia has been to establish who is in a position to influence policy making, few studies dared to measure influence per se (Ibid.: 460). The existing literature on interest group influence can be arranged in four broad clusters of determinants: interest group resources, political institutions, issue characteristics, and interest group strategies. Considering the first cluster, interest group resources mentioned in the academic literature include financial means, support, legitimacy, expertise and information (Bouwen 2002; Eising, 2004; Mahoney, 2007). The second cluster is emphasizing the explanatory power of varying institutional conditions and it is claimed that political institutions can shape actors’ access to policy-making process (Beyers et al., 2008; Pollack, 1997). The third cluster stresses the fact that influence success varies according to an issue at stake (Mahoney 2007, 2008; Baumgartner et al., 2009). And finally, the fourth cluster supposes that the choice of interest group strategies plays an important role when aiming at influence (Beyers, 2004). .......... According to Dur (2008b: 1220) conflicting findings in research on interest groups influence persist as there are three continuous obstacles: the difficulty of defining influence (See Chapter 2), the problem of measuring influence (See Chapter 4), and the need to consider several pathways to influence in order not to underestimate interest groups’ power (See Chapter 6). When it comes to the latter, the various pathways include access, selection, voice, and structural coercion. It is likely that groups use multiple pathways in order to achieve their objectives and to have influence. Therefore, the analysis of only one pathway may lead to a serious underestimation of the overall impact. For this reason, Dur recommends that future research takes into account these distinct pathways (Ibid.: 1223). Three theories are selected and specified for this research: theory of access goods, structural characteristics theory, and issue-characteristics theory. The first two theories can be

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considered prevalent in interest groups research on influence, and they are somehow complementary and overlapping as they both belong to ‘interest group resources’ cluster explaining access to the EU institutions. However, at the same time they also differ as the first one focuses on the exchange process of access goods between interest groups and institutions, while the second one is more concerned with characteristics and structure of an interest group itself, and particularly with its monetary resources. The third theory of issue-characteristics differs from the other two theories as it stresses the fact that influence varies according to the nature of issue at stake. The theoretical aspiration of this research is to add to academia a theoretical innovation as the two most prevalent theories presented above have shortcomings in explaining influence. The aim is to fill in the gap in interest group research and to shed light on the importance of a newer theoretical framework of issue characteristics, as in the recent years political science scholars have started to emphasize its importance (Mahoney, 2007; Baumgartner et al., 2009). As this theory also takes into account the degree of conflict between interest groups, the choice of using it for this study responds to Dur’s recommendation for future research. He states that while testing different hypotheses, research should take into consideration that interest groups often counteract each other’s lobbying efforts. As he puts it ‘’ignoring such countervailing pressures leads to the underestimation of the strength of different groups’’ (Dur, 2008b: 1226). When designing a congruence analysis it is important to be aware of the trade-off due to the number of theories that are being selected and specified. A convincing congruence analysis requires more than one theory but the exact number is up to each researcher. At least two theories are required as the analysis of congruence between theories and empirical observations is conducted in a comparative way (Blatter & Haverland, 2011: 2). As most small-N studies that apply congruence analysis usually focus on the major theoretical controversies, theories are being selected from different paradigms. If a theoretical aspiration is to establish that dominant theories cannot explain the case in a satisfying manner, the newer theories are also used in order to fill the gaps (Ibid.: 36-37). For these reasons, two theories are chosen from a more dominant paradigm, while the third one belongs to a less prominent paradigm. With regard to the results, a larger and more differentiated set of theories is likely to lead to more differentiated results, and it is probable that there will not be clear-cut results confirming one paradigm. Moreover, if considering all existing variants of the dominant paradigms and not reaching confirmation for them, it is easier to claim that a new theoretical approach is needed. In regard to conducting the congruence analysis itself, a larger set of theories will lead to more overlaps in the set of expectations (as a result, expectations will be in line with more than one theory), and the number of expectations per one theory will be reduced. In addition, a larger number of theories will analyse congruence between theory and observation for fewer aspects than in the case of choosing fewer theories (Ibid.: 39-42)......... The three theories that are being selected for this study belong to ‘resources’ and ‘issue characteristics’ clusters as characterized in the previous research. While ‘interest group strategies’ cluster will also be partially taken into account via conducting a process-tracing method in Chapter 6, the trade-off is that ‘political institutions’ cluster will not be taken into account for the aim of this research. This means that it will not be investigated in what manner political institutions can possibly shape the influence success of interest groups.

3.2 Access goods theoryDrawing on resource dependency theory, Bouwen (2002; 2004) considers lobbying as an exchange process where goods are exchanged between decision-makers and interest groups.

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This interdependency stems from the fact that both sides are not self-sufficient and require resources from each other. Hence, he focuses on both, the needs of different EU institutions and on the ability of different kinds of groups to respond to these needs. This resource exchange supposes a level of interdependence between interest groups and those institutions that are being targeted.

Bouwen has developed an access goods theory and he points out that access to the EU institutions is a precondition for exercising influence in a legislative process. However, it should not be taken for granted that access would automatically lead to influence as it is only a precondition for it. The need to exchange information results in a market-like situation where interest groups supply technical and political information to the political decision-makers. Different parties trade access in exchange for access goods (information is the most important one), while the demand side determines to whom access is granted. In his work, Bouwen presents a well-elaborated theoretical framework of business associations in the EU and uses access to decision-makers as a proxy for business group influence. Bouwen (2002) points out that there are three different ways of organizational form that a firm, or an interest group, can choose: individual action, national association and European association (Ibid.: 365-390). Since empirical results do not differ no matter whether only business groups or all types of interest groups are taken into account, his theoretical framework can be applied for researching interest groups in general, and for the purpose of this study the focus will be only on European associations.

In the resource exchange perspective the concept of opportunity structure is a framework that determines which resources are most valuable in gaining access in a given situation. In Bouwen’s analysis, the opportunity structure is determined by the informational needs of a given EU institution, while their needs depend on the institutional role and characteristics of that entity. Depending on that need, certain types of resources are better access goods than others and, and institutions require certain goods which are crucial for their functioning, therefore, the need for a certain type of resource depends on the specific institution at stake. The activities of interest groups cannot change the information needs of the Commission, the EP and the Council. As a result, the opportunity structure is a given for interest groups that aim to influence the EU policies (Ibid.).

There are three categories of access goods needed by the respective EU institutions. First, there is expert knowledge and technical know-how for the legislation which is a priority for the Commission since it has the responsibility of drafting legislative proposals, as proposals are drafted in the first phase of policy-making process this requires a significant amount of expertise. Second, there is information about the European encompassing interests which refers to the aggregated needs and preferences of a specific subset of society at the European level. This type of information is the priority for the European Parliament as it has to evaluate the Commission’s legislative proposals from a European perspective, and it needs information about the needs and interests in the EU internal market. Third, there is information about the domestic encompassing interests which refers to the aggregated needs and preferences of a specific subset of society at the national level. This type of information is of priority to the Council of Ministers which is the most intergovernmental institution, as it gives Member States information about the needs and interests of the domestic market.

Due to these different demands there are different requirements for interest groups in terms of what they need to offer to the European institutions in order for getting access to policy-making process. The more important access goods are for the functioning of an institution, the higher the chances that delivering them will result in access, and possibly influence. As interest groups differ in their ability to deliver these goods, consequently, the degree of influence of different groups varies (Bouwen, 2004: 346-348).

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According to Bouwen (2004) business groups and professional consultancies can

provide technical and sectoral expertise from a set of narrow constituents, and these groups are particularly active in the policy drafting stage. For example, Coen (1997) claims that the Commission is actually biased towards the kind of information that these kind of groups can provide. NGOs, on the other hand, can provide information about what appeals to their diffuse supporters and they can also put issues on the agenda and mobilize popular support. For these reasons, this type of information is useful to the directly elected and agenda-setting MEPs. Hence, it can be concluded that the ‘less economic’ interest groups target the EP as this institution needs information that is highly relevant to public opinion. These groups are often representing civil society on topics such as, environment and social equality.

Companies are rather efficient at providing technical expert information, while the same cannot be said about European associations, they cannot respond as quickly as companies due to their multi-layered structure. However, European associations are particularly good in providing information about the European encompassing interests since they manage to aggregate very diverse interests and to produce a consensus among them. In comparison, national associations provide high quality information about the domestic encompassing interests, but are not very good at providing expert knowledge or information about the European encompassing interests. As the success of interest groups depends on the type of resources that the EU institutions demand, consequently, a group will first target the institution for which it can provide the type of information that it needed (Bouwen, 2004).

Some of the criticism on this theory is that the linkage between access and influence is far from evident, and in many cases not linear. Although interest groups may find it easier to influence policy outcomes when they are ‘in touch’ with EU institutions, access does not necessarily translate into influence. As a matter of fact, opposing groups may have equal access and political actors can reject the demands made by interest groups. Public actors could even use access as an instrument to co-opt societal interests, and taking access as a proxy for influence can lead to erroneous results (Dur & de Bievre 2007b; Dur, 2008b: 1221). Moreover, many of the resources supposed to be used by interest groups to gain influence appear to be hard to measure, as the amount of information and knowledge that an actor possesses and whether a decision-maker really demanded resources (Dur, 2008b: 1215).

3.2.1 Predictions The following predictions are derived from the above theory:

1. If this theory applies, the EU institutions need different types of goods as the critical resource for each institution is different. Therefore, that interest group that used the most effective channel in targeting the venue for which it has the right access good, is likely to be more influential in the case. European Associations, which are under examination in this case study, best

provide information about the European encompassing interests which is the most important access good for the European Parliament (EP). That interest group that used this particular channel and provided this type of information to the EP, should be more influential in the case.

The second most important lobbying venue for European associations should be the Commission. That interest group that used this particular channel and provided this type of information to the Commission, should be more influential in the case.

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2. Based on this theory that interest group which provided more crucial information to

the European institutions through the information inflow (this can be measured through the amount of position papers and meetings), is expected to be more influential in the case.

3.3 Structural characteristics theoryThis theoretical framework considers the resources of interest groups, the possibility to use multi-level strategies and whether a group lobbies for status quo or policy change as crucial in determining their potential influence on policy-making. According to this framework the concept of resources is a crucial aspect. According to van Schendelen (2010) resources are the organization’s tool for survival, they are not fixed assets in permanent possession, but have to be acquired and constantly kept in good condition. A resource tool can be anything that contributes to effective and efficient participation, and can refer to expertise, networks or external positions (Ibid.: 205-207). For the purpose of this study resources in terms of financial means and are taken into account. As financial means resources enable an interest group to hire more staff and to have a bigger office, and to use more diverse strategies, there should be more chance for influence. In addition, also non-permanent characteristics in terms of whether an interest group is lobbying for a status quo or policy change in a specific case will be taken account.

In his study Eising (2007) considers three dimensions that help to access the European institutions: the EU institutional framework, the structure of interest groups and the strategic choices of interest organizations. When it comes to the last element it is not taken into consideration here as the results of Eising‘s research did not support any of his hypothesis regarding this matter. For the purpose of this research Eising’s notion of the structure of interest groups will be considered, as it contributes to the second theory of structural characteristics which can explain the lobbying success of interest groups.

Eising (2004) argues that the strategies of interest groups depend on their location in the EU multilevel system and on their governance capacities. He distinguishes two kinds of capacities: negotiation capacities and organizational resources. While the first one denotes the abilities to mediate between competing demands between actors, the latter one refers to resources which are crucial for interest groups as the pursuit of multi-level strategies requires money, time, expertise and sustained effort. It can be expected that interest group with greater resource capabilities can represent their interests easier and this should also translate into influence (Ibid.: 218). The complexity of the European multilevel setting requires actors to have considerable organizational resources in order ‘’to keep track of policy developments and to represent their interests continuously at the different levels of government and throughout the policy cycle’’ (Ibid.). A large amount of resources allows groups to hire specialized staff members, to acquire necessary expertise more easily, be active in strategies of political communication, to cooperate with other associations, and to ensure regular access to national and EU institutions.

Also Mahoney (2007) points out, that structural characteristics of interest groups influence success. First of all, in terms of their resources well-endowed groups can spend more resources on an issue, to use multiple strategies and tactics, and to devote more man power to the topic as the number of their personnel allows it. All these considerations should lead to more success in their activities, and as annual budgets and money spent on lobbying are has shown to be difficult to gather, staff number has been used as an indicator of the level of financial resources. In addition, engaging in not just direct lobbying but also in more specialized techniques is likely to lead to a situation of attaining one’s lobbying goals. Specialized techniques can include e.g. hiring a consultant, working through a coalition, or

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employing outside lobbying. The second important characteristic is membership size as ‘’larger groups convey some degree of legitimacy to policy makers’’ (Ibid.: 21). As a consequence, larger groups should be more successful compared to organizations which cannot represent a large number of citizens.

According to Dur (2008b) the larger the pool of members a group has, the more political legitimacy it can claim. Moreover, the type of membership matters as one can expect groups composed of firms to have reasonable monetary resources and groups made up from individuals to find it easier to mobilize resources (Ibid.: 1214). Eising (2007) claims that financial funds that interest groups receive from their members are crucial. These funds do not only allow organizations to specialize in their lobbying techniques, but also to be more efficient and to follow long-term strategies. In addition, chances of having contacts with the Commission are higher for those associations that have enough resources (Ibid.: 339).

The above mentioned structural characteristics are of permanent character referring to the capacities of interest groups. However, Mahoney (2007) argues that their non-permanent characteristics also play a role in whether they will influence policy-making. These non-permanent characteristics are: the position of an interest group on the case and the tactics a group uses during the lobbying process. For the purpose of this research the position of an interest group on the case will be taken into account. As Mahoney points out, due to the institutional stickiness it is easier for an interest group to stay still rather than to move to new policy equilibrium. As a consequence, those advocates that are lobbying towards a status quo are more likely to attain their lobbying goals, than those groups which are urging for a new policy that would change the current regulatory environment considerably (Ibid.: 23).

3.3.1 PredictionsThe following predictions have been derived from the above theory:

1. If this theory applies it can be expected that an interest group with the larger resources (administrative capacity, membership size, and annual budget if available) should be more influential in the case.

