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322 Public Administration Review • May/June 2001, Vol. 61, No. 3

Daniel J. FiorinoU.S. Environmental Protection Agency

Environmental Policy As Learning:A New View of an Old Landscape*

Environmental policy in the United States has always been characterized by high levels of politicalconflict. At the same time, however, policy makers have shown a capacity to learn from their ownand others’ experience. This article examines U.S. environmental policy since 1970 as a learningprocess and, more specifically, as an effort to develop three kinds of capacities for policy learning.The first decade and a half may be seen in terms of technical learning, characterized by a highdegree of technical and legal proficiency, but also narrow problem definitions, institutional frag-mentation, and adversarial relations among actors. In the 1980s, growing recognition of deficien-cies in technical learning led to a search for new goals, strategies, and policy instruments, in whatmay be termed conceptual learning. By the early 1990s, policy makers also recognized a need fora new set of capacities at social learning, reflecting trends in European environmental policy,international interest in the concept of sustainability, and dissatisfaction with the U.S. experience.Social learning stresses communication and interaction among actors. Most industrial nations,including the United States, are working to develop and integrate capacities for all three kinds oflearning. Efforts to integrate capacities for conceptual and social learning in the United Stateshave had mixed success, however, because the institutional and legal framework for environmen-tal policy still is founded on technical learning.

*The views expressed in this article are those of the author and notnecessarily those of the U.S. Environmental Protection Agency.

Daniel J. Fiorino is the director of the Performance Incentives Division in theOffice of Policy, Economics, and Innovation at the U.S. Environmental Pro-tection Agency. He directs projects on performance-based environmentalmanagement, performance measurement, and regulatory innovation and isthe program manager for the EPA’s National Environmental PerformanceTrack. He is the author of Making Environmental Policy (California, 1995)and a co-author of Managing for the Environment (Jossey-Bass, 1999). Email:[email protected].

Do governments and institutions learn? Are policy mak-ers, activists, experts, and others capable of drawing les-sons from their experiences and applying it to problemsthey face? A persuasive literature in public policy arguesthat institutions and people within them do learn, and thata learning model is a useful way to understand and explainpolicy change. This learning approach has been proposedto complement more traditional approaches to policychange that are based on political conflict, approaches thatdepict government and policy as driven largely by societalconflicts and pressures.

Approaches to policy change based on a learning model“generally hold that states can learn from their experiencesand that they can modify their present actions on the basisof their interpretation of how previous actors have fared inthe past” (Bennett and Howlett 1992, 276). A learningmodel suggests a more positive view of policy making thandoes the traditional, conflict-based model. The notion that

governments and policy makers learn over time suggests apurpose to policy making. A learning approach stressesknowledge acquisition and use. Policy makers are seen lessas passive forces driven by political and interest group pres-sures than as sources and implementers of ideas, informa-tion, and analysis that influence choices.

This article applies a learning model to U.S. environ-mental policy, with a focus on pollution control. Environ-mental policy making is knowledge intensive and com-plex, involving scientific, technical, legal, policy, and socialissues. How people obtain, evaluate, and use knowledge isimportant. Many aspects of politics and policy—defini-tions of problems, analytical tools and methods, differencesbetween lay and expert perceptions, perceived conflicts

Environmental Policy As Learning: A New View of an Old Landscape 323

between economic and environmental goals—havechanged over time. Nations at similar stages of develop-ment face similar issues and move through comparablephases in environmental problem solving (Janicke 1996;Janicke and Weidner 1997). Thus, environmental policypresents an opportunity to examine how policy makers haveor may be able to learn from their experience.

The Foundations of a Learning ApproachWhat does it mean to view public policy making as a

learning process? An early application of a learning ap-proach was Hugh Heclo’s Modern Social Politics in Brit-ain and Sweden (1974). In that work, Heclo challengedthe prevailing view among political scientists that changesin public policy were largely the product of societal con-flict, arguing that an approach “focused on knowledge ac-quisition and utilization could yield better explanations andunderstanding about policies than existing conflict-basedtheories” (276). Although the resolution of conflicts amongsocietal interests may explain periods of fundamentalchange, much of what occurs in between may be seen asefforts by policy makers to learn and to apply the lessonsof that learning.

Heclo described policy learning as “a relatively endur-ing alteration in behavior that results from experience”(306). Policy makers learn in response to changes in theexternal policy environment: “As the environment changes,policy makers must adapt if their policies are not to fail”(277). Similarly, in a book on “lesson drawing,” RichardRose presents learning as a response to dissatisfaction,which in turn stimulates a search for solutions: “actionsthat will reduce the gap between what is expected from aprogram and what government is doing” (1993, 50). Dis-satisfaction with the status quo may come from manysources: changes in problems, the emergence of new con-stituency groups, a catastrophic event, globalization ofdomestic issues, budget constraints, and so on. What mat-ters is that there is enough of a sense of disruption thatpolicy makers are led to search for ways to reduce dissat-isfaction within the policy system.

Of course, the differences between conflict-based andlearning-based models are not always clear cut. Any policysystem will experience periods of conflict, especially whendissatisfaction produces demands for fundamental change.These periods of change may redefine the context in whichlearning occurs. In U.S. environmental policy, for example,especially high levels of conflict between the executive andlegislative branches in the early 1980s (when a Republi-can president was paired with a Democratic Congress) andmid-1990s (when the reverse situation existed) stimulatedefforts to shift from one to another kind of policy learning.The point of this article is not to deny that conflict shapes

policy, but that viewing policy making primarily in termsof conflict undervalues the substantial amount of construc-tive learning that occurs in a policy system over time. Be-neath the obvious political conflict, a great deal of learn-ing has been going on.

Thinking of policy making as a learning process raisesseveral questions (Bennett and Howlett 1992). First, who isdoing the learning? Should we think of learning as some-thing that occurs only among government officials, or is therea broader set of influential actors who are part of the learn-ing process? The literature suggests a range of answers, fromonly elected officials, to appointed and career governmentofficials, to a much broader set of nongovernmental actors(lobbyists, advocacy groups, litigators, journalists) and“epistemic communities” of policy experts. This article takesa broad view, including anyone who may have influenceover policy choices as part of the learning process. In theenvironmental arena, this includes elected officials and staff,political appointees, agency staff, the media, advocacygroups, researchers, regulated firms, and international bod-ies such as the United Nations Environment Program.

