environmental policy as learning: a new view of an old landscape

Environmental Policy As Learning: A New View of an Old LandscapeAuthor(s): Daniel J. FiorinoSource: Public Administration Review, Vol. 61, No. 3 (May - Jun., 2001), pp. 322-334Published by: Wiley on behalf of the American Society for Public AdministrationStable URL: http://www.jstor.org/stable/977603 .

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Daniel J. Fiorino U.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 political conflict. At the same time, however, policy makers have shown a capacity to learn from their own and others' experience. This article examines U.S. environmental policy since 1970 as a learning process 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 high degree of technical and legal proficiency, but also narrow problem definitions, institutional fragmentation, and adversarial relations among actors. In the 1 980s, growing recognition of deficiencies in technical learning led to a search for new goals, strategies, and policy instruments, in what may be termed conceptual learning. By the early 1990s, policy makers also recognized a need for a 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 of learning. Efforts to integrate capacities for conceptual and social learning in the United States have had mixed success, however, because the institutional and legal framework for environmental policy still is founded on technical learning.

Do governments and institutions learn? Are policy makers, activists, experts, and others capable of drawing lessons from their experiences and applying it to problems they face? A persuasive literature in public policy argues that institutions and people within them do learn, and that a learning model is a useful way to understand and explain policy change. This learning approach has been proposed to complement more traditional approaches to policy change that are based on political conflict, approaches that depict government and policy as driven largely by societal conflicts and pressures.

Approaches to policy change based on a learning model "generally hold that states can learn from their experiences and that they can modify their present actions on the basis of their interpretation of how previous actors have fared in the past" (Bennett and Howlett 1992, 276). A learning model suggests a more positive view of policy making than does the traditional, conflict-based model. The notion that

*The views expressed in this article are those of the author and not necessarily those of the U.S. Environmental Protection Agency.

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

governments and policy makers learn over time suggests a purpose to policy making. A learning approach stresses knowledge acquisition and use. Policy makers are seen less as passive forces driven by political and interest group pressures than as sources and implementers of ideas, information, and analysis that influence choices.

This article applies a learning model to U.S. environmental policy, with a focus on pollution control. Environ- mental policy making is knowledge intensive and complex, involving scientific, technical, legal, policy, and social issues. How people obtain, evaluate, and use knowledge is important. Many aspects of politics and policy-definitions of problems, analytical tools and methods, differences between lay and expert perceptions, perceived conflicts

Daniel J. Fiorino is the director of the Performance Incentives Division in the Office of Policy, Economics, and Innovation at the U.S. Environmental Pro- tection Agency. He directs projects on performance-based environmental management, performance measurement, and regulatory innovation and is the program manager for the EPA's National Environmental Performance Track. He is the author of Making Environmental Policy (California, 1995) and a co-author of Managing for the Environment (Jossey-Bass, 1999). Email: Fiorino.Dan @epamail.epa.gov.



between economic and environmental goals-have changed over time. Nations at similar stages of development face similar issues and move through comparable phases in environmental problem solving (Janicke 1996; Janicke and Weidner 1997). Thus, environmental policy presents an opportunity to examine how policy makers have or may be able to learn from their experience.

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

learning process? An early application of a learning approach was Hugh Heclo's Modern Social Politics in Brit- ain and Sweden (1974). In that work, Heclo challenged the prevailing view among political scientists that changes in public policy were largely the product of societal conflict, arguing that an approach "focused on knowledge acquisition and utilization could yield better explanations and understanding about policies than existing conflict-based theories" (276). Although the resolution of conflicts among societal interests may explain periods of fundamental change, much of what occurs in between may be seen as efforts by policy makers to learn and to apply the lessons of that learning.

Heclo described policy learning as "a relatively enduring alteration in behavior that results from experience" (306). Policy makers learn in response to changes in the external 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," Richard Rose presents learning as a response to dissatisfaction, which in turn stimulates a search for solutions: "actions that will reduce the gap between what is expected from a program and what government is doing" (1993, 50). Dis- satisfaction with the status quo may come from many sources: changes in problems, the emergence of new con- stituency groups, a catastrophic event, globalization of domestic issues, budget constraints, and so on. What mat- ters is that there is enough of a sense of disruption that policy makers are led to search for ways to reduce dissatisfaction within the policy system.

Of course, the differences between conflict-based and learning-based models are not always clear cut. Any policy system will experience periods of conflict, especially when dissatisfaction produces demands for fundamental change. These periods of change may redefine the context in which learning occurs. In U.S. environmental policy, for example, especially high levels of conflict between the executive and legislative branches in the early 1980s (when a Republi- can president was paired with a Democratic Congress) and mid-i 990s (when the reverse situation existed) stimulated efforts 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 terms of conflict undervalues the substantial amount of constructive learning that occurs in a policy system over time. Be- neath the obvious political conflict, a great deal of learning has been going on.