2. Based on this theory that interest group that is well-endowed and uses a larger number of programs and multilevel specialized lobbying strategies, and that also targets more than one institution in its lobbying activities, should turn out to be more influential.

3. According to this theory that interest group which is lobbying for the status quo and not for radical policy change, should be more influential in the case.

3.4 Theory of issue-characteristics The third theory used for the congruence analysis is the theory of issue-characteristics arguing that the degree of influence and success actually varies from one issue or policy field to another. Therefore, the following factors are important to consider when examining the influence success: policy type, scope of the issue or in another words saliency of the issue to the public, saliency of the issue to interest groups themselves and the degree of conflict between different groups. . . The first characteristic which is worth taking into account to and which has an impact on interest group influence is policy type. Drawing on Lowi (1964), Dur explains that it makes a difference whether an issue is of a regulatory, distributive or re-distributive type. In distributive politics the benefits of action are concentrated to one specific group and the costs are widely dispersed. In this case concentrated interests tend to win over diffuse interests, as the latter tend to face collective action problems. In regard to re-distributive politics, the overall influence should be rather small, as this kind of policies lead to diffuse costs and

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benefits. While regulatory decisions generally have concentrated benefits for one group, at the same time they pose concentrated costs for another group. In regulatory decisions at least two groups with opposing interests are expected to clash, and this should generally limit the power of all individual groups involved in a case (Dur, 2008b: 1217). As this part of the theory cannot help to derive a prediction which would point which of the two interest groups exactly will have influence in the case, it will not be used for the sake of this research. This part of the theory can only predict that as the issue of inclusion of aviation in the EU ETS is of regulatory character, strong opposing views in regard to the case are expected, and that consequently, influence of all interest groups would be limited. ........... According to Mahoney (2007) another critical component for understanding the lobbying success is considering the scope of the issue, or the so-called saliency of the issue to the general public. The larger the scope of the issue that is at stake, meaning that an issue has far reaching implications, the less influence interest groups are expected to have. Large scope issues include a large number of vested interests, and also a large portion of the general public is usually concerned with this kind of issues. This usually means that policy-makers dealing with these issues ‘’would not be well advised to follow the lead of a single special interest’’ (Ibid.: 40). On these issues a legislator cannot easily deviate from voters’ interests without a fear of ‘punishment’ in next elections, therefore, policy makers are expected to follow the general public opinion.

The scope of an issue can also be understood as issue salience, meaning that the more salient an issue and if it is of interest to a large proportion of the population, the less success there is to be expected for interest groups. This factor can be somehow influenced by the activity of interest groups as it is possible to increase the public interest in an issue for the benefit of an interest group, for example, via outside lobbying strategies such as media coverage. In this case of increasing public saliency the hope is that activities of an organization or an interest group will influence public opinion in its favor and against other different positions. However, it has to be noted that increasing salience can be endogenous as groups can raise the salience of an issue for their strategic reasons, but this would not necessary always increase their influence. While taking this fact into account, the expectation derived from the theory is that if a group tries to increase the saliency of an issue to the general public, a group is expected to be influential in the case (Ibid.).

In regard to the salience of an issue in relation to interest groups themselves, the presence of countervailing forces also matters. Issues that are characterized by conflict and clearly opposing camps lead to a very different lobbying environment compared to those issues where there is only one dominating and unopposed perspective. Consequently, interest groups are not likely to be successful if their lobbying activities fall into a highly conflicting issue (Ibid.). The issue salience among interest groups can be measured by the number of submissions received in the Commission’s online-consultation, and in order to check the salience to specific groups they can be asked about the importance hey attribute to the issue in an interview. However, as this part of the theory cannot directly predict which of the two interest groups at stake are expected to have more influence, the attention will be paid to a stronger alliance formation in order to have a clear prediction.

The degree of conflict between different interest groups can be tracked if groups on the one side of the debate join their forces in one voice against the other side. Michalowitz (2007) draws on the Sabatier & Jenkins-Smith (1999) advocacy coalitions framework to explain the success of interest groups that form alliances. This framework considers the degree to which interest groups form advocacy coalitions with other groups with similar interests, or the degree to which interest groups have to fight their cause against many opposed interests or coalitions. As Michalowitz (2007) puts it ‘’the degree to which interest

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groups are part of or outside a strong coalition of interests is likely to influence the strength of an opinion voiced to alter a legislative act’’ (Ibid.: 125). Bouwen (2002) points out that the advantage of alliances is that they provide interest groups with more resources in terms of man power, budget and knowledge. In addition, groups united in alliances can make use of each others’ expertise and networks inside the EU institutions. Moreover, argumentation of different groups becomes more reliable and more legitimate for the EU decision makers when spoken out through an alliance.

3.4.1 PredictionsThe following predictions are formulated based on the above theory:

1. Based on this theory in case if the general public was widely aware of the issue of bringing aviation in the EU ETS, and if it was more in favour of an environmental solution and concerned with the climate change, this would mean that a group lobbying for the environmental cause should be more influential than a group lobbying for the aviation interests.

2. Based on this theory that interest group that tries to increase salience of the issue at stake to the general public, is expected to be more influential.

3. If this framework applies that interest group that formed stronger alliance with other interest groups in comparison to the other interest group with different preferences, should be more influential.

Chapter 4: Research method

Thus far, this study has dealt with the background information on interest representation and the theoretical framework. This chapter first examines the available research designs types and then makes a choice of the most suitable and feasible design for this study. The research designs under discussion are quasi-experimental, cross-sectional and a case study. Experimental design with a controlled experiment is not being presented as it would not be feasible for the purpose of this research. In the second part of this chapter three established methods for measuring influence are being discussed and the most feasible method is being selected. The final part reflects on the process of data collection and difficulties encountered during this process. It is also being shown how the author tried to cope with these limitations to a certain extent in order to attain the necessary research data.

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4.1 Discussion of available designs

Three different research types which would be possible for this study are discussed in this sub-section. These designs are quasi-experimental design, cross-sectional design and a case study.

4.1.1 Quasi-experimental designQuasi-experimental design could be possibly chosen for this research study, and precisely the so-called 'interrupted times series design' accompanied with a comparison group. In his type of design 'the causal' variable is examined as an event or change occurring at a single time, specified independently of inspection of the data (Campbell & Ross, 1970: 116). In comparison, in the time-series analysis the variable is a continuously present variable which occurs in different degrees. In this study we would be looking at the development of the dependent variable (influence of interest groups) before and after the introduction of an independent variable (independent variables would be: exchange of information, resources, and issue-characteristics). Observation is done on the dependent variable and the participants would be interest groups involved in the case of bringing aviation in the EU ETS. Consequently, possible changes in data after the treatment can be linked to the elements of the introduction of independent variable.

This design is generally speaking feasible as it is easier to set up than real experimental designs which require random assignment of subjects, and randomization can turn out to be unethical. Other advantage is that external validity is higher than in other designs, as this design is testing hypotheses by taking place in more real world conditions. However, treatment is different from other cases. Co-variation can be observed, there is also temporal ordering as researches controls the treatment and thus X is before Y. However, as not many variables are controlled, consequently there are less causal claims.

As pointed out by Robson et al. (2001) adding a control group is one of the strategies to improve the design and to check on the threats to validity. Like in experimental design, there is at least one group which receives intervention (intervention group) and one which does not (control group). Contrary to experimental design, in this design groups are not randomly assigned. Generally speaking, experimental design can have limitations in regard to internal validity, but having control groups helps to control for that and is highly recommended as ''on balance, they (control groups) strengthen the evaluation design far more than they weaken it'' (Robson et al., 2001: 40). This design type will not be chosen as the unit of analysis is interest groups. In quasi-experiment we cannot control the application of the independent variable and subjects cannot be assigned to different groups, and this poses a problem when taking into account the topic and the central question of the this study.

4.1.2 Cross-sectional design This type of large-N design strengthens our belief in generality and average strengths of causal effects, however, it is at the expense of not explaining any single case in details (Gschwend & Schimmelfennig, 2007: 11). This design requires careful selection of control independent variable, and a regression analysis is performed on the data for estimating the result. The goal of the statistical analysis is to investigate whether there are correlations between one dependent variable and the various identified independent variables. One of its most powerful characteristics is the statistical control of confounding variables, especially when the relationship of interest cannot be easily separated from other effects (Graddy, 2011: 379). This design ''relies on existing differences rather than examining of interventions'' (Vaus, 2001: 172). In addition, data is collected at one point of time.

When it comes to establishing internal validity co-variation can be established, other

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variables are being held constant by statistical control, but temporal ordering poses a problem. There is difficulty to identify time sequence of events, and thus a problem of identifying a causal direction arises (Ibid.:173). The problem of time dimension needs to be solved through arguments drawn from theory. External validity is pretty high if sample represents population, and it is easier to generalize than from experimental design. As there is no time dimension we can avoid bias being introduced by sample attrition. If the initial sample is well selected it ''should yield data that are reflective of the population they were they were designed to present'' (Ibid.:185).

However, there are few threats for internal validity. It can happen that a relevant variable is excluded which is called 'ommitted variable bias', or that instead, an irrelevant variable is being included which can increase standard errors leading to inefficiency. The more standard errors there are, the more difficult it is to reject the null hypothesis (testing shows that there is no relationship in population, even though there is) which is also referred to as type II error. To overcome these threats it is necessary to identify independent variables according to plausible causal relationships drawn from theory and from previous literature on the subject (Kellstedt & Whitten, 2007: 93).

As Vaus points out the more variables we control statistically, the more certainly the final relationship we find between X and Y reflects the causal relationship between them (Vaus, 2001: 178). The theoretical causal mechanism will help to establish which variables are relevant and which are not (Ibid.; 180). Another possible threat is that there are not enough cases. And more cases there are, less likely it is that previously mentioned type II error would occur. As a rule of thumb there should be about 5 cases for each independent variable, and cases should be chosen randomly as they have to be representative of the population in order to establish external validity. Keeping this in mind, the chosen independent variables would have each 5 cases, which means that there would be twenty five cases in total. It is also important to include cases which are not related to independent variables in order to establish variation, this type of design is cost-effective as it ‘’does not entail the cost of repeated data collections, tracking respondents or of experimental interventions’’ (Ibid.: 176).

In order to control for internal validity a lot of cases should be chosen, and relevant variables will be chosen carefully to avoid errors. This design will not be chosen as the aim is not to generalize and look a broad spectrum of cases, but to study one case in EU environmental policy. In addition, large-N study would not be possible for the purpose of this research due to time restrictions and as the topic of interest groups influence would require a time consuming data collection for the purpose of large-N design.

4.1.3 Case studyAccording to Yin, a case study is relevant if the research is seeking to explain some present circumstances, how and why some social phenomenon works, or if it requires an ‘in-depth’ description of some contemporary social phenomenon (Yin, 2009). As he puts it, ‘’the distinctive need for case studies arises out of the desire to understand complex social phenomena because the case study method allows investigators to retain the holistic and meaningful characteristics of real-life events‘’ (Ibid.: 2). As the objective of this thesis demands an in-depth scrutiny of the social phenomenon of interest group lobbying, case study research design seems to be an appropriate and feasible design. Disadvantages of case studies are that a researcher might be too sloppy, and not follow systematic procedures and allow biased views to influence the findings. Also, case studies are not generalizable to populations or universes, but only to theoretical propositions. Another concern is that they might take too long and thus not be feasible, but they should be confused with participant observation

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method which requires a lot of time. While participant observation might be beneficial for case study research, it is important to note that it is not compulsory.

There are two approaches to conduct a case study. First, a co-variational design which is driven by co-variation and which compares at least two cases. And second, a congruence analysis which typically looks at one case and establishes congruence between theoretical expectations and observations within one case (Blatter & Haverland, 2011). The second approach is similar to what Yin describes as pattern matching (Yin, 2009).

4.1.4 Selection of design: case study – congruence analysis It appears that congruence analysis which compares theoretical expectations and empirical data would be the most appropriate approach for the research agenda of this study. It fits the aim of investigating what drives interest group influence and which theory could better explain the influence success. In congruence analysis case studies are used to ‘’provide empirical evidence for the explanatory relevance or relative strength of one theoretical approach in comparison to other theoretical approaches’’ (Blatter & Haverland, 2011: 1). Explanation is not driven by co-variation, but by establishing the congruence within one case between theoretical observations and expectations. First, a set of propositions and observable implications is deducted by reviewing theoretical literature. Then, empirical observations are being compared with theory implications. In order to increase the number of observations one can speculate a number of observations stemming from theory within the case. Thus, first relevant theories need to be chosen and then the cases selected (Ibid.: 9).

The major advantage of the case studies is that they allow for an understanding of the meaning of internal processes and interactions between actors and structures. Internal validity on individual case is ensured by congruence. Thus, causal analysis is based on the congruence between theoretical expectations and empirical data (degree of congruence between predictions and observations, and non-congruence between them for alternative explanations). To rule out of alternative explanations depends on: the number of predictions, the precision and certainty of predictions, the subtleness of the pattern of predictions, and the degree of uniqueness of predictions. In regard to external validity, the limitation is that generalization to population is not possible, but generalization to theory or the so-called 'theoretical generalization' by selecting crucial cases for the theoretical discourse is possible (Ibid.: 81).

4.2 Discussion of available methods for measuring influenceAfter selecting case study as a research design, it is important to discuss three methods of measuring influence and their methodological shortcomings as the aim of this research is to establish which interest group was more influential in the case of bringing aviation in the EU ETS. Dur provides a good overview of these methods and the following description of methods will be based on his academic articles (Dur, 2008a, 2008b, 2008c). At the end of this section one of the methods will be selected which will be used in combination with congruence analysis design.

4.2.1 Attributed interest methodThis method measures influence of interest groups with the help of surveys. The members of the group under examination can be asked to rank each other according to influence, either over the individual respondent or over the group. In addition, it can be directed at observers who report group’s reputation for influence. This method has an advantage of being relatively simple, but it also comes with some drawbacks which vary depending on the type of actors asked.