Second, what is learned? A principal issue is whetherpolicy makers learn only about the means or instrumentsof policy or whether they learn about the ends or goals ofpolicy as well. This article proposes a broad conception ofwhat is learned. Certainly the participants in environmen-tal policy making have shown a capacity to learn aboutmeans and instruments. Examples in the United States arethe growth of emissions trading, application of alternativedispute resolution to environmental issues, and improve-ments in risk communication over the last 20 or so years.But policy makers have shown a capacity to learn aboutgoals as well. The goal of pollution control was expandedto encompass pollution prevention and risk managementin the 1980s. Since the Brundtland Commission report in1987, and the Rio de Janeiro Earth Summit in 1992, peoplerecognize the concept of sustainable development as a new,more inclusive goal for environmental policy.

Third, what are the results of learning? This article takesthe view that “learning does not occur unless there is somekind of policy change which results from the learning pro-cess” (Bennett and Howlett 1992, 285). An organizationmay have effective mechanisms for collecting intelligenceabout shortcomings in existing policies, but it may not havemechanisms for translating this intelligence into new formsof behavior or structures that allow for changes in behav-ior. For example, policy systems founded on what is de-scribed as technical learning may possess mechanisms forgaining feedback about the effects of policies, but may lackthe flexibility to respond. In particular, this article arguesthat the prescriptive environmental statutes passed in the1970s and 1980s limited the United States’ capacity to adaptto demands for change in the 1990s.


This does not mean the policy response to learning mustbe immediate. Indeed, it may take decades for policy mak-ers to incorporate information about new strategies intoactual policy. An example is the process by which market-based incentives have gradually been incorporated intopollution control programs. A crude form of air emissionstrading was first adopted in the “offset” policy of the mid-1970s, but broader air emission trading concepts wereimplemented throughout the 1980s. Incorporation of trad-ing provisions into water pollution policies has proceededat a much slower pace. Still, the gradual adoption of mar-ket trading concepts into U.S. pollution control may beviewed as a successful case of policy learning.

This article distinguishes three kinds of policy learning,based on Pieter Glasbergen’s (1996) work on environmen-tal policy in the Netherlands. Glasbergen’s learning typesare developmental; one often evolves into another. U.S.environmental policy over the last 30 years may be seen asa partial evolution from one type into others. They also arecumulative; each builds on experience with a predecessorand complements rather than replaces it. The learningmodel may be applied to all aspects of environmental policymaking: problem definitions, the organization of respon-sibilities within government, the relationships among ac-tors, and the choice of policy instruments for respondingto problems. Glasbergen proposes the learning model notas an alternative to the traditional analysis of policy mak-ing that is shaped by political conflict, but as a supplemen-tary perspective to enhance our understanding and to charta path for the future.

Glasbergen stresses the need for “continuing initial re-flection on the policy process” (175). Like most writerson policy learning, he recognizes the role of “reflexiv-ity” in contemporary environmental policy (see Giddens1990; Teubner 1983; Orts 1995). Two aspects of his ap-proach deserve emphasis. First, he takes a broad approachto what is learned. Learning relates not only to instru-ments (emissions trading) or analytic tools (cost–benefitanalysis), but also to problem definitions, policy goals,and strategies. Second, he stresses the contexts of learn-ing, especially relationships among actors, the institu-tional aspects of policy processes, and legal frameworks.The emphasis on context leads Glasbergen to distinguishthree types of policy learning:

Technical learning consists of a search for new policyinstruments in the context of fixed policy objectives.Change occurs without fundamental discussion ofobjectives or basic strategies. Policy makers respondto demands for change with “more of the same” kindsof solutions that they adopted in first responding toenvironmental problems: more regulation, oversight,and enforcement.

Conceptual learning is a process of redefining policygoals and adjusting problem definitions and strate-gies. Policy objectives are debated, perspectives onissues change, strategies are reformulated. New con-cepts (pollution prevention, ecological moderniza-tion, sustainability) enter the lexicon.

Social learning focuses on interactions and commu-nications among actors. It builds on the cognitivecapacities of technical learning and the rethinkingof objectives and strategies that occurs in concep-tual learning, but it emphasizes relations among ac-tors and the quality of the dialogue.

In addition to considering the applicability of a learn-ing model, this article assesses the relevance of technical,conceptual, and social learning to the U.S. experience. Itargues that the U.S. environmental policy system is foundedon technical learning. Beginning in the mid-1980s, a rec-ognition of the deficiencies of the existing system led policymakers to search for new strategies and policy objectives.This search and the changes that resulted resemble con-ceptual learning. By the 1990s, continued dissatisfactionwith aspects of environmental regulation, especiallyadversarial relationships and a lack of capacity for coop-erative problem-solving, led to efforts to innovate throughsocial learning. Thus, the history of contemporary envi-ronmental policy may be seen as a process of evolutionfrom technical, to conceptual, to social learning. But it isonly a partial evolution. Institutionally and legally, U.S.policy is still grounded in technical learning. Conceptuallearning has been integrated only partially into nationalpolicy making; efforts to integrate social learning haveencountered even more difficulties. This article argues thatto be successful, a policy system must develop and inte-grate a capacity for all three kinds of policy learning.

This article has both descriptive and normative goals.First, the three kinds of learning describe, in many keyrespects, the evolution of U.S. environmental policy overthe last three decades. They also help to explain the diffi-culties that U.S. policy makers have encountered in adapt-ing the policy system to the demands of what Glasbergencalls conceptual and social learning. Second, by under-standing the different types of policy learning, especiallythe characteristics of effective conceptual and social learn-ing, we can better understand how this country’s environ-mental policy system should be changed. This approachalso offers a framework for drawing lessons about cross-national experiences, a point that will be developed later.