Thinking of policy making as a learning process raises several questions (Bennett and Howlett 1992). First, who is doing the learning? Should we think of learning as something that occurs only among government officials, or is there a broader set of influential actors who are part of the learning process? The literature suggests a range of answers, from only elected officials, to appointed and career government officials, to a much broader set of nongovernmental actors (lobbyists, advocacy groups, litigators, journalists) and "epistemic communities" of policy experts. This article takes a broad view, including anyone who may have influence over policy choices as part of the learning process. In the environmental arena, this includes elected officials and staff, political appointees, agency staff, the media, advocacy groups, researchers, regulated firms, and international bod- ies such as the United Nations Environment Program.

Second, what is learned? A principal issue is whether policy makers learn only about the means or instruments of policy or whether they learn about the ends or goals of policy as well. This article proposes a broad conception of what is learned. Certainly the participants in environmental policy making have shown a capacity to learn about means and instruments. Examples in the United States are the growth of emissions trading, application of alternative dispute 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 about goals as well. The goal of pollution control was expanded to encompass pollution prevention and risk management in the 1980s. Since the Brundtland Commission report in 1987, and the Rio de Janeiro Earth Summit in 1992, people recognize the concept of sustainable development as a new, more inclusive goal for environmental policy.

Third, what are the results of learning? This article takes the view that "learning does not occur unless there is some kind of policy change which results from the learning process" (Bennett and Howlett 1992, 285). An organization may have effective mechanisms for collecting intelligence about shortcomings in existing policies, but it may not have mechanisms for translating this intelligence into new forms of behavior or structures that allow for changes in behavior. For example, policy systems founded on what is described as technical learning may possess mechanisms for gaining feedback about the effects of policies, but may lack the flexibility to respond. In particular, this article argues that the prescriptive environmental statutes passed in the 1970s and 1980s limited the United States' capacity to adapt to demands for change in the 1990s.

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



This does not mean the policy response to learning must be immediate. Indeed, it may take decades for policy makers to incorporate information about new strategies into actual policy. An example is the process by which market- based incentives have gradually been incorporated into pollution control programs. A crude form of air emissions trading was first adopted in the "offset" policy of the mid- 1970s, but broader air emission trading concepts were implemented throughout the 1980s. Incorporation of trading provisions into water pollution policies has proceeded at a much slower pace. Still, the gradual adoption of market trading concepts into U.S. pollution control may be viewed as a successful case of policy learning.

This article distinguishes three kinds of policy learning, based on Pieter Glasbergen's (1996) work on environmental policy in the Netherlands. Glasbergen's learning types are developmental; one often evolves into another. U.S. environmental policy over the last 30 years may be seen as a partial evolution from one type into others. They also are cumulative; each builds on experience with a predecessor and complements rather than replaces it. The learning model may be applied to all aspects of environmental policy making: problem definitions, the organization of responsibilities within government, the relationships among actors, and the choice of policy instruments for responding to problems. Glasbergen proposes the learning model not as an alternative to the traditional analysis of policy making that is shaped by political conflict, but as a supplemen- tary perspective to enhance our understanding and to chart a path for the future.

Glasbergen stresses the need for "continuing initial re- flection on the policy process" (175). Like most writers on policy learning, he recognizes the role of "reflexiv- ity" in contemporary environmental policy (see Giddens 1990; Teubner 1983; Orts 1995). Two aspects of his approach deserve emphasis. First, he takes a broad approach to what is learned. Learning relates not only to instruments (emissions trading) or analytic tools (cost-benefit analysis), but also to problem definitions, policy goals, and strategies. Second, he stresses the contexts of learning, especially relationships among actors, the institutional aspects of policy processes, and legal frameworks. The emphasis on context leads Glasbergen to distinguish three types of policy learning:

Technical learning consists of a search for new policy instruments in the context of fixed policy objectives. Change occurs without fundamental discussion of objectives or basic strategies. Policy makers respond to demands for change with "more of the same" kinds of solutions that they adopted in first responding to environmental problems: more regulation, oversight, and enforcement.


Conceptual learning is a process of redefining policy goals and adjusting problem definitions and strategies. Policy objectives are debated, perspectives on issues change, strategies are reformulated. New concepts (pollution prevention, ecological modernization, sustainability) enter the lexicon.

Social learning focuses on interactions and commu- nications among actors. It builds on the cognitive capacities of technical learning and the rethinking of objectives and strategies that occurs in conceptual learning, but it emphasizes relations among actors and the quality of the dialogue.

In addition to considering the applicability of a learning model, this article assesses the relevance of technical, conceptual, and social learning to the U.S. experience. It argues that the U.S. environmental policy system is founded on technical learning. Beginning in the mid-1980s, a recognition of the deficiencies of the existing system led policy makers to search for new strategies and policy objectives. This search and the changes that resulted resemble conceptual learning. By the 1990s, continued dissatisfaction with aspects of environmental regulation, especially adversarial relationships and a lack of capacity for cooperative problem-solving, led to efforts to innovate through social learning. Thus, the history of contemporary environmental policy may be seen as a process of evolution from technical, to conceptual, to social learning. But it is only a partial evolution. Institutionally and legally, U.S. policy is still grounded in technical learning. Conceptual learning has been integrated only partially into national policy making; efforts to integrate social learning have encountered even more difficulties. This article argues that to be successful, a policy system must develop and integrate 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 key respects, the evolution of U.S. environmental policy over the last three decades. They also help to explain the difficulties that U.S. policy makers have encountered in adapt- ing the policy system to the demands of what Glasbergen calls conceptual and social learning. Second, by understanding the different types of policy learning, especially the characteristics of effective conceptual and social learning, we can better understand how this country's environmental policy system should be changed. This approach also offers a framework for drawing lessons about cross- national experiences, a point that will be developed later.