This is a reliable indicator as if there is a standardized set of specific questions for

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surveys for different evaluators the results can be expected to be the same each time. However, reliability can suffer from this method as self-estimation of influence can be biased (exaggeration or playing down of influence). Estimation of others’ influence, again, can be strategic as actors can apt for minimizing the role of other actors. In the case of asking experts, they might simply repeat the findings of academic studies or base their answers on widely accepted beliefs, for example, that big companies are more powerful). It can be argued that in all the variants of this method the measure actually assesses perceptions of influence, rather than actual influence. In addition, generally surveys are not strong enough to uncover all the necessary data (Dur, 2008a: 565-566; Dur, 2008b: 1224).

4.2.2 Assessing the degree of preferences attainmentThis method compares the outcomes of political processes with the ideal points of actors. In the most basic form “the idea is that the distance between an outcome and the ideal point of an actor reflects the influence of this actor’’ (Dur, 2008a: 566). In more complex approaches researches would try to control for other factors which might influence moving outcomes closer to or further away from ideal points. The advantage of this method is that influence can be detected even if nothing visible happens, e.g. lobbying is secret or structural play a big role. Due to the simplicity of the method, it is feasible to assess a relatively large number of cases which would allow generalization of the findings. The shortcomings of this method are that determination of preferences correctly might be troublesome, and it might be difficult to control for factors explaining a coincidence between preferences and outcomes. When quantifying the degree of influence, it is important to keep in mind that possibly only one or few specific aspects have been influenced, instead of only looking at the general picture composed of all the aspects. Therefore, disaggregation of political decisions to very specific issues is recommendable, however, this is not such a straightforward task (Dur, 2008a: 566-569; Dur, 2008c: 55-59).

4.2.3 Process-tracing methodProcess-tracing method is the most frequently used indicator for measuring influence. This method tries to uncover the steps by which causes affect outcomes. In order to measure interest group influence scholars scrutinize a groups’ preference, influence attempts, a group’s access to decision-makers, the course of political decision-making process, the degree to which interest group preferences are reflected in the final outcome, and a group’s statements with (dis)satisfaction in regard to the final outcome. The advantage of this method is that one will have a reasonably good knowledge of nearly all factors influencing a political decision. In addition, as this method often relies on semi-structured interviews, they can give a researcher important insights into developments not traceable in document analysis. Some of the disadvantages of this method are that getting empirical evidence that would cover all steps is sometimes not possible and that can lead to gaps in the causal chain. Researchers can also over-rely on interviews while neglecting making use of other potential and crucial sources. There can also be a lack of clear correlation between the level of group activity and influence, or the influence of interest groups could be overestimated as other factors that are not being taken into account might have played a role. In addition, cross-checking evidence from interviews against other sources might be troublesome, and generalization from small-N studies for which process-tracing method is used is not possible (Dur, 2008a: 562-565).

4.2.4 Selection of method: process tracing combined with congruence analysis

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Process-tracing method is chosen for this study as it best suits the goal of this research for investigating which theory can better explain influence of interest groups under examination. Process-tracing examines all the steps of ‘influence making’ path which greatly benefits the current research goal of scrutinizing what drives interest group influence. Also, it takes into account that interests groups can at times only influence one or few aspects of the final legislation, while the other two methods presented above acknowledge this feature to a lesser extent. As pointed out by Woll (2006) only knowing that policy outcome corresponds to the preferences of an actor is not sufficient, as even though an actor might seem powerful in a particular case, assumptions about influence making require a causal link (Ibid.: 72). For this reason, applying process-method is beneficial as it can provide an in-depth assessment of actors’ preferences, countervailing forces and the whole chain of lobbying process. Congruence analysis which has been chosen as the research design is combined with process-tracing method in order not only to explain which theory has a stronger explanatory power in scrutinizing influence of interest groups, but also for tracing as many steps as possible in interest group lobbying process. In addition, it can be established to what extent interest groups’ preferences are being reflected in the final outcome. The results of process-tracing (see Chapter 6) are used to check upon the congruence analysis proper (See Chapter 7) when predictions derived from theories are being compared with empirical observations. In this manner, theoretically derived predictions will be confirmed, disconfirmed or partially confirmed based on the empirical observations and the results of process-tracing. The results of process-tracing will pinpoint which of the two interest groups under examination is expected to be more influential.

4.3. Data collectionThe following sub-section clarifies what type of data has been used in this research and how it has been collected, while also reflecting on what difficulties have been encountered in the process and how the author tried to overcome them. Yin (2009) identifies six sources of evidence for case studies. These sources are: documents, archival records, interviews, direct observation, participant-observation, and physical artefacts. This study makes use of documents and interviews.

4.3.1 Desk researchData collection starts by conducting desk research and consulting different documents. According to Yin (2009) documents can refer to: agendas, memoranda, administrative documents, newspaper articles, journal articles, press releases, draft reports, and any document that is relevant to the investigation. In the interest of triangulation of evidence the documents serve to verify the evidence from other sources. For case studies ''the most important use of documents is to corroborate and augment evidence from other sources'' (Ibid.: 87). It means that documents can provide other specific details to affirm information from other sources. To conclude, it must be kept in mind and elaborated in the thesis that all sources have their strengths and weaknesses. For example, documentation can have a reporting bias (Ibid.: 86).

The following documents will be used for data collection for the purpose of this study: official documents, press releases, position papers, public statements, official reports and newsletters, academic articles, Legislative Observatory of the European Parliament database, as well as relevant web sites. These relevant websites are EUObserver and EurActive. EUObserver is a web site supporting the debate on and development of European affairs covering a wide range of topics, while EurActive is a media portal dedicated to the EU affairs

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establishing a platform for Brussels and national professionals in EU policies. One of the limitation of using the above stated data sources is that it is challenging to find information which would shed light on the lobbying activities of interest groups, therefore, in order to cope with this problem it is necessary to conduct interviews which are important sources for case study research.

In addition, as not as many interviews were possible as originally planned for and needed for this case study, the second best choice for additional data had to be found. Especially, in order to trace lobbying activities of two interest groups and to find significant differences in their lobbying efforts. This additional data was intended to be collected using such databases as ABI/INFORM and Factiva. ABI/INFORM Complete provides sources from trade and scholarly journals, reports, magazines and newspapers, while Factiva database provides business information and news from local and global newspapers. Also, databases for such newspapers as the Financial Times, the Economist and the International Herald Tribune have been examined. And, electronic newspapers directly related to the EU affairs, such as, the European Voice and the New Europe. However, also this solution turned out to pose further limitations as it did not render as many results as was hoped for. These sources could not provide necessary information in terms of the details of interest groups’ lobbying activities and differences between the two groups. These sources could only provide information on the debate surrounding the proposed Aviation Directive, its speculated consequences and the course of political decision-making process.

4.3.2 Interviews Interviews are the most important sources of case study information, and they can help the researcher to overcome possible gaps due to the lack of information during the desk research. Especially for the purpose of this case study which is establishing the influence of interest groups, interviews are particularly important as lobbying activities do not tend to be publicly visible. In addition, an interview can be used to confirm information which could be found during the desk research process. There are several types of interviews that are possible when conducting a case study: open-ended, semi-structured, focused, structured or a survey. The initial intention of the author was to conduct semi-structured interviews which have a flexible and fluid structure with an interview guide, while the sequence of asked questions can be rather flexible. In contrast, structured interviews contain a structured sequence of questions which are asked in the same way from all interviewees, but this might impose the researcher’s framework and understanding. Semi-structured interviews intend to generate interviewees’ accounts of their own perspective, perception and understanding, this fact adds validity to this type of interview source and does not incorporate a possible bias of an interviewer (The SAGE Encyclopedia, 2012). This type of interview is not highly structured with only closed ended questions and it is suitable for tracing informal and informal lobbying activities, which could have led to influence in the case. In addition, the intention is to create a comfortable environment for an interviewee.

However, as there were certain limitations with securing interviews for this case study, the author opted for developing and sending out questionnaires instead. Therefore, interviews for the purpose of this study have not been conducted in a traditional interview setting, but through an e-mail using a questionnaire form. This turned out to be the most feasible way for several reasons. First of all, interest groups themselves, and other interviewees indicated having a busy workload and preferred an e-mail interview over scheduling a meeting. Also, two of the interviewees are located in Germany and United Kingdom, and scheduling an appointment with them was not possible due to time and resource limitations of this research.

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Second, using a questionnaire was also more reasonable due to time considerations, as it took more time than expected to get positive replies from the people contacted for an interview, and having an actual interview meeting was not possible anymore.

For the purpose of present case study two interest groups were chosen: Transport & Environment Federation (T & E) representing environmental interests, and European Regional Airlines Association (ERA) representing the aviation industry. More details on the choice of these groups and their description will be provided in Chapter 5 (See section 5.3.). Both of the groups were contacted for an interview and a positive reply was received from both. Interview requests were first sent to employees who according to association websites are working with the issues of the EU ETS and interest representation activities in general. If a contacted person was not able to help, he/she would usually recommend a colleague who would be more suited for answering the questions. Interviewees were those persons familiar with how an interest group participated in policy-making during the making of the Aviation Directive, and their subjective experiences are used for understanding the lobbying process.

In addition, a wide array of other organizations/institutions has been contacted in order to get a more objective view on lobbying activities of the two groups, such as: the Commission, MEPs, consultancies, think-tanks, NGOs etc. (See Appendix 2 for a detailed list). However, there were only few positive replies from the contacted people and this is a considerable limitation to the present research as more interviews would have been needed. Positive replies considering an interview also first came from CE Delft and the Corporate Europe Observatory (CEO), but at the end these interviews could not be realized, but would have been of a great value to this research. CE Delft is an independent research and consultation organization specialized in developing structural and innovation solution to environmental problems, and which also prepared a report for the Commission on the impact of including aviation in the EU ETS (CE Delft, 2005). CEO is a research and campaign group working to expose and challenge the privileged access and influence of corporations and their lobbying groups, and according to their press releases they were active in researching the case of interest representation in regard to the Aviation Directive.

At the end, only four interviews in total were possible for collecting the data. In addition to being able to interview two interest groups under examination (T & E and ERA), a representative from Aviation Environment Federation (AEF) and a representative from German Watch agreed to be interviewed. AEF is the principal UK non-profit environmental association concerned with the environmental effects of the aviation, and German Watch is a German independent development and environmental organization lobbying for global development by observing, analysing and collaborating with other organizations. However, these interviewees acknowledged from the beginning that they would not be necessary able to help to trace the whole lobbying process in regard to the two interest groups at stake.

A questionnaire has a set of carefully designed questions given in exactly same form to a group of people in order to collect data on a given topic. However, the questionnaire form sent out to the interviewees varied according to if it was intended for an interest group under examination, or for other groups with an objective view on these interest groups’ lobbying activities. Therefore, two different types of questionnaires have been developed by the author and used (See Appendix 3 & 4). This type of data collection through questionnaires has its advantages as it is less time consuming, and as there is not direct contact with an interviewee, it means that the issue of interviewer bias does not arise. However, there is also a considerable number of drawbacks with this method as questionnaires simply cannot capture the whole extent of a social phenomenon, as it is a much more complex than few variables in the questionnaire. Also, in order to create a good questionnaire it is necessary to understand the whole subject matter in its complexity (The SAGE Dictionary, 2012). In order to cope with

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this limitation, when designing the questionnaires the author had to be as fully aware as possible of the debates surrounding the case study, and also being aware of what sort of data is required for the purpose of conducting process-tracing combined with congruence analysis.

As process-tracing method is a crucial part of data analysis for this study, the below table (See Table 1) summarizes the sources for data collection for the purpose of process-tracing which has been chosen as the research method complementing the congruence analysis design. The following steps of process-tracing have been taken into account when collecting the necessary data: identification of interest groups; tracing preferences of interest groups; tracing influence attempts and access to decision-makers; the decision-making process; establishing to what extent interest groups’ preferences have been reflected in the final outcome; and finally, statements of interest groups in regard to the outcome. The gathered data in will be examined in Chapter 6.

Table 1 Data collection sources for process-tracing method

Steps of process-tracing Data sources1. Identification of interest groups Consultation documentation, press releases,

working groups documentation, official reports2. Preferences of interest groups Position papers, press releases, public statements,

reports, interviews, relevant web-sites, interviews3. Influence attempts and access to decision-makers Interviews, official documents, reports, press release,

working groups reports, databases, newspapers4. The decision-making process Press release, relevant web-sites, official statements,

 newspapers, databases5. Preferences reflected in the outcome Official documents of the EU, legislation and press

releases by the EU, interviews6. Statements of interest groups Interviews, press release, official statements, web-sites

Chapter 5: The case of bringing aviation in the EU Emissions Trading System (EU ETS)

This chapter first introduces EU climate change policy and the EU Emissions Trading System’s function in combating climate change. After this, the case under examination of bringing aviation in the EU ETS with the Directive 2008/101/EC is being described while reflecting on this specific case selection. Finally, the choice of the two interest groups that lobbied the chosen case is explained, and these groups will be shortly presented.

5.1 EU climate change policy and the EU ETS The chosen case study falls into the area of the EU’s environmental policy. Over the past years environmental protection, and especially combat of climate change has been one of the major topics of political discussion. When examining the amount of interests groups by policy area it has been shown that the second biggest policy area of interest to interest groups is

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environment, while the first one is enterprise (Hix & Hoyland, 2011: 164). As there are considerable gaps in the research on actual influence exerted by interest groups it would be interesting to look at widely lobbied area, while making it a unique research by choosing a Directive which has not been yet researched in relation to interest groups’ preferences, positions, lobbying activities, and consequently influence.

The EU has some of the world’s highest environmental standards which have been developed over the decades. Today, some of its main priorities are protecting endangered species and habitats and using natural resources more efficiently. Environmental policies encompass many issues such as air, chemicals, industries, waste, water etc. Climate action is one of the top priorities for the EU and it is aiming at cutting greenhouse gas emissions substantially while encouraging other nations to do that as well. At the same time the EU is developing strategies in order to adapt to the already occurring impacts of climate change (European Commission, 2012).