The Foundation: U.S. Environmental Policy AsTechnical Learning

Technical learning describes the early stages of nationalenvironmental policy in the United States. In technicallearning, problem definitions are narrow and focused on


threats to human health. Symptoms (auto emission levels)rather than causes (patterns of development or energy poli-cies) define problems and policy strategies. As a result,environmental responsibilities are focused in one area ofgovernment, in a separate set of legal instruments, and theyare poorly integrated, with limited connections to otherpolicy sectors and institutions. Problems are compartmen-talized, so policies are fragmented (Caldwell 1963). Theprimary strategy is control through prohibitive regulation.Hierarchical relationships are important, within govern-ment institutions and between government and society.Prescriptive legislation authorizes administrative agenciesto issue rules that, if not followed by target groups, arebacked by negative sanctions. Such regulatory instrumentsare assumed to be the primary drivers that determine thebehavior of regulated entities.

U.S. environmental policy making has closely followedthe technical model. The legal framework for pollutioncontrol that began with the Clean Air Act of 1970 embod-ied technical learning, as did laws regulating drinking wa-ter (1974), hazardous waste (1976), and waste cleanup(1980), and their reauthorized versions in the 1980s (Fiorino1995; Portney 1990). Consider the characteristics of theU.S. policy system:

1. Definitions of environmental problems. Policy mak-ers defined problems almost entirely on the basis of thepathways in which harmful exposures occurred. The frag-mented legal framework defined and reinforced compart-mentalization of problems along these lines (Andrews1997; Marcus 1980). Authorities and organizations werecreated to deal separately with air, water, waste, toxics,and pesticides. Policy responses focused almost entirelyon identifiable signs of pollution (for instance, end-of-pipewater discharges) rather than on the practices, processes,or behaviors that caused the pollution in the first place.

2. Allocation of administrative responsibilities. Re-sponsibilities that had been scattered across the federalgovernment were assigned to a new Environmental Pro-tection Agency (EPA). Authority that previously had re-sided with the Departments of the Interior, Health, Edu-cation, and Welfare, and Agriculture were shifted to theEPA (Marcus 1980). This undoubtedly strengthened thenational capacity for dealing with environmental issues,because it created a visible and (with passage of nationalenvironmental laws in the 1970s) legally powerfulagency that could rein in industrial polluters. At the sametime, however, this concentration of authority and re-sponsibility removed much of the internal advocacy andlegal obligation to protect environmental values fromother federal agencies. The EPA now had significantauthority over industrial and other sources of pollution,narrowly defined, but it was isolated administrativelyfrom federal policies with a major environmental im-

pact—land management, agriculture, transportation, andpublic health.

3. Policy strategies and institutional relationships. Adefinitive characteristic of technical learning, and of U.S.environmental policy in its early decades, is its reliance ondirect regulation, which emphasizes hierarchy and control.Hierarchy begins with Congress as the source of delegatedauthority to an agency. It continues with the internal allo-cation of responsibility, in which the agency’s political lead-ership defines goals and decision premises for lower lev-els. The agency exercises authority over the targets ofregulation, principally industrial enterprises and publicentities such as sewage treatment plants and local or stategovernments. The strategy is to control behavior by issu-ing rules, overseeing compliance, and applying sanctionsif there is evidence of noncompliance (Kagan and Scholz1984). Indeed, modern environmental regulation conformsclosely to Max Weber’s classic model of bureaucratic or-ganization—extensive hierarchy, with well-defined supe-rior–subordinate relationships; elaborate rules, substantiveand procedural; heavy reliance on documentation; and adivision of labor that fragments problem-solving capaci-ties (Fiorino 1997).

4. Separation of environmental goals from other goals.By adopting a narrow view of environmental problems,policy makers separated environmental from economicgoals. Part of technical learning is the assumption that eco-nomic and environmental goals conflict. Opponents ofexpanded regulation argued that any expenditure on pollu-tion control was a direct loss for economic growth. Advo-cates of regulation assumed that growth translated directlyinto environmental damage. Policy makers struggled tobalance two apparently irreconcilable goals, and the po-litical debate focused on the conflicts between them.

5. Relationship with industry and other stakeholders. Acharacteristic of technical learning is legalistic andadversarial relationships between regulators and industry.The regulated entity is seen less as a participant in policymaking than an object of regulatory authority. The rela-tionship between regulator and industry is characterizedby legal formalization and (as a consequence) distrust(Bardach and Kagan 1982). Although this adversarial re-lationship was later seen as a weakness of the U.S. ap-proach, it was deliberately built into the design. Reactingto evidence of industry capture of economic regulators (forexample, the Interstate Commerce Commission), policymakers designed a system based on “adversarial legalism”(Kagan 1995).

Technical learning may be seen as the typical first stagein the evolution of environmental problem solving. Com-parative analyses show that most Western nations initiallyapproached environmental problems through technicallearning (Dryzek 1997; Janicke 1996). The United States


developed this capacity to a high degree. For many years,it was an exemplar of technical learning, one that othernations strove to emulate. Over time, however, policymakers recognized the limits of an approach based purelyon technical learning. This recognition stimulated a searchfor new capacities, presented in the next section as con-ceptual learning.

The 1980s: From Technical to ConceptualLearning

During the 1980s, there was a growing recognition that,whatever gains had been made, the existing approach wasdeficient. Efforts to overcome these deficiencies stimulatedinterest in capacities for conceptual learning. Governmentand industry reformulated policy objectives and searchedfor new strategies.

Traumatic events often initiate a search for new policymodels and objectives. The early 1980s was a traumaticperiod for U.S. environmental policy. The Reagan admin-istration arrived in Washington in 1981, convinced it had amandate to reduce government intervention in the economy,in environmental regulation as much as anywhere else.President Reagan appointed Anne Gorsuch to head the EPA,and she quickly set out to reduce federal regulation onnearly all fronts. When the administration’s strategy forlegislative change was frustrated by the Democratic Con-gress, it turned to an administrative strategy of cutting en-vironmental budgets, trimming enforcement, institutingcost-based review of agency rules by the Office of Man-agement and Budget, and initiating rules to grant regula-tory relief to regulated firms. By early 1983, however, itwas clear the administration had misjudged public sup-port: Anne Gorsuch was forced to resign and WilliamRuckelshaus returned for a second tour as administrator(Vig 1997).