The Foundation: U.S. Environmental Policy As Technical Learning

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



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

U.S. environmental policy making has closely followed the technical model. The legal framework for pollution control that began with the Clean Air Act of 1970 embod- ied technical learning, as did laws regulating drinking water (1974), hazardous waste (1976), and waste cleanup (1980), and their reauthorized versions in the 1980s (Fiorino 1995; Portney 1990). Consider the characteristics of the U.S. policy system:

1. Definitions of environmental problems. Policy makers defined problems almost entirely on the basis of the pathways in which harmful exposures occurred. The fragmented legal framework defined and reinforced compart- mentalization of problems along these lines (Andrews 1997; Marcus 1980). Authorities and organizations were created to deal separately with air, water, waste, toxics, and pesticides. Policy responses focused almost entirely on identifiable signs of pollution (for instance, end-of-pipe water 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 federal government 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 the EPA (Marcus 1980). This undoubtedly strengthened the national capacity for dealing with environmental issues, because it created a visible and (with passage of national environmental laws in the 1970s) legally powerful agency that could rein in industrial polluters. At the same time, however, this concentration of authority and responsibility removed much of the internal advocacy and legal obligation to protect environmental values from other federal agencies. The EPA now had significant authority over industrial and other sources of pollution, narrowly defined, but it was isolated administratively from federal policies with a major environmental im-

pact-land management, agriculture, transportation, and public health.

3. Policy strategies and institutional relationships. A definitive characteristic of technical learning, and of U.S. environmental policy in its early decades, is its reliance on direct regulation, which emphasizes hierarchy and control. Hierarchy begins with Congress as the source of delegated authority to an agency. It continues with the internal allocation of responsibility, in which the agency's political leadership defines goals and decision premises for lower levels. The agency exercises authority over the targets of regulation, principally industrial enterprises and public entities such as sewage treatment plants and local or state governments. The strategy is to control behavior by issu- ing rules, overseeing compliance, and applying sanctions if there is evidence of noncompliance (Kagan and Scholz 1984). Indeed, modern environmental regulation conforms closely to Max Weber's classic model of bureaucratic organization-extensive hierarchy, with well-defined superior-subordinate relationships; elaborate rules, substantive and procedural; heavy reliance on documentation; and a division of labor that fragments problem-solving capacities (Fiorino 1997).

4. Separation of environmental goals from other goals. By adopting a narrow view of environmental problems, policy makers separated environmental from economic goals. Part of technical learning is the assumption that economic and environmental goals conflict. Opponents of expanded regulation argued that any expenditure on pollution control was a direct loss for economic growth. Advo- cates of regulation assumed that growth translated directly into environmental damage. Policy makers struggled to balance two apparently irreconcilable goals, and the political debate focused on the conflicts between them.

5. Relationship with industry and other stakeholders. A characteristic of technical learning is legalistic and adversarial relationships between regulators and industry. The regulated entity is seen less as a participant in policy making than an object of regulatory authority. The relationship between regulator and industry is characterized by legal formalization and (as a consequence) distrust (Bardach and Kagan 1982). Although this adversarial relationship was later seen as a weakness of the U.S. approach, it was deliberately built into the design. Reacting to evidence of industry capture of economic regulators (for example, the Interstate Commerce Commission), policy makers designed a system based on "adversarial legalism" (Kagan 1995).

Technical learning may be seen as the typical first stage in the evolution of environmental problem solving. Com- parative analyses show that most Western nations initially approached environmental problems through technical learning (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 other nations strove to emulate. Over time, however, policy makers recognized the limits of an approach based purely on technical learning. This recognition stimulated a search for new capacities, presented in the next section as conceptual learning.

The 1980s: From Technical to Conceptual Learning

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

Traumatic events often initiate a search for new policy models and objectives. The early 1980s was a traumatic period for U.S. environmental policy. The Reagan administration arrived in Washington in 1981, convinced it had a mandate 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 on nearly all fronts. When the administration's strategy for legislative change was frustrated by the Democratic Con- gress, it turned to an administrative strategy of cutting environmental budgets, trimming enforcement, instituting cost-based review of agency rules by the Office of Man- agement and Budget, and initiating rules to grant regulatory relief to regulated firms. By early 1983, however, it was clear the administration had misjudged public support: Anne Gorsuch was forced to resign and William Ruckelshaus returned for a second tour as administrator (Vig 1997).

The shift in U.S. environmental policy from solely technical to conceptual learning began with Ruckelshaus's re- turn in 1983. The political battles of the early 1980s had been fought largely in terms of technical learning. A core issue was how to trade-off environmental and economic goals. The degree of environmental protection that Ameri- can society could achieve was equated directly with the scope and stringency of environmental regulation. Debates focused on the design of medium-specific statutes and the enforcement of requirements in specific environmental programs. The goal of Reagan-era regulatory reformers was not to change the status of industry in the regulatory system, but to shrink the system itself.