The EU Emissions Trading System (EU ETS) is a cornerstone for the policy of combating climate change and it is seen to be a key tool for reducing industrial greenhouse gas emissions in a cost-effective way by trading greenhouse gas emissions allowances. It works on the ‘cap and trade’ principle meaning that there is a limit on the total amount of certain greenhouse gases that are emitted by factories, power plans, and other installations. Within the cap companies receive emissions allowances which can be sold or bought from one another as needed. The limit of the total number of allowances ensures that that they have a value, and at the end of the year a company has to surrender enough allowances to cover its emissions or heavy fines will follow. If a company has reduced its emissions, it can spare allowances for the future or sell them and this trading flexibility ensures that emissions are cut where it costs least to do so. The number of allowances is supposed to fall over time so that emissions would also fall (European Commission, 2012).

The stakeholders in the field of climate policy are dominated by two types of interest groups: business and industry organizations, and environmental organizations. The first type of interest groups emphasizes competitiveness and is directing it lobbying efforts for reducing emissions in an economically cost-effective way. In addition, these groups also favour a global agreement comprising both developed and developing countries when it comes to the international climate change negotiations. In contrast, the environmental groups are stressing the importance of environmental policy being effective and sound, and arguing that the developed countries have to make the first step by reducing their emissions (Gullberg, 2008: 165).

5.2 The case - Directive 2008/101/EC as to include aviation activities in the EU ETSThe issue of aviation has moved on the political agenda of the EU, especially because expanding aviation sector is responsible for the rapidly rising emissions. In addition, industries have already been affected by the EU climate policy and it is has been hard to justify why aviation has not been also included. Aviation is the fastest growing source of greenhouse gas emissions and the most climate-intensive form of transport. Its emissions have more than doubled in the last twenty years. In 2008 aviation sector together with shipping accounted for a quarter of total transport emissions, and in addition, aviation has been received special treatment by being able to avoid fuel taxes and VAT (Angler & Kohler, 2009).

In order to mitigate the climate impact of aviation the EU has decided to impose a cap on CO2 emissions from all international flights that arrive at or depart from the EU airport. It was confirmed in 2008, and it became law in February 2009, that aviation would be included

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in the EU ETS from the start of 2012 with the Directive 2008/101/EC or the so-called Aviation Directive. The EU sees this measure as the most cost-efficient and environmentally effective option for controlling aviation emissions. However, this decision is of controversial character and it has caused international unease as it has been criticized by both, the aviation industry and various environmental groups.

The choice of this case is relevant as a growing body of scientific literature is showing that climate change is taking place and that is influenced by human activities, since the early 1990s this issue has been moving up the international and the European political agenda (EurActive, 2010). Another important reason for the choice of this case is the time frame as it is feasible to look at the decision-making process and lobbying activities which were taking place between 2005-2008, as it is still not that long time ago and it should be possible to trace people for an interview with knowledge on this this topic. In addition, this case is of controversial matter and there were clearly opposing interests and preferences from the aviation sector side and environmental interest side. Due to this fact, it is interesting to compare interest groups from both sides in order to see whose preferences got reflected in the final outcome and which side was more influential.

This case is also particularly appealing as the overall outcome with the adoption of the Aviation Directive might be considered as a victory for the environmental interest groups, as it is an important political step for mitigating climate change. Moreover, it might be considered against the widespread myth that as industry supported interest groups are important for the EU’s economic growth and employment, they have more potential to influence the legislation making. The time scope for the present case study is between 2005 and 2008 as this is when the lobbying activities of interest groups took place. The discussion and consultation in the Commission started in 2005, the proposal drafted by the Commission was on the table in 2006, and the directive was amended in 2008.

The final version of the Aviation Directive imposes a cap on air carriers and they have to keep emitted greenhouse emissions under certain limits. In 2012 the cap is set at 97 per cent of average emissions during 2004-2006 and from 2013 this will be reduced to 95 per cent. Aviation will have to pay for permits covering 15 per cent of their allowances to emit carbon dioxide CO2, and the remaining 85 per cent will be allocated to free. This means that airlines will have to cut their CO2 emissions by 3 per cent in 2012, and by 5 per cent from 2013 onwards. Air carriers expressed criticism about this directive already at the legislation proposal stage and also later during the co-decision procedure stage, as they were concerned that it would lead to negative impact on the aviation industry’s competitiveness. In fact, they argued that it will cause more financial pressure on the aviation industry, higher bills for customers, and that there are not any proven benefits in the scheme for the benefit of environment ether (EuObserver, 8 July 2008; New Europe, 5 January 2007).

The essence of this case of bringing aviation in the EU ETS can be summarizes as being about a trade-off between combating climate change and economic growth of the EU. It was opposed by the aviation industry which stated that it would put EU aircraft operators at a competitive disadvantage compared to non EU-carriers, and it was also argued that the proposal to bring aviation in the scheme underestimates the wide-ranging burdensome cost effect for the aviation industry (EU Observer, 12 June 2007). The environmental groups, on the other hand, welcomed the proposal to bring aviation in the scheme, but warned on its weakness as according to them it was lacking important details. They criticized it for being too weak as it would only lead to emission reduction of 3 per cent which is less than one year’s growth of the aviation sector’s emissions. Moreover, they pointed out that the aviation industry already enjoys a fuel tax exemption and the lack of VAT tickets, and that inclusion in the scheme might in fact only benefit the aviation sector further (EurActive, 8 March 2011).

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In addition, they were also concerned that the scheme would actually lead to windfall profits for the aviation sector itself and not reduction of the emissions.

5.3 Interest groups involvedBased on the preliminary review of the press releases, documents, and position papers four interest groups have been identified as being relevant to the case of lobbying the Aviation Directive. They were first chosen as they were most often mentioned in the documents, press releases and reports and it could be established that they have been particularly active in lobbying the directive under examination. The initial plan was to examine all of the four of these groups, two of them representing the aviation industry interests: Association of European Airlines (AEA) and European Regions Airline Association (ERA), while the other two representing the environmental interests: Transport and Environment Federation (T & E) and Climate Action Network Europe (CAN-Europe).

However, after further investigation it became apparent that the aviation industry groups had the same preferences in regard to the case, while the environmental groups had the same ones as well. For this reason, only one group from each side has been chosen, and in particular, European Regions Airlines Association (ERA) and Transport and Environment Federation (T & E). Both of these interest groups agreed to be interviewed while with the other two an interview was not possible. This was another important factor for choosing these two particular groups at for the purpose of an in-depth case study interviews are a crucial source. In addition, what contributed to their choice is that these groups represent contradicting preferences on the issue of bringing aviation in the trading scheme, which makes a comparison between their influence successes more appealing. This chapter will be completed by giving a short description of the two selected interest groups.

European Regions Airline Association (ERA) is a non-profit organization representing some 200 companies involved in European air transport, including airlines, airframe and engine manufacturers, airport, suppliers and service providers across Europe. It promotes the interests of intra-European airlines by lobbying the European regulatory bodies on relevant policy matters while promoting the social and economic importance of air transport and its environmental commitments. In its activities, ERA holds networking events and provides advise and guidance on all air transport regulatory matters to its members (ERA, 2012a).

Transport and Environment Federation (T & E) is an environmental organization campaigning for sustainable and environmentally sound transport at the EU level. It represents and is supported by around fifty member organizations across Europe. Their aim is to see the EU as being a global leader in reducing the environmental impacts of transport. Furthermore, T & E believes that Europe should have the lowest levels of greenhouse gas emissions and air and noise pollution from transport; the cleanest vehicles, planes and ships; transport policies that encourage efficiency; and pricing that makes polluters and not society as a whole to pay for pollution. When it comes to the aviation, T& E is campaigning for global targets of reduction in emissions within the aviation sector, and for removing exemptions and fuel taxation and VAT for airlines in the EU (T & E, 2012a).

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Chapter 6: Process-tracing applied to the case

This chapter applies the chosen method of process-tracing in various steps to the chosen case of the Aviation Directive, and particularly in regard to how interest groups lobbied this case. First, preferences of the two interest groups at stake will be presented and the final outcome will be described which will allow to make a comparison of how many preferences each interest group got reflected in the final piece of legislation. Then, the course of political decision-making process in regard to the case will be shortly discussed. After this, lobbying activities of interest groups will be traced. To conclude, process-tracing will be finalized with complimentary insights into statements of the interest groups after the legislation was adopted. In regard to the preferences reflected in the outcome and the extent of lobbying activities, it will be possible to indicate which one of the two groups was more influential. This will allow to verify the correctness of the empirically tested predictions in congruence analysis proper in Chapter 7 by either confirming, disconfirming or partially confirming theoretically derived predictions. In this way, the research design of congruence analysis and the method of process-tracing are being combined.

6.1 Preferences of interest groups in regard to the caseThe following section will first present the preferences of interest group Transport & Environment Federation (T & E) which also represent the preferences of other environmental NGOs that were active in lobbying the case. After that, the preferences of the aviation industry represented by the European Regional Association (ERA) will be clarified which also represent the aviation industry preferences in general.

6.1.1 The preferences of Transport & Environment Federation (T & E)In general, various NGOs supported a separate dedicated ETS for the aviation so that airlines could not buy allowances from the other industrial sectors, and this in their opinion would be a more effective solution for tackling climate change. However, in case the aviation would be incorporated in the EU ETS itself, the NGOs pointed out that several details would be crucial for efficiency of the scheme (CAN-Europe & T & E, October 2006). T & E’s preferences were: to include the aviation from 2010 rather than postponing it until 2012 as proposed by the aviation sector; to cover the EU and international flights rather than only incorporating the EU flights; to set a cap on the aviation emissions which should be much lower than 95 per cent of the average 2004-2006 emissions as proposed by the Commission, in fact, as low as 50 per cent was suggested. In addition, there was a preference for much higher levels of auctioning than 15 per cent in order to prevent windfall profits for the aviation sector. Ideally, full auctioning was preferred as it was argued that only then airlines would fully pay for their emissions. And, with setting level of auctioning at 15 per cent it would mean that 85 per cent of allowances would be given for them for free. Moreover, T & E was in favor of fully including non-CO2 effects such as mono-nitrogen oxides (NOx) in the scheme, as it was argued that otherwise every tonne of carbon dioxide (CO2) that airlines would need to buy would actually lead to a net increase of global warming rather than its decrease.

The baseline for capping the aviation sector’s emissions proposed by the Commission was 2004-2006 with which T & E fully agreed. When it comes to the exemptions of some aircrafts T & E agreed with the Commission’s proposal that all flights above 5,700 kg of Maximum Take-Off Weight (MTOW) should be included. According to T & E with the higher MTOW most business jets would be outside the scheme which would lead to market distortions. As stated by a representative from T & E they did not have a big problem with other proposed exemptions (e.g. for those airlines only operating few flights) as they only

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represent a small percentage of emissions (Interview 1, T & E, 2012). The final preference aspect has to do with fuel taxation and T & E pointed out that complementary measures are needed on top of the emissions trading system to make it efficient, such as: a kerosene tax on fuel for domestic flights, ending of VAT-exemption and en route NOx emissions charges (T & E et al., April 2008).

6.1.2 The preferences of European Regional Airlines Association (ERA)ERA and the aviation industry sector interest groups agreed with the Commission’s perspective that the application of the ETS would be more cost-effective and environmentally friendly, than additional taxes and charges directed at the aviation sector in achieving the EU’s environmental objectives. According to the ERA the inclusion of aviation is acceptable as long as it does not distort international competition and does not pose unreasonable cost burdens for the aviation sector (ERA, 13 October 2006). ERA’s preferences were to have the starting date as from 2012 and to cover both the EU and international flights instead of already starting in 2010 and only including the EU flights. A cap of 110 per cent was preferred which would according to the group better accommodate the increased passenger demand (ERA, 7 July 2007). In 2008 ERA also came to accept the cap of 100 per cent proposed by the Council, while at that time of the decision-making process the MEPs were proposing a cap of 50 per cent (ERA, 19 May 2008).

According to ERA baseline should have been based on the average emissions of 2007-2009 instead of the proposed 2004-2006. According to the group this reference period provides a more realistic and a recent basis while guaranteeing a harmonized and verifiable set of data (ERA, 15 October 2007). ERA rejected the principle of full auctioning which would mean that the aviation sector would have to buy 100 per cent of allowances. The group stated that the level of auctioning should remain modest, as the original purpose of the ETS is to cover the administrative costs of the ETS, and to insure that it functions as a market mechanism rather than as a fiscal instrument.

ERA was opposed to all exemptions as according to the group these establish a differentiation in treatment and could lead to distortions of competition between different operators. ERA also stated that the exemption related to the aircraft size and to the number of flights should be replaced by a more generic exemption based on minimum volume emissions’ system (ERA, 11 November 2008). Furthermore, ERA preferred that the ETS should only apply to CO2 and not to any other non-CO2 effects, such as NOx. According to the group NOx is not a greenhouse gas and there is no scientific evidence that it contributes to climate change. ERA also rejected any fuel taxation on top of the ETS, and it stated that allowances should be allocated free of charge, instead of selling 15 per cent of them as proposed, to the aviation operators since they are the entity which is responsible for the production of emissions. Also, in the group’s opinion allowances should not be allocated at a member state level because according to them this would result in unacceptable distortion of competition.

6.2 The final outcome Directive 2008/101/ECThe Aviation Directive or Directive 2008/101/EC of the EP and the Council from 19 November 2008 amends Directive 2003/87/EC which establishes a scheme for greenhouse gas emission allowances and included installations operating in the energy sector, iron and steel production and processing, the mineral, paper and board industry. Directive 2008/101/EC brings aviation activities in the scheme for greenhouse gas emission allowances.

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Its objective is to reduce climate change impact attributable to aviation, while improving environmental effectiveness but also avoiding distortions in competition.