The shift in U.S. environmental policy from solely tech-nical to conceptual learning began with Ruckelshaus’s re-turn in 1983. The political battles of the early 1980s hadbeen fought largely in terms of technical learning. A coreissue was how to trade-off environmental and economicgoals. The degree of environmental protection that Ameri-can society could achieve was equated directly with thescope and stringency of environmental regulation. Debatesfocused on the design of medium-specific statutes and theenforcement of requirements in specific environmentalprograms. The goal of Reagan-era regulatory reformers wasnot to change the status of industry in the regulatory sys-tem, but to shrink the system itself.

The enduring legacy of Ruckelshaus’s second term wasto salvage the old policy system while initiating the searchfor a new one. He initiated a series of changes that can nowbe seen as a concerted effort to develop and integrate a ca-pacity for conceptual learning. This effort continued under

his successors, Lee Thomas and William Reilly. They (andmany others in the environmental policy community) hadbeen drawing conclusions from the U.S. experience since1970 and reassessing policy based on those conclusions.

What were the conclusions underlying this shift fromtechnical to conceptual learning? One conclusion was theneed to set priorities. It is fair to say that, by the mid-1980s,policy makers had begun to appreciate there were far moreproblems demanding attention than there were resourcesor political will to solve them. The environmental policy“problem” had grown from a concern with large industrialsources of air and water pollution to a far more complexset of issues: the generation and movement of hazardousmaterials, the effects of agriculture and energy productionand use, the risks from tens of thousands of chemicals, thelong-term effects of changes in climate and losses inbiodiversity, and many others. No matter how well theywere funded, environmental agencies could not respondeffectively to all of them. Ruckelshaus and others saw theneed for determining which problems deserved govern-ment attention, and in what order.

A second conclusion was that the single-medium focusof environmental laws and programs was inefficient andoften shifted problems from one area to another (Irwin1992). Air pollution rules for an industrial facility couldrequire controls costing far more per unit of pollution re-duced than controls on water discharges of the same pol-lutant. The separation of air, water, and waste strategiesoften shifted problems from one medium to another. Con-trolling pollution with scrubbers created sludge and a wastedisposal problem; disposal of hazardous wastes by incin-eration caused air pollution. The fragmentation of policystrategies began with the statutory framework and was re-inforced by professional specialization, program organi-zation in the EPA and in the states, congressional over-sight, and issue networks that grew up around each problem.Opportunities for overall efficiency and cross-media solu-tions were lost due to this fragmentation.

The third conclusion reached during the mid-1980s wasthat there was too much emphasis on controlling pollutionand not enough on preventing it. The core strategy of thetechnical-learning phase had been to control pollution atthe end of the pipe with required technologies. By the mid-1980s, this was changing. The core of conceptual learn-ing, Glasbergen suggests, is an effort to redefine goals andstrategies. Perspectives on problems change, objectivescome under discussion, and control strategies are adjusted.Policy makers want to deal with problems in more inte-grated ways. Artificial distinctions among environmentalmedia (air, water) and among policy sectors (energy, agri-culture) are viewed as constraints on effective problemsolving. People questioned the dominant direct-regulatorystrategy, leading to interest in new strategies based on


market incentives, information, and government–industrypartnerships (OTA 1995).

An important aspect of the move toward conceptuallearning was that people began to see environmental andeconomic goals as complementary rather than conflicting.Maarten Hajer describes this convergence of goals as theprocess of ecological modernization: “the political responseto the environmental dilemma that starts from the assump-tion that economic growth and the resolution of ecologicalproblems can be reconciled” (Hajer 1995, 170; Hajer 1996).Gradually, the assumption that economic and environmen-tal goals were a zero sum was viewed more skeptically.Companies such as 3M looked beyond legal complianceto find ways to reduce pollution and production costs whileincreasing the appeal of their products. Trade associationsbegan to develop codes of environmental conduct(Gunningham 1995; Nash and Ehrenfeld 1997). By the1990s, a “greening of industry” was under way (Press andMazmanian 1997). Porter and van der Linde (1995) andothers (such as DeSimone and Popoff 1997) stress the valueof high environmental standards for firms in search of eco-efficiency, expanded markets, and public acceptance.

How did U.S. policy reflect a shift toward conceptuallearning in the 1980s?

1. A change in the scale of problem definitions. Con-ceptual learning involves a search for broader definitionsof problems. In the United States, emphasis shifted fromhuman health concerns to the health of the larger ecologi-cal system (USEPA 1990). Instead of focusing on whatcomes out of a discharge pipe, policy makers began to con-sider how processes and raw materials could be changedto reduce the amount and toxicity of pollutants generated.New kinds of problems—global warming, deforestation,acid rain—shifted attention from national to global levels.

2. A search for integrated strategies. As policy makersrecognized the limits of the narrow problem definitionsused in technical learning, they searched for more inte-grated strategies, such as “cross-media” approaches. Anearly effort within the EPA, for example, was to analyzeenvironmental risks, not on the basis of environmentalmedium, but on the basis of geographic area, pollutant,and industrial sectors (Schmandt 1985). The EPA com-missioned the Conservation Foundation to produce a se-ries of reports on integrated pollution control, including amodel integrated statute (Davies 1990). Pollution preven-tion became a basis for policy integration. In 1989, theEPA created its Office of Pollution Prevention. Congresspassed the Pollution Prevention Act in 1990, and state agen-cies began to integrate prevention into regulatory and per-mitting decisions.

3. A growing use of consensus-based processes. Part ofthe evolution from purely technical to conceptual learningis dissatisfaction with adversarial and legalistic processes.

Policy makers responded to the turbulent environmentalpolitics of the early 1980s with efforts to reduce conflictand distrust. The techniques of alternative dispute resolu-tion were applied to a variety of situations (Bingham 1986),such as regulatory negotiation. That issue responded to whatPhilip Harter (1982) called the “malaise” of traditional rulemaking and was a forerunner of efforts to convene stake-holders for the EPA’s reinvention projects.