The enduring legacy of Ruckelshaus's second term was to salvage the old policy system while initiating the search for a new one. He initiated a series of changes that can now be seen as a concerted effort to develop and integrate a capacity for conceptual learning. This effort continued under


his successors, Lee Thomas and William Reilly. They (and many others in the environmental policy community) had been drawing conclusions from the U.S. experience since 1970 and reassessing policy based on those conclusions.

What were the conclusions underlying this shift from technical to conceptual learning? One conclusion was the need to set priorities. It is fair to say that, by the mid- 1980s, policy makers had begun to appreciate there were far more problems demanding attention than there were resources or political will to solve them. The environmental policy "problem" had grown from a concern with large industrial sources of air and water pollution to a far more complex set of issues: the generation and movement of hazardous materials, the effects of agriculture and energy production and use, the risks from tens of thousands of chemicals, the long-term effects of changes in climate and losses in biodiversity, and many others. No matter how well they were funded, environmental agencies could not respond effectively to all of them. Ruckelshaus and others saw the need for determining which problems deserved government attention, and in what order.

A second conclusion was that the single-medium focus of environmental laws and programs was inefficient and often shifted problems from one area to another (Irwin 1992). Air pollution rules for an industrial facility could require controls costing far more per unit of pollution re- duced than controls on water discharges of the same pollutant. The separation of air, water, and waste strategies often shifted problems from one medium to another. Con- trolling pollution with scrubbers created sludge and a waste disposal problem; disposal of hazardous wastes by incin- eration caused air pollution. The fragmentation of policy strategies began with the statutory framework and was reinforced by professional specialization, program organization in the EPA and in the states, congressional oversight, and issue networks that grew up around each problem. Opportunities for overall efficiency and cross-media solutions were lost due to this fragmentation.

The third conclusion reached during the mid- 1980s was that there was too much emphasis on controlling pollution and not enough on preventing it. The core strategy of the technical-learning phase had been to control pollution at the end of the pipe with required technologies. By the mid- 1980s, this was changing. The core of conceptual learning, Glasbergen suggests, is an effort to redefine goals and strategies. Perspectives on problems change, objectives come under discussion, and control strategies are adjusted. Policy makers want to deal with problems in more integrated ways. Artificial distinctions among environmental media (air, water) and among policy sectors (energy, agriculture) are viewed as constraints on effective problem solving. People questioned the dominant direct-regulatory strategy, leading to interest in new strategies based on



market incentives, information, and government-industry partnerships (OTA 1995).

An important aspect of the move toward conceptual learning was that people began to see environmental and economic goals as complementary rather than conflicting. Maarten Hajer describes this convergence of goals as the process of ecological modernization: "the political response to the environmental dilemma that starts from the assumption that economic growth and the resolution of ecological problems can be reconciled" (Hajer 1995, 170; Hajer 1996). Gradually, the assumption that economic and environmental goals were a zero sum was viewed more skeptically. Companies such as 3M looked beyond legal compliance to find ways to reduce pollution and production costs while increasing the appeal of their products. Trade associations began to develop codes of environmental conduct (Gunningham 1995; Nash and Ehrenfeld 1997). By the 1990s, a "greening of industry" was under way (Press and Mazmanian 1997). Porter and van der Linde (1995) and others (such as DeSimone and Popoff 1997) stress the value of high environmental standards for firms in search of eco- efficiency, expanded markets, and public acceptance.

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

1. A change in the scale of problem definitions. Con- ceptual learning involves a search for broader definitions of problems. In the United States, emphasis shifted from human health concerns to the health of the larger ecological system (USEPA 1990). Instead of focusing on what comes out of a discharge pipe, policy makers began to consider how processes and raw materials could be changed to 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 makers recognized the limits of the narrow problem definitions used in technical learning, they searched for more integrated strategies, such as "cross-media" approaches. An early effort within the EPA, for example, was to analyze environmental risks, not on the basis of environmental medium, but on the basis of geographic area, pollutant, and industrial sectors (Schmandt 1985). The EPA com- missioned the Conservation Foundation to produce a series of reports on integrated pollution control, including a model integrated statute (Davies 1990). Pollution prevention became a basis for policy integration. In 1989, the EPA created its Office of Pollution Prevention. Congress passed the Pollution Prevention Act in 1990, and state agencies began to integrate prevention into regulatory and permitting decisions.

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

Policy makers responded to the turbulent environmental politics of the early 1980s with efforts to reduce conflict and distrust. The techniques of alternative dispute resolution were applied to a variety of situations (Bingham 1986), such as regulatory negotiation. That issue responded to what Philip Harter (1982) called the "malaise" of traditional rule making and was a forerunner of efforts to convene stakeholders for the EPA's reinvention projects.