According to this directive aviation activities were due to be included in the EU ETS from 1 January 2012. All airlines with operations to, from and within the EU fall under the scope of the directive, also including non-EU airlines. When it comes to quantity of allowances all aircraft operators (including international) have a cap on their emissions which is 97 per cent of the average historical emissions from 2004-2006 for the period from 1 January 2012 to 31 December 2012. For the period beginning on 1 January 2013 and for each subsequent period the total quantity of allowances to be allocated to aircraft operators will be equivalent to 95 per cent of the historical aviation emissions multiplied by the number of years in the period.

The allocation of allowances for aviation will take place through auctioning. The allocation of allowances is 85 per cent free of charge for the aviation sector, and 15 per cent for auctioning and to be bought by the air operators from 1 January 2012. Allocation is based on tonne-kilometres, and is based on 2004-2006 average of their emissions. From 2013 to 2020 free allowances will reduce to 82 per cent and the same amount of 15 per cent will be auctioned. In addition, 3 per cent will be set aside to create a reserve of allowances for new entrants and fast growing airlines. Each year an operator has to surrender a number of allowances equal to their actual emissions. Member States should determine the use to be made of revenues generated from the auctioning. These revenues should be used to tackle climate change in the EU and in third countries as well as for the research in the field of low-emissions transport. Moreover, the member states must report about the use of revenues to the Commission (the EP & the Council, 2008).

There is a special reserve for certain aircraft operators as the directive excludes flights related to search and rescue, fire-fighting, humanitarian aid, emergency medical services as well as flights for public service obligations (police, customs and military). Also, operators with very low traffic levels will be excluded from the scheme in order to avoid disproportional administrative costs. This provision is aimed at inter alia operators from developing countries. Excluded aircraft operators are those that fly fewer than 243 flights for three consecutive, four months periods, or emit less than 10,000 tonnes of carbon dioxide a year, or operate aircraft weighting less than 5,700kg (The European Parliament, 2012).

6.3 Comparison of preferences versus the final outcomeThe below tables (See Table 2 & 3) allow a comprehensive comparison of nine issues from interest group preferences versus nine issues included in the final outcome. Table 2 shows that when it comes to Transport & Environment Federation, this group got two out of its nine preferences reflected in the final outcome: EU and international flights were both included in the scheme, and a baseline for setting a cap was set to 2004-2006 (See Table 2: issues 2 and 4). With other seven issues in their preferences they were not successful. For example, their preference for a cap was 50 per cent (meaning that the aviation sector would be expected to cut its emissions by 50 per cent), while the outcome set it to 97 per cent. Furthermore T & E was in favor of full auctioning of allowances, while the final outcome set auctioning at only 10 per cent. In addition, T & E argued for an earlier starting date than 2012, exemptions to be allowed according to size instead of to operators with low traffic levels, the scheme also to cover non-CO2 effects of emissions, additional fuel taxation for the aircrafts on top of the scheme and emissions being sold to the aviation instead of given to them for free. However, none of these preferences materialized and are not reflected in the outcome.

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Table 2 Comparison of Transport & Environment Federation preferences versus the final outcome

Interest group Preferences Outcome: Directive 2008/101/EC

T & E(Transport and Environment Federation)

1. Starting date 2010 1. Starting date 20122. Covering EU and international flights 2. Covering EU and international flights3. Setting a cap on emissions should be much lower than 95 % , preferably at 50 %

3. Cap at 97 % of historical emissions till the end of 2012, from 2013 onwards allowances reduced to 95 %

4. Baseline for a cap from 2004-2006 4. Baseline for a cap from 2004-20065. Level of auctioning should be higher than 15 % or gradually increased, ideally full auctioning = 100%

5. Level of auctioning 10 % (from 1 January 2013 15 % of allowances shall be auctioned)

6. Exemptions allowed according to size 6. Exemption to operators with very low traffic levels on routes to, from and within the EU

7. Also non- CO2 effects e.g. NOx should be covered 7. Non- CO2 effects not included8. Fuel taxation should also be included 8. No fuel taxation9. Emissions sold to the aviation sector and not for free 9. Raised revenues retained and spent by the Member

States (85 % for given for free to airlines)

When it comes to ERA’s preferences reflected in the final outcome, this interest group got six out of its nine preferences reflected in the outcome (See Table 3: issues 1, 2, 3, 5, 7, and 8). Its preference was to have a starting date from 2012 and to include both EU and international flights which materialized in the outcome. ERA’s original preference for a cap was 110 per cent, but later 100 per cent was also accepted. The final directive set a cap at 97 per cent which is relatively close to ERA’s preference, therefore it be claimed the group got this preference reflected in the outcome. ERA objected to full auctioning of allowances and was in favour of a modest auctioning level. The final outcome sets 10 per cent of allowances for auctioning, which can be considered as a modest level and reflecting the preference of ERA. In addition, other types of emissions were not included in the legislation and there was not extra burden in terms of fuel taxation, which also reflects the preferences of ERA. Three of its preferences did not materialize in the final legislation: later baseline for a cap which would be 2007-2009 instead of 2004-2006; exemptions based on a minimum volume of emissions instead of on being on very low traffic levels; and allocation of allowances free of charge to the aviation sector instead of being allocated to the Member States.

Table 3 Comparison of European Regional Airlines Association preferences versus the final outcome

Interest group Preferences Outcome: Directive 2008/101/EC

ERA(European

Regional Airlines Association)

1. Starting date 2012 1. Starting date 20122. Covering EU and international flights 2. Covering EU and international flights3. Cap of 110 % - later 100 % also accepted 3. Cap at 97 % of historical emissions till the end of

2012, from 2013 onwards allowances reduced to 95 %

4. Baseline for a cap from 2007-2009 emissions 4. Baseline for a cap from 2004-2006 emissions5. Auctioning should be based on the average of all the EU member state auctioning levels (modest level) objection to full auctioning

5. Level of auctioning 10% (from 1 January 2013 15% of allowances shall be auctioned)

6. No exemption related to aircraft size - instead a generic exemption based on a minimum volume of emissions

6. Exemption to operators with very low traffic levels on routes to, from and within the EU

7. Other emissions should not be included 7. Non- CO2 effects not included8. No fuel taxation = extra burdens 8. No fuel taxation9. Allowances should be allocated free of charge to the aviation sector and not member states

9. Raised revenues retained and spent by the Member States (85 % given for free to airlines)

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As nine issues are taken into account in the comparison, the two groups can be ranked

on a scale from one to nine. Based on the comparison it can be seen that European Regional Airlines Association (ERA) got their preferences closer to the final outcome as they have six of their nine preferences reflected in the directive (See Table 4: issues 1, 2, 3, 5, 7 and 8). Transport and Environment (T & E) is much less influential as it only got two of its nine preferences reflected in the final outcome (See Table 4: issues 2 and 4). Table 4 shows which issues both interest groups ‘scored’ or did not in the final outcome. According to the comparison of preferences ERA which got six of its preferences reflected in the final outcome was more influential in the case, than T & E which only got two of its preferences reflected.

Table 4 Number of issues reflected in the final outcome

Issue T & E ERA1. Starting date x2. Scope x x3. Cap x4. Baseline x5. Level of auctioning x6. Exemptions7. Non- CO2 effects x8. Extra requirements: fuel taxation x9. Retaining revenuesNumber of issues reflected in the outcome 2 6

6.4 The course of political decision-making processThis sub-section will shortly trace down how different aspects of the Aviation Directive changed during the policy-making process. Table 5 shows the overall time line of the decision-making process, but the description of this sub-section will only focus on the course of the political decision-making in the Commission’s legislative proposal in 2006, the Council’s Common Position in April 2008, the Parliament’s 2nd reading in in June 2008, and on the compromise agreement between the Council, the EP and the Commission in June 2008. In addition, not all of the nine issues relevant for the directive described in the previous sub-section will be taken into account, the focus will be on the four major and controversial issues: the starting date of including aviation; the emissions cap; application of multiplier meaning if non-CO2 effects should be included as well; and the percentage of auctioning of permits.

The Commission’s legislative proposal in 20 December 2006 proposed to include intra-EU flights in to the ETS scheme starting from 2011, and consequently, all flights including international ones starting from 2012. It was proposed that for the first period in 2012 the cap should be set at 100 per cent of 2004-2006 average emissions, while in subsequent periods from 2013 the cap should not be changed. When it comes to permit allocation it was proposed that in the first period in 2012 aviation should have 3 per cent of auctioning, while starting from 2013 auctioning should start at 20 per cent and go up to 100 per cent in 2020. Emissions of other gases should be addressed by the end of 2008 (CEO, 2008). With the EP’s first reading the on November 2007 the proposal of 50 per cent auctioning became 25 per cent instead, and the starting date was delayed to 2011. Moreover, the MEPs backed the ENVI Committee’s proposal without its ‘more extreme amendments’ voted by the Committee which would have been 50 per cent auctioning of permits to pollute,

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a two-times multiplier applied to the purchase of allowances in order to take into account non-CO2 emissions, and a starting date for all flights in 2010 (Oxford Analytica Daily Brief Service, 16 November 2007). Table 5 summarizes the decision-making process between 2005 and 2008, and also presents the date the Aviation Directive entered into force, target date for aviation to start trading CO2, and the date revised EU ETS enters into force.

Table 5 Time-line of the decision-making process in including aviation in the EU ETS

2005 March - May Commission's public consultationSeptember Commission's communication

2006 April -May Parliament's ENVI Committee issuing and adopting the Lucas reportDecember Commission's legislative proposal and impact assessment

2007 June - October Parliament's ENVI Committee issuing and adopting the Liese reportNovember Parliament's 1st reading backing up the Liese report

2008 December Council reaches political agreement on a common positionApril Council officially adopting its common positionMay Parliament's ENVI Committee adopts the Liese report, 2nd readingJune Parliament back the Liese report, 2nd reading

Trialogue meetings and deal between Parliament, Council and CommissionJuly Parliament's 2nd reading vote backs the deal, not the Liese reportOctober Council's final adoption of the directive

2009 February Directive entering into force2012 January Target date for aviation sector to start trading CO22013 January Revised EU ETS including aviation due to come into force

(Source: the EP Legislative Observatory, 2012; CEO, 2008)

In the Council’s Common Position in April 2008 the starting date was proposed as from 2012. The Commission’s proposal for a cap of 100 per cent in the first period from 2012 was accepted, but for the subsequent periods cap should be revised in 2015 as part of the general review of the aviation directive. Auctioning of permits should be 10 per cent starting from 2012, and later on the percentage might be increased as a part of the general review. In regard to a multiplier factor, the opinion was same as in the Commissions’ proposal as to address other emission gases in addition to CO2 which are believed to contribute to climate change by the end of 2008. In the Parliament’s 2nd reading in June 2008 the starting date for all aircrafts was voted for 2011 instead of the Commission’s proposed 2012, the cap for the first period in 2012 to be set at 90 per cent of 2004-2006 average instead of the Commission’s 100 per cent of 2004-2006 average, and later on it should be revised in a same manner as in other sectors. Auctioning of permits was set at 25 per cent in the first period rather than 3 per cent proposed by the Commission, and in the subsequent periods it should be increased according to the maximum level of auctioning in other sectors. In addition, it was voted that a multiplier for other gas emissions should be applied to every tonne of CO2 emitted, and previously in the Commission’s proposal it was stated that other gases should be addressed by the end of 2008 (CEO, 2008; EP Legislative Observatory, 2012).

Before the trialogue meetings, which take place between the EP, the Council and the Commission in case if an agreement cannot be reached, the MEPs voted in a plenary for an earlier starting date which would be 2011, a more rigorous cap on emissions of 90 per cent, full auctioning of allowances instead of 25 per cent, a multiplier to take into account considerable non-CO2 impacts on climate instead of not paying attention to other emission gases, and even a separated closed ETS for aviation so that airlines would not be able to buy allowances from other industrial sectors. However, none of these measures were reflected in

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the final outcome (CEO Report, 2008). An agreement between the Council, the Commission and the EP and a compromise deal took place in June 2008 and it set the starting date for including aviation from 2012, a cap of 97 per cent of 2004-2006 average emissions from 2012 onwards, and for subsequent periods at 95 per cent and that could be further modified as a part of a general review. Auctioning of permits was set at 15 per cent, but from 2013 it could be increased as a part of a general review. In addition, it was decided that no multiplier will be applied to the purchase of allowances (Oxford Analytica Daily Brief Service, 16 October 2007).

6.5 Tracing the lobbying processAnother important step of process-tracing is to trace interest groups’ lobbying activities. Dur (2008b:1223) states that there are different strategies that interest groups can make use of, such as: access, selection, voice and structural coercion. As he points out it is likely that groups use multiple pathways to achieve their objectives, and the analysis of only one may lead to an underestimation of their overall impact. For the purpose of this research only the pathway of access will be considered, and for this reason of only focusing on one type of strategy claims about the lack of influence or influence success should be made more cautiously. As described by Dur ‘access’ is the direct expression of demands by interest groups to decision-makers and it can take form in e.g. informal communication, testifying before expert commissions, or public hearings. However, it is important to keep in mind that access does not necessarily translate into influence even if a group has a ‘seat on the table’ (Ibid.). In order to trace the lobbying activities of both interest groups it will be investigated how they approached and lobbied the European Commission, the European Parliament, the Council and what other general lobbying techniques were used.

6.5.1 Lobbying the Commission The Commission is a crucial venue for lobbying activities due to its central role in the EU legislative process, as it is an agenda-setter and has a formal right to initiate legislation by drafting legislative proposals. Therefore, it is crucial to start tracing the lobbying process by looking at how both interest groups lobbied this venue. The Commission’s stakeholder consultation on inclusion of aviation lasted from March to May 2005. This can be characterized as ‘policy preparation stage’ when the Commission gathers information and feedback on its proposal. There were two different questionnaires, one for individuals was aimed at the general public, and the one for organizations contained more technical and detailed questions. A total amount of 198 organizations participated in the consultation and NGOs made the up the largest fraction of respondents, those primarily active in the field of environmental protection. There was a general agreement among organizations to include the air transport sector in efforts to mitigate climate change. While some organizations highlighted the urgency of taking action, airport, manufacturers and airports preferred emissions trading to any other economic instruments as long as the system is open to sectors and limited to CO2 emissions only. NGOs doubted that it would be rather difficult to make the scheme effective enough and some demanded ambitious targets.