4. Attention to novel policy instruments. A central fea-ture of technical learning is reliance on direct regulationas a policy instrument. In conceptual learning, policy mak-ers become interested in alternatives and complements todirect regulation (see Stewart 1988). Market instrumentsare a good example: Applied mostly to air pollution, in-struments such as emissions trading, the bubble policy, andacid rain allowance trading incorporate a system of eco-nomic incentives into the existing regulatory framework.These innovations provide some flexibility from the uni-formity and technology basis of the technical model byallowing firms to trade pollution-control requirements anddistribute costs more efficiently (Hockenstein, Stavins, andWhitehead 1997). Information is also used explicitly as apolicy instrument. In the 1980s, to respond to such prob-lems as radon in homes, household chemical use, and leadin drinking water, the EPA and other health agencies turnedto risk communication, disclosure, and other information-based tools to influence behavior (OTA 1995).

Although the United States made significant strides indeveloping capacities for conceptual learning through the1980s, it made less progress in integrating conceptual learn-ing into mainstream policy making. The legal, bureaucratic,and institutional framework was still founded on technicallearning. Congress revised most of the environmental stat-utes between 1981 and 1990, but these changes largelyreinforced the reliance on technical learning that had char-acterized U.S. policy. There were exceptions—the Pollu-tion Prevention Act of 1990, the emphasis on non-pointsource water pollution in the 1987 Water Quality Act, theacid rain trading provisions of the Clean Air Act Amend-ments of 1990—but the overall thrust of what Kingdon(1984) calls the “political stream” was to reinforce the struc-ture that policy makers had already built in earlier envi-ronmental statutes (Fiorino 1996).

At about the same time, many European nations weredeveloping and integrating conceptual learning into theirlegal and administrative structures. Great Britain imple-mented cross-media regulation and adopted an integratedlaw for air and water pollution (Gouldson and Murphy1998; Owens 1990). The Dutch adopted a National Envi-ronmental Policy Plan that integrated planning across sec-tors, institutionalized cooperation between industry andgovernment, and incorporated new policy instruments, suchas product stewardship (Gouldson and Murphy 1998).


Sweden, Norway, and Denmark expanded their capacitiesfor cooperative action and policy integration (Janicke andWeidner 1997; Wallace 1995). Although the 1980s werean innovative time for the United States, especially inKingdon’s (1984) “policy” stream, many other industrialnations were able to more effectively integrate conceptuallearning into their national policy systems.

The recognition that a first generation of policies basedon technical learning would be inadequate for dealing withenvironmental problems over the long term was widespreadamong the industrial nations. This stimulated interest inconceptual learning—a search for new strategies based onreformulated policy objectives and problem definitions. Bythe late 1980s, though, it began to appear that conceptualchange was not enough, given the growing emphasis onsustainability, participation, and inclusion that reached fullarticulation in the 1992 Earth Summit in Brazil. By theearly 1990s, many nations were well on their way to defin-ing and developing capacities for engaging in a third typeof policy learning.

The 1990s: An Emerging Capacity for SocialLearning?

Social learning is a third form of learning, one thatGlasbergen asserts will have “direct implications for a newconcept of democracy” (176). It builds on technical andconceptual learning, but it takes policy makers in new di-rections, toward new forms of communication and inter-action. While the shift from technical to conceptual learn-ing focused on problem definitions, policy strategies, andthe interdependencies among them, the shift to social learn-ing turns more on the relationships among participants.Like the other forms of learning, social learning emergedin response to the dynamism of problems and changes inthe institutional, political, and physical environment(Kooiman 1993a). Most of the elements associated withconceptual learning apply to social learning—concern forintegration, attention to industrial processes and raw ma-terials, efforts to reconcile economic and environmentalgoals, concern with global issues, and so on. In other ways,social learning involves a fundamental shift “in the viewswhich policy makers hold with respect to the facilities thathave to be created to promote policy-oriented learning”(Glasbergen 1996, 182).

Glasbergen describes three aspects of social learning.The first is a high degree of structural openness. Technicallearning is based on control, with government as control-ler. By design, relationships between regulators and theirtargets are distant, formal, and adversarial. In contrast,policy systems with a capacity for social learning exhibitmore open patterns of governance, described as “social–political governance” (Kooiman 1993b) or “communica-tive governance” (Van Vliet 1993). Social–political gover-

nance consists of “more or less continuous processes ofinteraction between social actors, groups and forces andsemi-public organizations, institutions, or authorities”(Kooiman 1993b, 3).

Second, social learning requires a different approach toimplementation. The traditional model of implementation,which is based on hierarchy and control, is replaced with acooperative model in which government, industry, and oth-ers share responsibility for achieving policy goals (seeAyres and Braithwaite 1992; Teubner, Farmer, and Murphy1994). Lines between policy formulation and implemen-tation blur. There is an implicit trade-off in social learn-ing: Industry is given more influence in setting standardsand flexibility in deciding how to meet them, but it sharesmore responsibility with government for achieving goals.

A third aspect of social learning is a recognition of un-certainty in knowledge of problems and capacities for solv-ing them. Technical learning reflects an optimism aboutknowledge and problem solving. Environmental policyexpanded in the 1960s, Glasbergen observes, when “therewas still a strong belief in the constructability of society”(1996, 182). It was assumed that scientific analysis andresearch would provide answers to most questions, givenenough time and resources. This confidence in the powerof science was matched by a confidence in institutions.Congress would pass laws that agencies could translateinto rules to change polluters’ behavior. Pollution sourceswould comply under the threat of penalties.

Nearly three decades of experience have tempered thisoptimism. More and better research does not necessarilyresolve political debates over science. Bureaucracies arenot always able to carry out the complex tasks that areassigned to them. Social learning reflects an awareness ofthese uncertainties and limitations. Rather than prove ascientific conclusion, for example, social learning stressesthe need for communication among stakeholders to deter-mine what action should be taken in the absence of con-clusive scientific evidence. One illustration is the precau-tionary principle, which European governments have usedto decide environmental policies “where the consequencesof alternative policy options are not determinable within areasonable margin of error and where potentially high costsare involved in taking action” (Weale 1998, 310).