4. Attention to novel policy instruments. A central fea- ture of technical learning is reliance on direct regulation as a policy instrument. In conceptual learning, policy makers become interested in alternatives and complements to direct regulation (see Stewart 1988). Market instruments are a good example: Applied mostly to air pollution, instruments such as emissions trading, the bubble policy, and acid rain allowance trading incorporate a system of economic incentives into the existing regulatory framework. These innovations provide some flexibility from the uni- formity and technology basis of the technical model by allowing firms to trade pollution-control requirements and distribute costs more efficiently (Hockenstein, Stavins, and Whitehead 1997). Information is also used explicitly as a policy instrument. In the 1980s, to respond to such problems as radon in homes, household chemical use, and lead in drinking water, the EPA and other health agencies turned to risk communication, disclosure, and other information- based tools to influence behavior (OTA 1995).

Although the United States made significant strides in developing capacities for conceptual learning through the 1980s, it made less progress in integrating conceptual learning into mainstream policy making. The legal, bureaucratic, and institutional framework was still founded on technical learning. Congress revised most of the environmental statutes between 1981 and 1990, but these changes largely reinforced the reliance on technical learning that had characterized U.S. policy. There were exceptions-the Pollu- tion Prevention Act of 1990, the emphasis on non-point source water pollution in the 1987 Water Quality Act, the acid 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 environmental statutes (Fiorino 1996).

At about the same time, many European nations were developing and integrating conceptual learning into their legal and administrative structures. Great Britain implemented cross-media regulation and adopted an integrated law for air and water pollution (Gouldson and Murphy 1998; Owens 1990). The Dutch adopted a National Envi- ronmental Policy Plan that integrated planning across sectors, institutionalized cooperation between industry and government, and incorporated new policy instruments, such as product stewardship (Gouldson and Murphy 1998).




Sweden, Norway, and Denmark expanded their capacities for cooperative action and policy integration (Janicke and Weidner 1997; Wallace 1995). Although the 1980s were an innovative time for the United States, especially in Kingdon's (1984) "policy" stream, many other industrial nations were able to more effectively integrate conceptual learning into their national policy systems.

The recognition that a first generation of policies based on technical learning would be inadequate for dealing with environmental problems over the long term was widespread among the industrial nations. This stimulated interest in conceptual learning-a search for new strategies based on reformulated policy objectives and problem definitions. By the late 1980s, though, it began to appear that conceptual change was not enough, given the growing emphasis on sustainability, participation, and inclusion that reached full articulation in the 1992 Earth Summit in Brazil. By the early 1990s, many nations were well on their way to defin- ing and developing capacities for engaging in a third type of policy learning.

The 1990s: An Emerging Capacity for Social Learning?

Social learning is a third form of learning, one that Glasbergen asserts will have "direct implications for a new concept of democracy" (176). It builds on technical and conceptual learning, but it takes policy makers in new di- rections, toward new forms of communication and interaction. While the shift from technical to conceptual learning focused on problem definitions, policy strategies, and the interdependencies among them, the shift to social learning turns more on the relationships among participants. Like the other forms of learning, social learning emerged in response to the dynamism of problems and changes in the institutional, political, and physical environment (Kooiman 1993a). Most of the elements associated with conceptual learning apply to social learning-concern for integration, attention to industrial processes and raw materials, efforts to reconcile economic and environmental goals, concern with global issues, and so on. In other ways, social learning involves a fundamental shift "in the views which policy makers hold with respect to the facilities that have 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. Technical learning is based on control, with government as control- ler. By design, relationships between regulators and their targets are distant, formal, and adversarial. In contrast, policy systems with a capacity for social learning exhibit more open patterns of governance, described as "social- political governance" (Kooiman 1993b) or "communicative governance" (Van Vliet 1993). Social-political gover-


nance consists of "more or less continuous processes of interaction between social actors, groups and forces and semi-public organizations, institutions, or authorities" (Kooiman 1993b, 3).

Second, social learning requires a different approach to implementation. The traditional model of implementation, which is based on hierarchy and control, is replaced with a cooperative model in which government, industry, and others share responsibility for achieving policy goals (see Ayres and Braithwaite 1992; Teubner, Farmer, and Murphy 1994). Lines between policy formulation and implementation blur. There is an implicit trade-off in social learning: Industry is given more influence in setting standards and flexibility in deciding how to meet them, but it shares more 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 solving them. Technical learning reflects an optimism about knowledge and problem solving. Environmental policy expanded in the 1960s, Glasbergen observes, when "there was still a strong belief in the constructability of society" (1996, 182). It was assumed that scientific analysis and research would provide answers to most questions, given enough time and resources. This confidence in the power of science was matched by a confidence in institutions. Congress would pass laws that agencies could translate into rules to change polluters' behavior. Pollution sources would comply under the threat of penalties.

Nearly three decades of experience have tempered this optimism. More and better research does not necessarily resolve political debates over science. Bureaucracies are not always able to carry out the complex tasks that are assigned to them. Social learning reflects an awareness of these uncertainties and limitations. Rather than prove a scientific conclusion, for example, social learning stresses the need for communication among stakeholders to determine what action should be taken in the absence of con- clusive scientific evidence. One illustration is the precau- tionary principle, which European governments have used to decide environmental policies "where the consequences of alternative policy options are not determinable within a reasonable margin of error and where potentially high costs are involved in taking action" (Weale 1998, 310).