Both of the interest groups at stake participated in the consultation. In the ERA’ opinion the consultation process was not exactly accurate as the Commission was relying on Ernst & Young Report on possible consequences of including aviation. The ERA argues that during the impact assessment phase aviation industry was ignored and the Commission was over-relying on this report, and once the proposal was adopted, ERA was able to be involved more frequently and to point its opinion on the original legislative text (Interview 2, ERA, 2012). Unfortunately, desk research could not show which of the two groups was more active

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during the consultation process, but during the interviews with both groups it could be established that both of the groups were active in participation and attributed a lot of importance to the consultation in order to get their preferences heard (Interview 1 & 2, T & E & ERA, 2012).

The Aviation Working Group (AWG) meetings took place four times from November 2005 to April 2006. AWG was set by the Commission in order to explore how to design the inclusion of the aviation into the ETS. Comments in the AWG reports are not attributed to individual groups, but the list of participants shows that both interest groups participated in the working group meetings each time. However, as pointed by Corporate Europe Observatory in practical terms the AWG was unbalanced with only two environmental NGOs, fifteen industry federations and no consumer organizations (CEO, 2008: 5).

ERA was lobbying the Commission by providing technical and expert information on the consequences of the inclusion of aviation, through impact assessment study commissioned with other airline association; expert knowledge about the methodology how to calculate the historical emissions; and also papers on the economic and social consequences of the scheme. Also, it had formal and informal meetings, mainly informal such as stakeholder conferences, public hearings and one-to-one meetings and the frequency of these meetings between 2005 and 2008 was on a monthly basis (Interview 2, ERA, 2012). T & E was also providing technical information to the Commission and had both informal and formal meetings with the institution. There were personal meetings with officials and the group was attending formal stakeholder meetings and answering formal consultations. In the months before the proposal the meetings were every 1-2 weeks and during the co-decision with the EP at least several meetings a week took place (Interviews 1 & 4, T & E & German Watch, 2012).

6.5.2 Lobbying the European Parliament There was a formal hearing on ‘Climate Change and Aviation’ organized in the EP by Caroline Lucas (Greens, MEP, UK), the Rapporteur on the Commission Communication on Aviation and Climate Change on 8th March 2006. Representatives of the airline associations and environmental organization took part in this meeting and both of the interest groups were present at this hearing. In addition, both of the groups lobbied the Parliament actively, by having contacts and face-to-face meetings with ENVI Committee, rapporteurs Caroline Lucas and Pieter Liese, shadow rapporteurs, and they were also active before the 1st and 2nd readings of the EP. They attended the hearings of the EP and published position papers (Interviews 1 & 2, T & E & ERA, 2012). Unfortunately, more details in regard to lobbying the EP could not be traced due to the fact that none of the MEPs contacted for an interview could give consent for an interview, which would have been crucial in establishing how the MEPs perceived the lobbying activities of both groups.

6.5.3 Lobbying the Council and additional lobbyingERA had contacts and meetings with the Council, particularly attention was paid to the Transport Attaches within the Member States’ Permanent Representations to the EU in Brussels (Interview 2, ERA, 2012). T & E was also targeting the Council through contacts and meetings, and it also published a position paper in a form of a letter directed to the EU Environment Ministers and Permanent Representatives in alliance with other NGOs (T & E, 20 June 2008) underlying the importance of urgently reaching an agreement with the EP on the inclusion of aviation into the EU ETS.

In addition, both groups were constantly publishing position papers and press releases, publication were mainly directed at the EU institutions, but also at the press so that the issue would reach the general public. However, in data collection it becomes clear that ERA had

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more position papers published (a list of published position papers for both groups can be found in Annex 5). Moreover, ERA hired a consultant by co-financing a study from a consultancy in order to re-address the impact assessment proposed by the Commission. These types of activities cannot be traced to T & E. Both interest groups were lobbying at a national level through their member organizations throughout Europe.

Both interest groups formed alliances with other interest groups, T & E with organizations representing environmental causes, and ERA with organizations representing the aviation industry in order to stand stronger in the decision-making process. Both of the groups find it being in an alliance as an important factor in their lobbying efforts (Interviews 1 & 2, T & E, ERA, 2012). T & E is in a permanent alliance with its 50 members that it represents, and in the case of inclusion of aviation to the scheme it also built alliances with other environmental NGOs. ERA is in a permanent alliance with its 260 members that it represents and it also formed alliances with other aviation industry associations. In addition, it is also in alliance and represented by the International Air Transport Association (IATA) which is an international trade body representing some 240 major airlines. This organization was heavily involved in the lobbying the case (CEO, 2008). Hence, it can claimed that even though both interest groups formed strong alliances to stand stronger in the decision-making process, ERA belonged to the stronger alliance as it is not only represents 173 members (while T & E only represents 50 members), but it is also strongly supported by IATA which represents 240 airlines and was strongly involved in lobbying the case and supporting ERA.

6.6 Comparison of the scope of activities In this section the activities of two interest groups will be compared in order to establish which of the groups was more active in their lobbying efforts. The table below (see Table 6) summarizes the lobbying activities of both groups, as it can be seen they are rather equal in their lobbying efforts and they were both targeting all of the three EU institutions, and also using extra lobbying techniques. However, as described above ERA was publishing more position papers, it hired a consultant and co-financed an assessment report, and it can also be argued that it had a stronger alliance formed compared to T & E. Due to these reasons it can be concluded that ERA can be ranked higher than T & E in its lobbying activities, and it was more influential in the case. This is also confirmed by the first step of process-tracing when preferences of interest groups were compared with the final outcome. It was shown that ERA got six of its preferences reflected in the final legislation, while T & E only got two of them reflected. Thus, to conclude it can be said that there are three aspects that distinguish ERA and make it more significant in its lobbying efforts compared to T & E, and that make it more influential in the case of bringing aviation in the EU ETS. These aspects are: the wider scope of published position papers, hiring a consultant to prepare an assessment report and a considerably stronger alliance with other interest group in comparison to the alliance of which T & E was part of.

Table 6 Summarizing and comparing the lobbying activities

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Activity T & E ERAthe Commissionconsultation x xworking groups x xDG Environment x xThe European ParliamentENVI Committee x xrapporteur Lucas x xrapporteur Liese x x1st reading x x2nd reading x xGeneral lobbyinghearing participation x xformal requests x xformal meetings x xinformal meetings x xhiring a consultant xposition papers x xxalliances x xxlobbying at national level x xThe Councillobbying national representatives x x

6.7 Statements concerning the final outcome The final step of the process-tracing will present interest groups’ statements of (dis) satisfaction after the final legislation has been passed. When it comes to T & E their statement is that one aspect of legislation which was covering in and outbound flights and which was one of their preferences, and which made it to the final piece of legislation, was more than the group expected in terms of influence attainment. However, they would have hoped that the cap would have been set to be progressively lowered 1 or 2 per cent each year as in other industry sectors. Also, the group was pressing for including non-CO2 effects emissions in the directive, such as NOx. According to T & E this was promised to the group but it never materialized in the outcome. Nonetheless, T & E strongly supports the legislation and continues to defend it from all attacks, even though they point out that it is not strong enough in its details, which undermines its efficiency (Interview 1, T & E, 2012).

ERA is satisfied with the fact that the EU ETS is an open trading scheme instead of restricting it only to selling allowances within the aviation sector, however, it is dissatisfied with the fact that the final outcome was the EU regional scheme instead of a global solution through the International Civil Aviation Organization (ICAO), which is a specialized agency of the United Nations promoting the development of international civil aviation throughout the world. ERA is generally supportive of market-based of measures to improve the environmental score of aviation, as long as these measures do not create distortions in competition and do not impose additional taxes and burdens on the airlines carriers. The concept of a cap and trade emissions was in principle welcomed by ERA as a fair system, but unfortunately, according the group the final directive is poorly designed and based on the Commission’s inaccurate impact assessment. As they put it, ‘’it is driven by often unfounded arguments, leading to unjustified and additional costs to the European air operators’’ (Interview 2, ERA, 2012).

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Among other things, ERA is dissatisfied with such issues as: the cap values and

baseline reference years for emissions cap calculations; with the fact that there is no formal obligation to invest the revenues from emissions trading on Research and Development in order to improve the aviation’s effect on environment, such as aircraft performance and alternative fuels; and also, the complexity and burdensome procedure for monitoring, reporting and verification (Interview 2, ERA, 2012). In addition, ERA points out that a unilateral, regional EU scheme is now causing international disputes and opposition by the non-EU countries, and their threatening measures could hurt the European airlines and manufacturers.

Based on the statements presented above it can be concluded that both interest groups accept the EU ETS in principle and they welcome it as an appropriate solution for mitigating climate change. However, both groups also express their dissatisfaction with the final outcome as many of their preferences were not reflected in the outcome and the legislation remains weak in their opinion. While T & E stresses the fact that crucial details are not incorporated in the final legislation, and that consequently, decrease of the aviation emissions is not significant, ERA points out that the directive has a negative effect on the EU’s the aviation sector’s competitiveness.

Chapter 7: Congruence analysis proper – data analysis

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This chapter presents a systematic comparison of deducted predictions stemming from three different theories with the collected empirical data. The same empirical information is compared with predictions from all the three theories in order to establish whether the observations are in line or in contradiction with the predictions. The theories under examination are: access goods theory, structural characteristics theory and issue characteristics theory. After testing each of the predictions for each theory it is concluded whether a particular prediction has been confirmed, disconfirmed or possibly partially confirmed. In order to verify the results for each prediction, the findings of the previous chapter on process-tracing are used for re-checking congruence analysis proper. This is possible as the analysis in the previous chapter already pinpointed which one of the two interest groups is supposed to be more influential. At the end of this chapter, findings of the congruence analysis proper in regard to the three theories and theoretically derived predictions are summarized.

7.1 Access goods theoryAccording to this theory there is an exchange relationship between decision-makers and interest groups, while the most important access good for this exchange is information. The opportunity structure to gain access and to exert influence is determined by informational needs of a given EU institution. Consequently, a group will first target an institution for which it has the type of information that it needs as different kinds of groups can provide different kinds of information. A business group is likely to be influential if it provides expert knowledge to the Commission, while a European association is likely to be influential if it provides information about the European encompassing interest to the EP. For the purpose of this research only European associations are examined, therefore the most important channel for them should be the EP, and the second important channel should be the Commission.

7.1.1 Prediction 1: providing information to the right institutionAccording to Transport & Environment it is important to target all the three EU institutions (the Commission, the EP and the Council). Information that T & E provided to the Commission was of technical character, while the information provided to the EP was why the legislation was needed, and what kind of impact it would have on the climate and emissions level in Europe, and also how it would affect the EU as a whole (Interview 1, T & E, 2012). ERA was also providing technical information to the Commission which was about the consequences of the proposed inclusion of aviation in to the EU ETS in general, and specifically the economic and social consequences. In addition, ERA provided expert knowledge for the revision of the methodology and formula for calculating the historical aviation emissions. ERA was continuously informing the EP on the estimated costs that the ETS scheme would impose in terms of job reductions, lower consumer surplus, European airlines decreased competitiveness, and also potential retaliatory measures by non EU-countries (Interview 2, ERA, 2012). Thus, it provided information on the European encompassing interest.

According to both interest groups it is important to provide information to all the EU institutions, and it depends on the specific phase of the legislative process when these institutions are being targeted with information. It is can be empirically seen that both groups were attaching equal importance to the Commission by providing technical information to it, and to the EP by supplying it with information how the inclusion in the scheme would affect the European encompassing interests. Based on the empirical observations it can be concluded that both interest groups were providing the essential access good information to the right institution. Therefore, it would be expected that both interest groups should be influential in

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the case. However, based on the comparison of interest groups’ preferences with the final legislative outcome and the comparison between the extent of their lobbying activities in Chapter 6, it has been shown that ERA had more influence in the case. For this reason, it can be claimed that the prediction that providing information to the right institution would lead to more influence is not in line with the empirical observations. Therefore, this prediction is disconfirmed.

7.1.2 Prediction 2: scope of information inflow and meetings T & E had both, informal and formal meetings with all the three institutions in which information was provided which included personal meetings with officials and attending formal stakeholder meetings and answering public consultations. Before the proposal most of the meetings were with the Commission, and after the proposal with the Parliament, so both were targeted with provision of information. In the months up to the proposal the frequency of the meetings was once or twice a week, and during the co-decision with the EP there were several, three on average (Interviews 1 & 4, T & E & German Watch, 2012). Information inflow targeted at the EU institutions is also visible in T & E’s position papers, reports and participation in the consultation process. ERA also had formal and informal meetings with the EU institutions where information was provided. These meetings were mainly formal as in stakeholder conferences, public hearings, and face-to-face meetings and they were of monthly frequency throughout 2005 and 2008. In addition, information was provided through position papers, press releases and reports.

According to the second prediction of access goods theory a group which was able to provide more information through information inflow and meetings, should be more influential. As both interest groups can be argued to have been equally active in providing information through meetings and in a written form, both are expected to be influential in the case. However, based on the process-tracing conducted in the previous chapter ERA has been shown to be more influential. Therefore, the second prediction for the access goods theory is also disconfirmed.

7.2 Structural characteristics theory According to this theory an interest group with larger staff and membership size is expected to be more influential in the case. Also, that interest group should be more influential that has used more diverse and multi-level strategies in its lobbying efforts, and that was lobbying more towards status quo instead of a radical policy change.

7.2.1 Prediction 1: staff and membershipAs annual budget is not available for both of the interest groups, the attention will be paid to their staff and membership size which is publicly available information. T & E consists of 15 staff members and it represents 50 members across Europe, which are environmental organizations. ERA Directorate consists of two departments of regulatory affairs and business development with 11 staff members in total. ERA represents 173 members in total, comprising of 57 airlines, 18 airports, 12 manufacturers and 86 suppliers. Table 7 summarizes the staff size and membership size of the two groups, and while T & E has four more staff members than ERA, ERA represents far more members than T & E. According to the prediction of staff and membership size, the group that should be more influential in the case is ERA due to its considerable membership size, but based on staff size it should be T & E. Based on the comparison of interest groups’ preferences with the final legislative outcome and the extent of their lobbying activities as a part of process-tracing in the previous chapter, it has been shown that ERA has been more influential in the case. Therefore, it can be

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concluded that this prediction is partially confirmed as according to the empirical observations both groups should be influential.