The growing interest in social learning in the 1990s wasa product of many influences. Dissatisfaction with the typi-cal relationships in U.S. environmental regulation waswidespread throughout the decade (see NAPA 1995, 1997;PCSD 1996; Ruckelshaus 1998; White House 1995). AsRichard Rose argues, dissatisfaction stimulates learning,as policy makers search for lessons to draw from their ownexperience or that of others. People turned to the Euro-pean experience, especially Scandinavia and the Nether-lands, for examples of cooperative, integrated policy sys-


tems with a capacity for dialogue. In addition, emphasison the social component of sustainability at the UnitedNations Conference on Environment and Development(UNCED) in 1992 stimulated international interest in so-cial learning. The UNCED blueprint for sustainability,Agenda 21, includes recommendations about participation,dialogue, equity, and collaboration (Lafferty 1998). Thisemphasis is reflected in the report of the President’s Coun-cil for Sustainable Development (PCSD 1996), which ech-oes themes of Agenda 21 regarding dialogue and the other“social” aspects of sustainability.

Yet social learning requires new capacities. It builds onthe cognitive and structural foundations of technical learn-ing and on the reformulation of goals and strategies thatoccurs under conceptual learning. But it also involves aneffort to overcome many constraints of technical learning,especially as it has evolved in the United States. Experi-ence with two initiatives of the U.S. Environmental Pro-tection Agency undertaken in the mid-1990s illustrate theeffort to integrate social learning onto the existing regula-tory system. The Common Sense Initiative and Project XLstressed cooperation through improved communication andinteraction among stakeholders. Both reflected a dissatis-faction with the current hierarchical, inflexible, fragmentedregulatory system. Both recognized limits in regulators’information capacities and the need to bring diverse stake-holders (including regulated firms) into policy making. Thepurpose in both initiatives was to move past old relation-ships based on bureaucratic formalism, legalism, andadversarialism to new patterns of interaction.

Because of design flaws and disagreement on goals andprotocols, both initiatives encountered problems. However,they are worth examining because they reflect an effort toapply social learning. Their design and the problems theyencountered illustrate both the desire to incorporate sociallearning and the institutional, legal, and other barriers thatarise in efforts to integrate a new type of policy learning.

Common Sense Initiative. The Common Sense Initia-tive (CSI) was the most comprehensive attempt the EPAhad ever made to implement a program based on industrysectors. Six sectors were selected for projects: metal fin-ishing, electronics and computers, iron and steel, printing,petroleum refining, and auto assembly. For each sector,the EPA convened a panel of stakeholders representing arange of interests—companies, trade associations, environ-mental groups, state/local officials, and others. The EPAformed a CSI Council to guide the overall initiative; eachsector panel was constituted as a subcommittee. The EPAidentified six issues for attention in each sector: regula-tion, pollution prevention, reporting, compliance, permit-ting, and technology. The stated goal was to achieve“cleaner, cheaper, smarter” environmental protection(USEPA 1994, 1998a, 1998b).

CSI illustrates an effort to build on conceptual learningand to integrate social learning into national environmen-tal policy. A core objective was to move from the existing,deterrence-based regulatory system to one based on coop-eration. In addition, CSI was designed to overcome theconventional distinctions among the air, water, and wasteprograms. The program was broken down by industry sec-tor (for instance, metal finishing) and functional issue (forinstance, pollution prevention) rather than by programmaticarea. From the start, it was not clear how this would bedone—it was presumed that stakeholders would find a wayto reconcile economic and environmental goals in thecourse of their deliberations. In these respects, CSI incor-porated efforts that had been made to that point to imple-ment conceptual learning into U.S. environmental policy.

What is most revealing about CSI as a case in sociallearning is how the government structured the relationshipsamong participating groups. The CSI Council and subcom-mittees were based on a principle of horizontal policymaking. The EPA sat down in face-to-face talks with 20–25 stakeholders, looked at management and regulatory is-sues across the sector, worked through the concerns andideas of all stakeholders, and attempted to reach consen-sus on areas for change. The lines between government,regulated firms, and others would, it was assumed, bemuted; participants would overcome narrow self-interestto promote the general good. The CSI design reflected anexpectation that U.S. stakeholders could build the kinds ofrelationships that had been achieved in Dutch industry-sector negotiations, which Glasbergen (1996), Van Vliet(1993), and others cite as an example of social learningapplied to environmental policy.

Project XL. The second case in social learning (XLstands for excellence and leadership) was announced asone of President Clinton’s proposals for “StreamliningEnvironmental Regulation” (USEPA 1995; White House1995). Project XL invited companies to propose alterna-tive regulatory strategies when they could demonstrate thatsuch strategies would achieve better environmental resultsthan could be expected under existing law. The premisewas that more flexible regulation would give society bet-ter environmental protection at less cost, so long as firmsremain accountable for their performance and are willingto collaborate with the public. The program involved atrade-off: Regulated firms would be given the flexibilityto implement alternative strategies if they could producegreater environmental benefits.

Once a proposal was approved the applicant was invitedto work with the EPA, state and local authorities, and envi-ronmental and community groups to develop a final projectagreement. This agreement was executed between the regu-latory agencies and the company, in consultation with otherstakeholders. It described what steps the company would


take to improve its performance, the regulatory exceptionsthe agencies would provide, the basis for measuring per-formance, and the expected environmental benefits, amongother topics. Once federal and state regulators approvedand the support of the other stakeholders was obtained, theagreement legally authorized the company to implementits program.

The assumptions and principles of social learning runthroughout Project XL. The stated goal of the program wasto replace a command-driven system with one in whichcompanies have discretion to develop solutions that ex-ceed those of existing law. The evolving model was notone of government telling companies what to do and howto do it, but of setting goals and working cooperatively todevise more effective, efficient, and socially responsibleways of achieving them. Although the role of local stake-holders was unclear in the design of Project XL, it wasunderstood that they had a role in shaping facility demon-strations and advising agencies on project agreements. LikeCSI, Project XL was billed as a sector-based, multi-stake-holder, consensus-based process (in terminology that ischaracteristic of social learning) in which direct commu-nication and interaction among the participants would leadto “win-win” solutions (USEPA 1998a).