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



terns with a capacity for dialogue. In addition, emphasis on the social component of sustainability at the United Nations Conference on Environment and Development (UNCED) in 1992 stimulated international interest in social learning. The UNCED blueprint for sustainability, Agenda 21, includes recommendations about participation, dialogue, equity, and collaboration (Lafferty 1998). This emphasis 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 on the cognitive and structural foundations of technical learning and on the reformulation of goals and strategies that occurs under conceptual learning. But it also involves an effort 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 the effort to integrate social learning onto the existing regulatory system. The Common Sense Initiative and Project XL stressed cooperation through improved communication and interaction among stakeholders. Both reflected a dissatisfaction with the current hierarchical, inflexible, fragmented regulatory system. Both recognized limits in regulators' information capacities and the need to bring diverse stakeholders (including regulated firms) into policy making. The purpose in both initiatives was to move past old relationships based on bureaucratic formalism, legalism, and adversarialism to new patterns of interaction.

Because of design flaws and disagreement on goals and protocols, both initiatives encountered problems. However, they are worth examining because they reflect an effort to apply social learning. Their design and the problems they encountered illustrate both the desire to incorporate social learning and the institutional, legal, and other barriers that arise 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 EPA had ever made to implement a program based on industry sectors. Six sectors were selected for projects: metal finishing, electronics and computers, iron and steel, printing, petroleum refining, and auto assembly. For each sector, the EPA convened a panel of stakeholders representing a range of interests-companies, trade associations, environmental groups, state/local officials, and others. The EPA formed a CSI Council to guide the overall initiative; each sector panel was constituted as a subcommittee. The EPA identified six issues for attention in each sector: regulation, pollution prevention, reporting, compliance, permitting, 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 learning and to integrate social learning into national environmental policy. A core objective was to move from the existing, deterrence-based regulatory system to one based on cooperation. In addition, CSI was designed to overcome the conventional distinctions among the air, water, and waste programs. The program was broken down by industry sector (for instance, metal finishing) and functional issue (for instance, pollution prevention) rather than by programmatic area. From the start, it was not clear how this would be done-it was presumed that stakeholders would find a way to reconcile economic and environmental goals in the course of their deliberations. In these respects, CSI incorporated efforts that had been made to that point to implement conceptual learning into U.S. environmental policy.

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

Project XL. The second case in social learning (XL stands for excellence and leadership) was announced as one of President Clinton's proposals for "Streamlining Environmental Regulation" (USEPA 1995; White House 1995). Project XL invited companies to propose alternative regulatory strategies when they could demonstrate that such strategies would achieve better environmental results than could be expected under existing law. The premise was that more flexible regulation would give society better environmental protection at less cost, so long as firms remain accountable for their performance and are willing to collaborate with the public. The program involved a trade-off: Regulated firms would be given the flexibility to implement alternative strategies if they could produce greater environmental benefits.

Once a proposal was approved the applicant was invited to work with the EPA, state and local authorities, and environmental and community groups to develop a final project agreement. This agreement was executed between the regulatory agencies and the company, in consultation with other stakeholders. It described what steps the company would




take to improve its performance, the regulatory exceptions the agencies would provide, the basis for measuring performance, and the expected environmental benefits, among other topics. Once federal and state regulators approved and the support of the other stakeholders was obtained, the agreement legally authorized the company to implement its program.

The assumptions and principles of social learning run throughout Project XL. The stated goal of the program was to replace a command-driven system with one in which companies have discretion to develop solutions that ex- ceed those of existing law. The evolving model was not one of government telling companies what to do and how to do it, but of setting goals and working cooperatively to devise more effective, efficient, and socially responsible ways of achieving them. Although the role of local stakeholders was unclear in the design of Project XL, it was understood that they had a role in shaping facility demon- strations and advising agencies on project agreements. Like CSI, Project XL was billed as a sector-based, multi-stake- holder, consensus-based process (in terminology that is characteristic of social learning) in which direct communication and interaction among the participants would lead to "win-win" solutions (USEPA 1998a).

Neither program worked fully as intended (Davies and Mazurek 1996; GAO 1997; NAPA 1997). CSI was plagued by disagreement on goals and protocols, a definition of consensus that gave participants a virtual veto, and uncer- tainty in policy goals. Progress in Project XL was hurt by ambiguity over stakeholders' roles (especially community groups), disagreements within the EPA, and disputes over what constituted "superior" environmental performance. Although Project XL has recently produced interesting results and offers several lessons on how to innovate in regulatory policy (see USEPA 1999), its effects have been far less sweeping than were originally expected. An obstacle in both projects was a mismatch between the goals of innovation and the statutory constraints. One study con- cluded that "The lack of a statutory basis for environmental initiatives or programs always foreshadows difficulty" (Davies and Mazurek 1996, 3; see also Mank 1998). The inflexible legal framework, based firmly on technical learning, inhibited efforts to integrate conceptual and social learning into the policy system.