Table 7 Staff and membership size

Interest group Staff size Membership size

Transport & Environment (T & E) 15 50

European Regional Airlines Association (ERA) 11 173

(Source: T& E, 2012b; 2012c; ERA, 2012b; 2012c)

7.2.2 Prediction 2: more diverse lobbying activities and specialized lobbying techniques

As it has become clear in the previous chapter when tracing the process of lobbying, both groups were rather equally active in their lobbying efforts and they both targeted all of the three EU institutions: the Commission, the EP, and the Council. However, it has been shown that ERA was slightly more active due to the larger number of position papers that could be traced during the desk research. This interest group also co-financed an independent consultancy study on the impact of inclusion of aviation into the EU ETS, and it was shown that it was part of a stronger alliance compared to T & E. When it comes to the specialized lobbying techniques, both interest groups lobbied in coalitions, but it could not have been traced that they would have used outside lobbying strategies. This prediction that a group that uses more diverse lobbying activities and specialized lobbying technique is expected to be more influential can be confirmed, as ERA used more diverse lobbying activities and it has been established in the process-tracing in the previous chapter that this group had more preferences reflected in the outcome and was ranked higher in its lobbying efforts.

7.2.3 Prediction 3: status quo versus policy changeAccording to the theory the group that lobbies more in the direction of status quo instead of a radical policy change, should be more influential in the case. In comparison between the two interest groups at stake, ERA was the group which was pushing more into direction of the existing state of affairs instead of a radical policy change. At first ERA was rather sceptical of the proposal to include aviation in the scheme and even completely against it, and later it was lobbying for a ‘modest’ version of the directive. It was modest in a sense that it was against full auctioning of allowances, against additional fuel taxation being imposed on the aircraft, and also against including any other gas effects except for CO2 in the scheme. T & E, on the other hand, was lobbying for more radical aspects to be included in the final legislation, such as: a cap of 50 per cent so that the aviation industry would be expected to reduce its emission by 50 per cent; full level of emissions auctioning so that none would be given for free but sold to the aviation sector instead; including non-CO2 emissions effects in the scheme; and also imposing additional fuel taxation on the aviation sector on top of the scheme. By all means this shows that T & E was lobbying towards a radical policy change in comparison to ERA. According to this prediction, ERA should be more influential as it was lobbying more in the direction of status quo. This can be re-checked by the process-tracing in the previous chapter, which established that ERA was more influential. Therefore, this prediction is also confirmed.

7.3 Issue-characteristics theory

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According to this theory what benefits interest group’s influence attempts is whether an issue at stake is salient to the public and whether there is high public visibility on it. In case that the public was more ‘in favour’ of an environmentally friendly solution, environmental groups are expected to be more influential, and if this was not the case, then aviation industry groups should be more influential. In addition, those groups that used ‘increasing saliency of the issue’ as their strategy are expected to be more influential. And, if there is a degree of conflict between different interest groups and some of the groups form stronger alliances in comparison to the other ones, they should be more influential in the regard to the outcome.

7.3.1 Prediction 1: public visibility of the issueAccording to the theory if the issue of bringing aviation in to the EU ETs was salient to the general public, and there was a lot of public awareness about it, while the public was also more in favour on an environmentally solution, then environmental groups should be more influential in the case. When examining individual responses from the general public in the Commission’s consultation in 2005, in total 5564 submissions were received and also many letters arrived, in particular from Germany, the Netherlands and the United Kingdom. Compared to the population of the EU in 2005 which was almost 460 million people, the number of submissions is relatively low which shows that public visibility and saliency of the issue was not that high.

A majority of the respondents as of 54,9 per cent stated that they do not feel informed about the climate change impact of the aviation, while 38,7 per cent responded that they do. There was a widespread support for the policy objective to include the aviation sector in the EU ETS as 82 % of the respondents fully agreed, and to include the cost of the climate impact in the price of air transport 68 % fully agreed (the European Commission, 2005).

According to one of the interviewees there was not much general public awareness about bringing aviation in the EU ETS, but it can be claimed that the public wanted that the aviation sector contributes to climate change mitigation with some measures/instruments (Interview 3, AEF, 2012). Another interviewee said that a significant proportion of the population is still doubtful whether climate change is real or whether it is a myth, and due to the complexity of a cap and trade model with which people are unfamiliar, this probably resulted in a quite low level of public visibility and engagement with the issue (Ibid.). Another interviewee stated that the general public was not clearly informed on the need and potential consequences of including of aviation in the EU ETS (Interview 2, ERA, 2012).

Thus, it can be claimed that there was no high public visibility on the issue of climate change and its capping, and therefore aviation industry interest group should be more influential in the case. This is also what process tracing has showed in the previous chapter, and therefore this prediction is confirmed.

7.3.2 Prediction 2: increasing saliency of the issueT & E was somehow increasing the saliency of the issue through its press releases directed at the press (Interview 1, T & E, 2012). ERA raised the saliency of the issue to the general public by press releases which were produced in order to raise awareness of a wider audience, but as stated by the group the main lobbying targets are the EU institutions (Interview 2, ERA, 2012).

According to the Corporate Europe Observatory (CEO) the European aircraft operators increased saliency if the issue by raising the spectre of thousands of job losses which is a common industry tactic. They challenged the impact assessment the impact assessment on inclusion to EU ETS by the Commission and commissioned consultants from Ernst & Young and York Aviation in order to conduct their own assessment which was

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published in June 2007. While the Commission’s conclusion was that the inclusion would only have a marginal effect on airline’s profitability and employment, the study commissioned by the airline industry suggested that it would between 8,000 and 42,000 direct jobs by 2020 depending on allowance prices, and also result in between E772 million and 3,862 million less gross value contributions to the economy compared to ‘business as usual scenario’ (CEO, 2008: 8).

Also, according to the CEO’s report the International Air Transport Association (IATA) was raising the saliency of the issue in 2008, for example, by a full page advertisement in the International Herald Tribune stating that ETS would cause international legal battles, and that it does not necessarily have effects on the climate change. IATA was also raising the saliency by an ‘environment display’ in a form of an exhibit at Schiphol Airport in Amsterdam in order to promote a public image of aviation as green. This exhibit was supposed to tour the EU’s major airports, being displayed two months at each airport. In addition, the IATA also launched a website ‘Enviro.Aero’, which provides facts on aviation and its climate change impact (Ibid.).

According to the prediction that group which uses increasing saliency of the issue as a strategy, should be more influential. While both groups only increased saliency through occasional press releases directed at the general public, ERA was involved more in increasing saliency of the issue as it was continuously pointing out what consequences the Aviation directive would have on the competitiveness and the EU job market. In addition, it was represented by IATA which was campaigning for increasing saliency as described above. Therefore, according to this prediction ERA should be more influential, which is also confirmed by process-tracing method of the previous chapter and this prediction is then also confirmed.

7.3.3 Prediction 3: degree of conflict – forming alliancesThere was a considerable degree of conflict in regard to Directive 2008/101/EC between T & E which represents environmental interests and ERA which represents the aviation industry. Major points of disagreement were the exact starting date of the EU ETS for aviation, how to determine the cap on emissions and how to distribute the allowances. In addition, T & E stated that other greenhouse gases should be taken into account in the directive, while ERA was strongly against it. Also, T & E was supporting full auctioning (100 per cent) of allowances which would constitute a practical application of the polluter-pays principle, while ERA was against full auctioning and lobbying for a modest level of auctioning.

When it comes to T & E interest group it built alliances, first of all with its fifty members that it represent, but the group also worked closely with a wide range of NGOs at both European and national levels (Interview 1, T & E, 2012). These groups are: CAN-Europe, Friends of the Earth Europe, Aviation Environment Federation and World Wildlife Fund. In addition to being in permanent alliance with their fifty members, T & E is also part of a permanent and the so-called ‘The Green 10’ group which includes ten of the largest European environmental organization/networks. These ten groups coordinate joint responses and recommendations to the EU decision makers, and it includes such organizations as the European Environment Bureau, Greenpeace, WWF European Policy Office etc. Through its alliance T & E was able to combine forces with other groups in order to compose position papers, as well as to write press releases and reports (Ibid.).

ERA was also part of an alliance with other aviation industry associations such as, Association of European Airlines (AEA), European Cargo Alliance, The International Air Carrier Association (IACA), European Business Aviation Association (EBAA), and European Express Association (EEA). In addition, its interest were also represented by the International

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Air Transport Association (IATA) which is an international trade body representing some 240 major passenger and cargo airlines. The was also heavily lobbying the case of including aviation in to the EU ETS on behalf of aviation industry stressing that emissions trading of aviation should be modest, and there should be more focus on technological development and implementation of the Single European Sky (EurActive, 2007). Through this cooperation it was possible to produce joins position papers, joint meetings with key decision-makers, financing independent reports and studies, sharing of technical data (Interview 2, ERA, 2012).

After the data analysis it can claimed that even though both interest groups formed strong alliances to stand stronger in the decision-making process, ERA belonged to the stronger alliance as it is not only represents 173 members (while T & E only represents 50 members), but it is also strongly supported by IATA which represents 240 airlines and was strongly involved in lobbying the case and supporting ERA. As according to the third prediction of issue characteristics theory that group which belongs to a stronger alliance should be more influential in the case, ERA is expected to have more influence. This can be checked upon by the process-tracing method, which also established in the previous chapter that ER had more influence in the case. Therefore, this prediction is also confirmed.

7.4 Conclusions on congruence analysis properThis chapter has intended to test the theoretically derived predictions from three theories with empirical observations attained through the process of data collection. Table 8 summarizes the results of congruence analysis proper by showing which theoretically derived predictions have been confirmed, disconfirmed or partially confirmed.

Table 8 Results of testing theoretically derived predictions with empirical observations

 Predictions Confirmed Disconfirmed Partially confirmedAccess goods theory1. information to the right institution x2. amount of information inflow and meetings xStructural characteristics theory1. larger staff and membership size x2. more diverse lobbying activities x3. status quo instead of policy change xIssue characteristics theory1. public visibility of the issue/saliency to general public x2. increasing saliency of the issue x3. degree of conflict - stronger alliance x

As it has been shown in this chapter, both predictions for access goods theory have been disconfirmed, as both interest groups provided crucial information to the right institution, and they were rather equal in amount of crucial information they were able to provide to the EU institutions. Therefore, it would be expected that both groups are influential in the case, while the analysis though process-tracing showed that ERA is more influential. In regard to the theory of structural characteristics, two of the predictions have been confirmed, and it has been shown that an interest group should be more influential in the case if it uses more diverse lobbying techniques, and if it is lobbying in the direction of a status quo instead of a radical policy change. When it comes to the third prediction of staff and membership

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size, it is only partially confirmed as T & E has a larger staff size and ERA has a larger membership size. Therefore, both groups would be expected to me influential in the case, while process-tracing showed that ERA was more influential. All of the three predictions for the issue characteristics theory have been confirmed. It has been shown that it matters for influence attainment of there is a general public visibility on the issue at stake. As the case of bringing aviation in the EU ETS was not a highly salient and publicly visible issue, the aviation sector was more influential which was lobbying for a less environmental solution compared to the environmental groups. In addition, an interest group is more influential in the case if tries to increase the saliency of the issue to the general public, and if it builds a stronger alliance compared to the other groups.

Chapter 8: Conclusion

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The final chapter of this research study sums up the overall study, gives an answer to the central research question and presents the main findings. This will be followed by a short discussion on the limitations encountered in the process of data collection and what implications this had for the analysis. Finally, recommendations for future research are given.

8.1 Summing up the researchThe aim of this research was to examine the influence of two interest groups in lobbying the policy-making process in the case of bringing aviation in the EU Emissions Trading System. Chapter 2 provided some essential background information on interest representation in the EU and elaborated on the concepts of lobbying and influence, while also explaining which EU institutions can be targeted by interest groups. Chapter 3 discussed the choice of three theories which were selected for this research and predictions were derived from these theories. Chapter 4 reflected on the available research designs while justifying the choice for a case study design, and in particular congruence analysis combined with a method of process-tracing for measuring interest group influence. Chapter 5 introduced the chosen case of Directive 2008/101/EC as of bringing aviation in the EU ETS, and identified the two relevant groups

8.2 Answer to the research question and findings The central research question of this study was:

Which theory better explains the influence of interest groups in the case of bringing aviation in the EU Emissions Trading System (ETS)?

Based on the congruence analysis proper combined with the method of process-tracing the answer to the central research question is that both, structural characteristics theory and issue characteristics theory better explain the influence of interest groups in the case of bringing aviation in the EU Emissions Trading System. The reason for this is that all of the three predictions for access goods theory were confirmed in congruence analysis proper, while two out of three predictions were confirmed for structural characteristics theory.

The findings of this study are that as proposed by structural characteristics theory, an interest group has more chance for influencing the final piece of legislation if it has larger membership size. However, having larger staff size was not confirmed to be an important factor. In addition, if an interest group uses more diverse and specialized lobbying strategies, and if it is lobbying towards status quo instead for pushing for a radical policy change, it should have more influence. Also, as proposed by issue characteristics theory an interest group has more chance for influence, if it increases saliency of the issue to the general public, and if it is part of a stronger alliance compared to the other interest groups in alliances. Public visibility of the issue to the general public matters as well. As it was concluded that the general public was not highly aware of climate change mitigation and including the aviation in the EU ETS topic, the aviation sector interest had more influence.

In regard to theory of access goods which was tested as the third theory, the findings are that both of the predictions derived from this theory are disconfirmed. As both interest groups provided crucial information to the right institution, and the amount of information inflow and meetings where information was provided are rather equal, both of the groups should be influential in the case. However, process-tracing method established that ERA has been more influential. Therefore, the findings off this research confirm the aim of this study which was to show that the newer theoretical framework of issue characteristics plays an important role when explaining the influence of interest groups. While a case study design is

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low on external validity and cannot be generalized to other cases, the recommendation for future research would be to continue testing the theory of issue characteristics on multiple cases, and not to take the more prevalent theory of access goods for granted when investigating interest group influence.