Neither program worked fully as intended (Davies andMazurek 1996; GAO 1997; NAPA 1997). CSI was plaguedby disagreement on goals and protocols, a definition ofconsensus that gave participants a virtual veto, and uncer-tainty in policy goals. Progress in Project XL was hurt byambiguity over stakeholders’ roles (especially communitygroups), disagreements within the EPA, and disputes overwhat constituted “superior” environmental performance.Although Project XL has recently produced interestingresults and offers several lessons on how to innovate inregulatory policy (see USEPA 1999), its effects have beenfar less sweeping than were originally expected. An ob-stacle in both projects was a mismatch between the goalsof innovation and the statutory constraints. One study con-cluded that “The lack of a statutory basis for environmen-tal initiatives or programs always foreshadows difficulty”(Davies and Mazurek 1996, 3; see also Mank 1998). Theinflexible legal framework, based firmly on technical learn-ing, inhibited efforts to integrate conceptual and sociallearning into the policy system.

A difficulty in both programs, especially in CSI, wasachieving the needed changes in participant roles and rela-tionships. Here was the EPA, the long-time regulator, aninstitution whose legal mandates and political circum-stances had forced it into an adversarial relationship withindustry, playing the role of facilitator with the very inter-ests whose behavior it had sought to control. Here werethe representatives of U.S. industry, far more accustomedto seeing the EPA as an issuer of rules and an enforcer,

being asked to sit down cooperatively with that same EPAin a public forum and agree on better approaches to envi-ronmental protection. At the same table were environmen-tal advocacy and justice groups, who generally were skep-tical of this apparent transformation in the EPA’s role andits relationship with industry. CSI and Project XL illus-trate attempts to integrate social learning. In both, the in-tent was to develop new forms of communication and in-teraction among stakeholders, achieve more flexibility thanthe existing framework allowed, and move from adversarialto cooperative relations. Their mixed success attests to thedifficulty of integrating social and conceptual learning intoa system founded on technical learning.

Policy Learning and the EnvironmentAt the heart of a learning model is the notion that policy

makers and other actors can adjust to changing circum-stances and to knowledge gained through experience. Thisarticle has presented the elements of a learning approachand applied it to the experience of the United States. Thisconclusion summarizes that experience, then considerswhat lessons may be drawn from a learning approach inthinking about the future.

Policy makers in the 1980s adapted to deficiencies intechnical learning by incorporating conceptual learning:emphasizing consensus-based processes; pollution preven-tion; cross-media problem-solving; global issues; and ef-forts to reconcile environmental and economic goals. Allof this took place within an institutional framework thatwas based on technical learning. Since about 1990, therehave been efforts to implement social learning within thissame framework. The mixed success of initiatives like CSIand Project XL illustrate the difficulties of integrating newlearning styles under such conditions.

John Kingdon’s framework (1984) on policy streamssuggests an important conclusion about the 1980s: Theshift to conceptual learning was led by the policy andproblem streams, while the political stream lagged. EPAadministrators led efforts to integrate policy, apply theconcept of risk, stress international issues, and use con-sensus-based approaches. Many state-level agencies ledthe move toward pollution prevention. Such think tanksas Resources for the Future, the Conservation Founda-tion, and the World Resources Institute provided the in-tellectual capital for conceptual learning. The Environ-mental Defense Fund led the effort to incorporate marketincentives into the acid rain trading program. A leadingstatement of conceptual learning, the EPA Science Advi-sory Board’s Reducing Risk (1990), was the work of anexpert panel. Most of the innovation associated with con-ceptual learning came from policy professionals, not fromCongress or the president.


It also appears that the problem stream drove the searchfor new objectives and strategies in the 1980s. My earlierdiscussion of the shift to conceptual learning describedchanges in the problem stream: the growing complexityand interdependence of air, water, and waste issues; theemergence of issues with global, long-term, and irrevers-ible consequences; the sharply increasing marginal costsof a pollution control compared to a pollution prevention-based approach; and the dynamism among problems andlikely solutions. To most people in the environmental policyfield, business as usual based on technical learning wasinsufficient for dealing with a new generation of problems.The status quo would not suffice. Environmental policymakers adapted with new goals and strategies based onconceptual learning.

By the late 1990s, the U.S. environmental policy sys-tem was at something of a crossroads. Although supportfor environmental goals remained strong, there was dis-satisfaction with the means used to achieve them. Thisquestioning of basic strategies continued the efforts at con-ceptual learning that had begun in the early 1980s. We stillsee the stress on integration, the efforts to reconcile envi-ronmental with economic goals, a concern with global is-sues, and the search for ways to prevent pollution. What isdistinctive about the 1990s is the concern about relation-ships among interests, the institutional foundations for thoserelationships, and the obstacles they pose to problem solv-ing. Like Moliere’s character, who realized that all his lifehe had been speaking prose without knowing it, the cur-rent generation of policy makers and reformers have beencalling for a better capacity for social learning without us-ing the term. The policy system is evolving—slowly andfitfully—toward a new learning model, one that will re-quire a greater capacity for social learning.

The nations that will be most successful at coping withenvironmental problems in the future will be those that areable to develop and integrate their capacities for differentkinds of policy learning. A capacity for technical learningis a necessary but not sufficient condition for success. TheUnited States was a leader in implementing a system basedon technical learning, because it built on the strengths ofthe policy system: impressive scientific and technical re-sources; a highly evolved legal system; a relatively capableand efficient bureaucracy; and a sense that polluters shouldbe held accountable for damages they cause. As Janickeand Weidner observe (1997, 301), the United States’ inno-vations in the 1970s provided (along with, they argue,Sweden and Japan) a model for other nations as they re-sponded to evidence of environmental degradation.

The nations that have been most successful at integrat-ing the various forms of learning are, not surprisingly, thosethat attract interest as models for the United States. TheNetherlands and Denmark in particular, and Sweden and

Norway to a slightly lesser degree, have been held up asexemplars not only of effective environmental policy butof a long-term capacity for technology innovation (Wallace1995), sustainability planning (Janicke and Jorgens 1997;Meadowcroft 1997), and sector-based innovation(Gouldson and Murphy 1998). The reasons for their suc-cess are complex, but they certainly are a combination ofsize, geography, political culture, institutions, and history.Cultural and institutional differences do matter. In his bookon environmental discourses, John Dryzek (1997) con-cludes that a consensus-based political culture built oncorporatist traditions offers the most fertile ground for eco-logical modernization and sustainable development, the twoof his discourses that most fully capture the concepts ofconceptual and social learning.