A difficulty in both programs, especially in CSI, was achieving the needed changes in participant roles and relationships. Here was the EPA, the long-time regulator, an institution whose legal mandates and political circum- stances had forced it into an adversarial relationship with industry, playing the role of facilitator with the very interests whose behavior it had sought to control. Here were the representatives of U.S. industry, far more accustomed to seeing the EPA as an issuer of rules and an enforcer,


being asked to sit down cooperatively with that same EPA in a public forum and agree on better approaches to environmental protection. At the same table were environmental advocacy and justice groups, who generally were skep- tical of this apparent transformation in the EPA's role and its relationship with industry. CSI and Project XL illustrate attempts to integrate social learning. In both, the in- tent was to develop new forms of communication and interaction among stakeholders, achieve more flexibility than the existing framework allowed, and move from adversarial to cooperative relations. Their mixed success attests to the difficulty of integrating social and conceptual learning into a system founded on technical learning.

Policy Learning and the Environment At 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. This article has presented the elements of a learning approach and applied it to the experience of the United States. This conclusion summarizes that experience, then considers what lessons may be drawn from a learning approach in thinking about the future.

Policy makers in the 1980s adapted to deficiencies in technical learning by incorporating conceptual learning: emphasizing consensus-based processes; pollution prevention; cross-media problem-solving; global issues; and efforts to reconcile environmental and economic goals. All of this took place within an institutional framework that was based on technical learning. Since about 1990, there have been efforts to implement social learning within this same framework. The mixed success of initiatives like CSI and Project XL illustrate the difficulties of integrating new learning styles under such conditions.

John Kingdon's framework (1984) on policy streams suggests an important conclusion about the 1980s: The shift to conceptual learning was led by the policy and problem streams, while the political stream lagged. EPA administrators led efforts to integrate policy, apply the concept of risk, stress international issues, and use consensus-based approaches. Many state-level agencies led the move toward pollution prevention. Such think tanks as 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 market incentives into the acid rain trading program. A leading statement of conceptual learning, the EPA Science Advi- sory Board's Reducing Risk (1990), was the work of an expert panel. Most of the innovation associated with conceptual learning came from policy professionals, not from Congress or the president.



It also appears that the problem stream drove the search for new objectives and strategies in the 1980s. My earlier discussion of the shift to conceptual learning described changes in the problem stream: the growing complexity and interdependence of air, water, and waste issues; the emergence of issues with global, long-term, and irrevers- ible consequences; the sharply increasing marginal costs of a pollution control compared to a pollution prevention- based approach; and the dynamism among problems and likely solutions. To most people in the environmental policy field, business as usual based on technical learning was insufficient for dealing with a new generation of problems. The status quo would not suffice. Environmental policy makers adapted with new goals and strategies based on conceptual learning.

By the late 1990s, the U.S. environmental policy system was at something of a crossroads. Although support for environmental goals remained strong, there was dissatisfaction with the means used to achieve them. This questioning of basic strategies continued the efforts at conceptual learning that had begun in the early 1 980s. We still see the stress on integration, the efforts to reconcile environmental with economic goals, a concern with global issues, and the search for ways to prevent pollution. What is distinctive about the 1990s is the concern about relationships among interests, the institutional foundations for those relationships, and the obstacles they pose to problem solving. Like Moliere's character, who realized that all his life he had been speaking prose without knowing it, the current generation of policy makers and reformers have been calling for a better capacity for social learning without using the term. The policy system is evolving-slowly and fitfully-toward a new learning model, one that will require a greater capacity for social learning.

The nations that will be most successful at coping with environmental problems in the future will be those that are able to develop and integrate their capacities for different kinds of policy learning. A capacity for technical learning is a necessary but not sufficient condition for success. The United States was a leader in implementing a system based on technical learning, because it built on the strengths of the policy system: impressive scientific and technical resources; a highly evolved legal system; a relatively capable and efficient bureaucracy; and a sense that polluters should be held accountable for damages they cause. As Janicke and Weidner observe (1997, 301), the United States' innovations in the 1970s provided (along with, they argue, Sweden and Japan) a model for other nations as they responded to evidence of environmental degradation.

The nations that have been most successful at integrating the various forms of learning are, not surprisingly, those that attract interest as models for the United States. The Netherlands and Denmark in particular, and Sweden and

Norway to a slightly lesser degree, have been held up as exemplars not only of effective environmental policy but of a long-term capacity for technology innovation (Wallace 1995), sustainability planning (Janicke and Jorgens 1997; Meadowcroft 1997), and sector-based innovation (Gouldson and Murphy 1998). The reasons for their success are complex, but they certainly are a combination of size, geography, political culture, institutions, and history. Cultural and institutional differences do matter. In his book on environmental discourses, John Dryzek (1997) con- cludes that a consensus-based political culture built on corporatist traditions offers the most fertile ground for ecological modernization and sustainable development, the two of his discourses that most fully capture the concepts of conceptual and social learning.

The Netherlands presents an especially interesting example of a nation that has developed and integrated its capacities for policy learning relatively successfully. Until the early 1980s, it exemplified a system based on technical learning. By the beginning of that decade, however, it was increasingly accepted that the existing approach would not suffice over the long term (Bennett 1991). Over the next several years, the Dutch undertook a crash course in conceptual 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 industry perceived that the government was moving too fast and had consulted too little with affected sectors. But the Dutch policy system showed a capacity to learn: By the second and third rounds of the plan, the needed trust and cooperation had been developed to support the integration of a new form of policy learning.