To conclude, it is important to note that due to the limitations encountered in this research, the author has to be cautious when making conclusions about the findings as there are several gaps in tracing the whole lobbying process of both interest groups. In addition, it was not possible to re-check all of the information obtained from the interviews through the desk research. There were several limitations that were encountered in this study. First of all, choosing to focus on measuring influence and tracing lobbying activities is not of the easiest tasks in social science research. However, this was a conscious decision and the aim was to elaborate to theoretical discourse on interest group influence which still remains a somehow largely not researched topic. As discussed in Chapter 4 there are three methods for measuring influence, but all of these methods have certain limitations, and tracing lobbying activities is rather challenging as data could not be found in public documents and the research had to rely on interviews with two interest groups, also as lobbying often happens behind closed doors it cannot always be traced. The method chosen for measuring influence was process-tracing which is beneficial in the sense that it can help to acknowledge all factors influencing a political decision and lobbying efforts. However, it is not always possible to get empirical evidence which would cover all steps in the causal chain and it often over-relies on interviews for tracing necessary information.

The second limitation of this research has to do with data collection process, as only four interviews could materialize in the end and much more would have been needed for the validity of this research. In addition, it turned out to be more feasible to opt for e-mail questionnaires instead of initially planned semi-structured interviews. However, this type of data collection does not necessary help in capturing the whole extent of a social phenomenon which is a notable limitation. Getting interviews proved to be a difficult task, while interviews with both interest were fortunately possible, this research lacks interviews with the EU institutions representatives in order to check upon the data collected through interviews with interest groups. Interview requests were sent to the Commission representatives, the MEPs, rapporteurs for the case of bringing aviation in the EU ETS and shadow rapporteurs for the file, but unfortunately interviews with these representatives could not be realized.

Third, as initially planned additional desk research through newspapers and databases was necessary to compensate for the limited amount of materialized interviews. However, this solution did not render as much results as was hoped for as these sources only discussed the consequences of including aviation in the EU ETS and the course of the political decision-making and did not touch upon the exact lobbying activities of the two interest groups which was crucial for process-tracing and congruence analysis proper. As a result of these limitations, there has been over-reliance on interviews in data collection process which cannot be rechecked through desk research, and the accuracy in distinguishing significant differences between the lobbying activities of the two interest groups is limited. The last sub-section of this chapter will present some considerations for future research on interest group influence.

6.3 Recommendations for future research This research aimed at contributing to theoretical discourse on interest group influence, but further and even wider research on influence is still needed. Further research should require more time that was available for this research, and it should attempt to make use of more interviews. Especially interviews with representatives from the EU institutions would be crucial in order to get a better picture on lobbying efforts and contacts that interest groups

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might have had with the EU representatives. In addition, in this research not all ‘strategies’ used by interest groups and described Dur (2008b) were taken into account. As a matter of fact, the focus was only on the strategy of access. Therefore, it is recommendable that future research takes other strategies such as, selection, voice and structural coercion into consideration. It can also be advised for future research to investigate more than one case in order to better test the theory of issue characteristics, perhaps, large-N study would also be rather beneficial.

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Appendix 1: List of interviewed persons (May – June 2012)

1. Mr. Bill Hemmings, Manager Aviation & Shipping, Transport & Environment Federation

2. Mr. Leonardo Massetti, Manager Industry Affairs, European Regional Airlines Association

3. Mrs. Cait Hewitt, Deputy Director, Aviation Environment Federation 4. Dr. Manfred Treber, Senior Advisor, German Watch

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Appendix 2: List of people contacted for an interviewName and position Organization Comments

1. Bill Hemmigs Transport and Environment (T & E) Interview was possible withManager - Aviation & Shipping Mr. Hemmings2. Jos DingsPolicy Team Director3. Julia Michalik CAN-EuropeEU Climate Policy Officer4. Jason Anderson WWF European Policy OfficeHead of European Climate and Energy

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5. Stephan SingerClimate and Energy Expert6. Sam van den PlatsPolicy Officer, Climate & Energy7. Esther Bourree Friends of the Earth EuropeOffice Manager8. Brook RileyClimate and Energy Programme9. Sonja MeisterClimate Justice and Energy Team10. Richard Dyer (UK office)Transport Campaigner11. Michel Adam Association of European AirlinesManager Env. & Consumer Affairs (AEA)12. David HendersonManager Policy Aspects13. Nick Mower European Regional Airlines Interview was possible withGeneral Manager Reg. Affairs Association (ERA) Mr. Massetti14. Sandra AnaniManager Reg. Affairs15. Leonardo MassettiManager Industry Affairs16. Kirsty WishartCoordinator Reg. Affairs17. Charlotte Inglis European Climate FoundationAssociate: Global Climate Policies18. Bert Metz in both Brussels & The HagueFellow19. Martijn BroekhofAssociate: Power20. Elsa OzmenAssociate: EU Climate Policies21. Stephen BoucherDirector EU Climate Policies22. general enquiry Oxfam Brussels23. Annika Ahtonen European Policy CentrePolicy Analyst24. Olivier Hoedeman Corporate Europe ObservatoryResearcher (CEO)25. Yiorgos YassalosResearcher26. Bettina KampmanSenior Consultant EU Climate Policy27. Jasper Faber CE Delft Agreed on an interview, but

Coordinator Aviation & Shipping it could not be materialized28. Huib van Essen/General Manager29. Joris den Blanken Greenpeace European UnitEU Climate & Energy Policy Director30. Tim Johnson Aviation Environment Federation Interview was possible with ViceDirector EU Climate Policies (AEF) President Ms. Cait Hewitt31. Tim ThomasGeneral Aviation Caseworker32. Nic FerridayAir Transport Caseworker33. Horst Seefeld EACON (European AffairsTransport Policy Consultant Consulting Group)34. Martin Saeckl

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Managing Director35. Pieter de Pous European Environmental BureauPolicy Director36. Agathe ErnoultPolicy Officer: Energy and Climate5 different representatives Lufthansa Airlines38. Alfredo Sanchez Vicence European Environment AgencyProject Manager -Transport39. Cinzia PastorelloProject Officer - Transport and Energy40. Francois DejeanClimate Change Mitigation41. Melanie SporerClimate Change Mitigation42. Ron Wit the Netherlands Society for NatureTeam Manager and Environment (SNM)43. Talitha KoekProject Leader Public Affairs44. Wilma BerendsSenior Project Leader45. Caroline Lucas ENVI CommitteeRapporteur at that time MEP 1999-201046. Peter LieseRapporteur at that time ENVI Committee47. Karl-Heinz Florenz (Christian Democrats)rapporteur for the CLIM Committtee MEP 1999-201048. Eisabetta Gardini ENVI Committee49. Thomas Verheye DG EnvironmentIndustrial Emissions & Air quality50. Soledad BlancoDirector Industry & Air51. Manfred Treber GermanwatchSenior Advisor - Climate and Transp.52. Sven HarmelingInternational Climate Policy53. Carl Schlyter Group of the GreensMEP54. Satu Hassi Group of the GreensMEP55. Chris Davies Group of the Alliance of LiberalsMEP and Democrats for Europe56. Terhi Lehtonen Group of the GreensMEP57. Claude Turmes Group of the GreensMEP58. Margrete Auken Group of the GreensMEP

Appendix 3: Questionnaire form for interest groups under investigation

Topic: interest representation in relation to the Directive 2008/10/EC as to bringing aviation into the EU ETS

Time scope: 2005-2008

Interest group: European Regional Airlines Association or

Transport & Environment Federation

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1. In your opinion to what extent are preferences and position of your organization in regard

to bringing aviation into the EU ETS reflected in the final version of the Directive?2. What are your statements about the final version of the Directive? 3. During the lobbying process did your organization provide information to the EU

institutions? If yes,a) In what form (position papers, press releases, reports, meetings, other ways)?b) Did you provide technical information/expert knowledge to the Commission, or was it

some other type of information?c) Did you provide information about the European encompassing interest (thus, how

legislation would influence the EU as a whole) to the European Parliament, or was it some other type of information?

4. Did your organization attend meetings related to the Directive with the EU institutions (the Commission, the European Parliament, the Council) and provide information during these meetings? If yes,

a) Were these meetings formal, informal, or both? Were these meetings with all of the three EU institutions, or was one of them targeted more than the others?

b) What was the frequency of these meetings (between 2005 and 2008)?5. In general, in your lobbying activities do you tend to provide information to the

Commission, the Parliament, or the Council? 6. In your opinion, how important was the Commission’s stakeholder consultation to your

organization? Was your organization active in providing its opinion during the consultation?

7. What kind of lobbying methods were used by your organization to lobby the European Parliament and the MEPs?

(for example: personal contact meetings, position papers, hearings of the EP, organizing lunches or dinners, contacting rapporteurs and shadow rapporteurs, contacting ENVI Committee, lobbying before 1st reading, lobbying before 2nd reading, other activities) 8. What kind of lobbying methods were used to lobby the Commission and DG

Environment (for example: informal meetings, formal meetings, formal requests, participating in hearings, personal contacts etc.)?

9. What kind of lobbying methods were used by your organization to lobby the Council?10. Did your organization form alliances with other interest groups? If yes, how did you

collaborate in the alliance? (for example: shared reports, lobbying together, organizing campaigns etc.)?

11. In your opinion, do alliances stand stronger in the policy process? 12. Did your organization use such lobbying techniques as hiring a consultant, mass media

mobilization, and employing outside lobbying?13. Did your organization try to raise the salience of the issue of bringing aviation into the EU

ETS to the general public? If yes, in what form was this accomplished?14. In your opinion was the issue of bringing aviation into the EU ETS salient to the general

public and was there a lot of public awareness about it?15. If it is public information, would it be possible to get the annual budget for 2011 of your

organization?

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Appendix 4: Questionnaire form for other interest groups

Subject: Directive 2008/101/EC bringing aviation into the EU ETS

Time scope: 2005-2008

Interest groups under examination:

Transport and Environment (T & E)

European Regional Airline Association (ERA)

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Provision of information

1. Which of the above groups provided technical information/expert knowledge to the Commission? In what form was this done and how often?

2. Which of the above groups provided information about the European encompassing interests to the European Parliament? In what form was it done and how often?

3. In your opinion which of the EU institutions was the most important target for each of these interest groups?

4. Which of the above groups were most active in providing information to the European institutions? Is there any significant difference in their efforts to provide information?

5. Which of the above groups had most of the formal/informal meetings with the relevant EU institutions? What was the frequency of these meetings and which EU institutions were targeted?

Lobbying methods

6. What kind of lobbying methods were used by the above interest groups to lobby the European Parliament and MEPs?

(for example: personal contact meetings, position papers, hearing of the EP, organizing lunches or dinners, contacting rapporteurs and shadow rapporteurs, contacting the ENVI Committee, lobbying before 1st reading, lobbying before 2nd reading, other activities) 7. What kind of lobbying methods were used to lobby the Commission and DG Environment

(for example: informal meetings, formal meetings, formal requests, participating in hearings, personal contacts etc.)?

8. What kind of lobbying methods were used by the above groups to lobby the Council?9. Did Transport & Environment, or European Regional Airlines Association form alliances

with other groups? Do the groups in alliances stand stronger in the policy process in your opinion?

10. Which alliance (on the environmental side or on the aviation industry side) was more significant and stronger? And why was it stronger compared to the other side?

11. Did the above groups also contact domestic decision-makers?12. What other lobbying techniques did the two groups use? (e.g. hiring a consultant, mass

media mobilization, employing outside lobbying, campaigns, press release, reports) 13. In your opinion did the groups use multi-level strategies and specialized lobbying

techniques? In your opinion, which of the two groups used more diverse strategies? 14. Generally speaking, in your opinion are there significant differences between the lobbying

methods of the two groups in this specific case?15. Was either of the group trying to increase the saliency of the bringing aviation into the EU

ETS issue? If yes, how was this done? Did they perhaps use this strategy in order to win their cause?

Public visibility of the issue

16. In your opinion was the issue of bringing aviation into the EU ETS salient to the general public and was there a lot of public awareness about it?

17. Could it be claimed that the general public was more in favour of an environmentally sound solution as it was concerned about climate change?

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Thank you for your time and answers!

Appendix 5: List of position papers published by both interest groups

European Regional Airlines Association

1. European aviation industry joint statement on emissions trading scheme (October 13, 2006)

2. Common position adopted by the airspace user associations on the proposed directive as to include aviation activities […] (June 6, 2007)

3. ERA proposal for suggested amendments (June 11, 2007)4. European aviation industry joint position paper on Emissions containment policy (July 7,

2007)5. Common position of the European aviation industry on amendments to the Commission’s

proposal to include aviation in the current ETS (October 15, 2007)

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6. ERA position on the common position of the European Council on the European

Commission’s proposal to include aviation in the EU ETS (April 30, 2008)7. Joint position adopted by the airline industry (May 19, 2008)8. Climate policy for aviation Nox. Airline associations’ joint reply to the CE Delft paper of

6 May 2008 (May 23, 2008)9. ERA paper on inclusion of aviation in the EU ETS prior to EP’s2nd reading (June 6, 2008)10. ERA draft response to the European Commission’s public consultation on the EU ETS –

monitoring, reporting, and verification (mrv) for aviation – Addressed to Directorate General Environment (November 3, 2008)

11. ERA position paper on aviation within the general revision of the EU (November, 11 2008)

Transport and Environment Federation

1. Joint NGO position paper on measures to curb the climate change impacts of aviation (May 31, 2005)

2. Joint NGO position paper on measures to reduce the climate change impact on aviation (October 26, 2006)

3. Joint NGO statement on including aviation in the EU Emissions Trading Scheme (May 22, 2008)

4. Letter to Environment Ministers on aviation in EU ETS (June 22, 2008)

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