The Netherlands presents an especially interesting ex-ample of a nation that has developed and integrated its ca-pacities for policy learning relatively successfully. Untilthe early 1980s, it exemplified a system based on techni-cal learning. By the beginning of that decade, however, itwas increasingly accepted that the existing approach wouldnot suffice over the long term (Bennett 1991). Over thenext several years, the Dutch undertook a crash course inconceptual and social learning. It was not a seamless tran-sition. Efforts to implement the first National Environmen-tal Policy Plan in 1985 were controversial. The industryperceived that the government was moving too fast andhad consulted too little with affected sectors. But the Dutchpolicy system showed a capacity to learn: By the secondand third rounds of the plan, the needed trust and coopera-tion had been developed to support the integration of anew form of policy learning.

Given its small size, tradition of state planning, inten-sity of pollution, and consensus-based political culture, theNetherlands was well-suited to developing and integratingits learning capacities. The same can be said for the Scan-dinavian countries. In contrast, larger, more diverse fed-eral systems with less tradition of cooperation among in-dustry and government, such as the United States orGermany, will find it difficult to achieve the same level ofsocial learning in environmental policy. The challenge inthose countries may be to think at different levels of gov-ernance. In the United States, where observers have oftencompared states according to their capacities for technicallearning, there are differences in capacities for other formsof learning as well. Minnesota, for example, exhibits a ca-pacity for integrating conceptual and social learning thatis probably better than any other state. New Jersey, whichhas been known for years for its stringent regulatory sys-tem, has taken steps to increase its capacities for concep-tual and social learning by experimenting with facilitywidepermitting, pollution-prevention planning, and govern-ment–industry cooperation (Rabe 1995).


The task of integrating conceptual and social with tech-nical learning poses many challenges, but two stand out.The first is redesigning the regulatory system so that ac-tors are able to respond to lessons learned. Part of learningis a capacity for change. Here the differences among formsof learning matter. Technical learning may be an effectiveway for policy systems to respond initially to complex,technical problems. It allows us to break problems intomanageable parts, establish government’s authority, andcreate knowledge needed to devise solutions—all neces-sary stages in developing a long-term ability to addressenvironmental problems.

At the same time, the reliance of technical learning onhierarchy and control may impede learning by limiting theability of actors in a policy system to change behavior basedon what is learned. Many complaints about U.S. regula-tion focus on the centralization and lack of flexibility char-acteristic of technical learning. Once policy is defined inrules, the system is designed to make people conform.Opportunities for discretion are controlled, a subject thatBardach and Kagan (1982) address so well in their bookon regulation.

The point is well-documented in the literature on innova-tion: Organizations that are run tightly from the top and al-low little room for creativity and judgment at middle andlower levels are the least innovative. David Wallace makesthis point in his analysis of the organizational literature withrespect to the capacity for environmental innovation in firms(1995, 11–22). Why then, at a time when most everyoneagrees on the need for continuous improvement and behav-ior that goes “beyond compliance,” do we continue to pro-tect the environment with the systematic equivalent of thenoncreative, noninnovative, nonlearning organization?Throughout efforts to implement CSI and Project XL, theprescriptive statutory framework was cited as an obstacle.The same obstacles have been cited since U.S. policy mak-ers began to develop a capacity for conceptual learning inthe 1980s. Whether the goal was pollution prevention, cross-media planning, risk-based planning, or sustainable devel-opment, the specifications of the principal environmentallaws have impeded the ability of government and others tochange their behavior based on experience.

A second challenge is to improve the quality of dia-logue. In Environmental Policy and Industrial Innovation,Wallace (1995) argues that the patterns of governance andthe quality of dialogue in a regime determine the capacityfor innovation far more than the specific policy instrumentsused. Government must enjoy some independence fromindustry influence if it is to maintain pressure for improvedperformance. At the same time, there must be a reasonabledegree of trust, potential for collaboration, sharing of in-formation, and respect for mutual competence among gov-ernment and industry to sustain the level of dialogue needed

to support technology innovation. Wallace rates the UnitedStates high on independence from industry, but low on thequality of dialogue, at least in comparison to three (Den-mark, the Netherlands, and Japan) of the five nations thathe examines in the study. In essence, Wallace is rankingthese other countries higher in their capacity for sociallearning and, thus, in their ability to promote innovation.

Social learning implies a different, though not neces-sarily lesser, role for the state. Indeed, Wallace and others(such as Janicke) give credit to the Netherlands, Denmark,and Sweden for sustaining independent, authoritative gov-ernment that maintains pressure on industry while also cre-ating the conditions that foster a productive dialogue. So-cial—and to some degree conceptual—learning alsoreflects many aspects of the “new governance” in publicadministration, especially their emphasis on networks,partnerships, and the use of alternative policy instrumentsin addition to direct regulatory control by the state (Petersand Pierre 1998). Many issues regarding the legitimacyand effectiveness of new forms of governance apply to theenvironmental policy debate as well. My arguments in fa-vor of social learning are not meant to imply a weakeningof governmental authority, but the need for capacities toexercise this authority in different ways.

Can the United States achieve the same level of profi-ciency at social learning as these other countries? Prob-ably not, at the national level. The differences in size, cul-ture, and institutions may be too profound. Although theUnited States can learn much from others (for example,from the Dutch model of sector-based targets and integratedplanning), we cannot expect to transplant one system ofgovernance into another environment. Surely, however, theU.S. system can improve its capacity for constructive dia-logue and cooperative governance in ways that are consis-tent with its own experience: reaching a better understand-ing of the factors that affect trust among actors; redesigningprocesses and institutions in ways that promote shared re-sponsibility and participation; promoting collaborativeproblem solving at local levels; and developing better, moreobjective methods for measuring environmental perfor-mance are some steps that come to mind.

Further analysis of policy learning and the learningcapacities examined here would suggest a more detailedagenda for change. Even before thinking about change,however, it is clear that a learning approach may help toexplain how U.S. environmental policy evolved as it did,to analyze its strengths and weaknesses, to compare na-tional experiences and capacities, and to underscore a needfor systematic lesson drawing from our experience andthat of others. In a policy arena known for political con-troversy and frequent stalemate, a learning approach mayencourage us to take a new, more optimistic view of anold policy landscape.


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