Given its small size, tradition of state planning, inten- sity of pollution, and consensus-based political culture, the Netherlands was well-suited to developing and integrating its learning capacities. The same can be said for the Scan- dinavian countries. In contrast, larger, more diverse federal systems with less tradition of cooperation among industry and government, such as the United States or Germany, will find it difficult to achieve the same level of social learning in environmental policy. The challenge in those countries may be to think at different levels of governance. In the United States, where observers have often compared states according to their capacities for technical learning, there are differences in capacities for other forms of learning as well. Minnesota, for example, exhibits a capacity for integrating conceptual and social learning that is probably better than any other state. New Jersey, which has been known for years for its stringent regulatory system, has taken steps to increase its capacities for conceptual and social learning by experimenting with facilitywide permitting, pollution-prevention planning, and government-industry cooperation (Rabe 1995).

Environmental Policy As learning: A New View of an Old landscape 331



The task of integrating conceptual and social with technical learning poses many challenges, but two stand out. The first is redesigning the regulatory system so that actors are able to respond to lessons learned. Part of learning is a capacity for change. Here the differences among forms of learning matter. Technical learning may be an effective way for policy systems to respond initially to complex, technical problems. It allows us to break problems into manageable parts, establish government's authority, and create knowledge needed to devise solutions-all necessary stages in developing a long-term ability to address environmental problems.

At the same time, the reliance of technical learning on hierarchy and control may impede learning by limiting the ability of actors in a policy system to change behavior based on what is learned. Many complaints about U.S. regulation focus on the centralization and lack of flexibility characteristic of technical learning. Once policy is defined in rules, the system is designed to make people conform. Opportunities for discretion are controlled, a subject that Bardach and Kagan (1982) address so well in their book on regulation.

The point is well-documented in the literature on innovation: Organizations that are run tightly from the top and allow little room for creativity and judgment at middle and lower levels are the least innovative. David Wallace makes this point in his analysis of the organizational literature with respect to the capacity for environmental innovation in firms (1995, 11-22). Why then, at a time when most everyone agrees on the need for continuous improvement and behavior that goes "beyond compliance," do we continue to protect the environment with the systematic equivalent of the noncreative, noninnovative, nonlearning organization? Throughout efforts to implement CSI and Project XL, the prescriptive statutory framework was cited as an obstacle. The same obstacles have been cited since U.S. policy makers began to develop a capacity for conceptual learning in the 1980s. Whether the goal was pollution prevention, cross- media planning, risk-based planning, or sustainable development, the specifications of the principal environmental laws have impeded the ability of government and others to change their behavior based on experience.

A second challenge is to improve the quality of dialogue. In Environmental Policy and Industrial Innovation, Wallace (1995) argues that the patterns of governance and the quality of dialogue in a regime determine the capacity for innovation far more than the specific policy instruments used. Government must enjoy some independence from industry influence if it is to maintain pressure for improved performance. At the same time, there must be a reasonable degree of trust, potential for collaboration, sharing of information, and respect for mutual competence among government and industry to sustain the level of dialogue needed

332 Public Administration Review e May/June 2001, Vol. 61, No. 3

to support technology innovation. Wallace rates the United States high on independence from industry, but low on the quality of dialogue, at least in comparison to three (Den- mark, the Netherlands, and Japan) of the five nations that he examines in the study. In essence, Wallace is ranking these other countries higher in their capacity for social learning and, thus, in their ability to promote innovation.

Social learning implies a different, though not necessarily lesser, role for the state. Indeed, Wallace and others (such as Janicke) give credit to the Netherlands, Denmark, and Sweden for sustaining independent, authoritative government that maintains pressure on industry while also cre- ating the conditions that foster a productive dialogue. So- cial-and to some degree conceptual-learning also reflects many aspects of the "new governance" in public administration, especially their emphasis on networks, partnerships, and the use of alternative policy instruments in addition to direct regulatory control by the state (Peters and Pierre 1998). Many issues regarding the legitimacy and effectiveness of new forms of governance apply to the environmental policy debate as well. My arguments in fa- vor of social learning are not meant to imply a weakening of governmental authority, but the need for capacities to exercise this authority in different ways.

Can the United States achieve the same level of proficiency at social learning as these other countries? Prob- ably not, at the national level. The differences in size, culture, and institutions may be too profound. Although the United States can learn much from others (for example, from the Dutch model of sector-based targets and integrated planning), we cannot expect to transplant one system of governance into another environment. Surely, however, the U.S. system can improve its capacity for constructive dialogue and cooperative governance in ways that are consis- tent with its own experience: reaching a better understanding of the factors that affect trust among actors; redesigning processes and institutions in ways that promote shared responsibility and participation; promoting collaborative problem solving at local levels; and developing better, more objective methods for measuring environmental performance are some steps that come to mind.

Further analysis of policy learning and the learning capacities examined here would suggest a more detailed agenda for change. Even before thinking about change, however, it is clear that a learning approach may help to explain how U.S. environmental policy evolved as it did, to analyze its strengths and weaknesses, to compare national experiences and capacities, and to underscore a need for systematic lesson drawing from our experience and that of others. In a policy arena known for political con- troversy and frequent stalemate, a learning approach may encourage us to take a new, more optimistic view of an old policy landscape.



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