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How Much "Europe" at the Local Level?

Analysing the influence of European partnership on migrant-integration organi-sations in Amsterdam

Department: Political Science, at the Faculty of Social and Behavioural Sciences

Specialisation: Political Theory and Behaviour Author: Arwen van Stigt - 10268316

E-mail: arwenvstigt@gmail.com Supervisor: Jeroen Doomernik Second reader: Liza Mügge Date: 24-06-2015

Bachelor Thesis Political Science Research Project Migration in Europe Word count (minus references): about 8600


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Introduction

Recently, my mother shared an anecdote with me. My mother is a teacher. For a sig-nificant part of her career she has been teaching migrants the Dutch language and culture, in order to help them integrate in Dutch society. Some of her students were already skilled in reading and writing, but most of them never learned to read or write properly. One of my mother's first students, a Turkish woman, was unable to read and write but very eager to learn. Now, many years later, she is running an NGO which helps adolescents get out of crime. With her organisation, she aims to raise awareness to the high crime rate among Turkish-Dutch adolescents in the city of Tilburg, and recently she admirably received attention from several Dutch media. 1

This is one of the few success stories my mother has ever shared with me. Of course my mother does not keep track of the lives of most of her students, and she does not tell me a whole lot about most of them anyway. However this anecdote func-tioned to position myself as an author with certain subjectivities, and to engage the reader to a critical reading of not just this, but all research papers. I want to position myself as a writer who acknowledges the relative "wealth" in Western European so-cieties. However, I do not want to underestimate the unequal access to institutions who define and distribute this wealth. In most scholarly articles the author strives complete objectivity aiming at making political science as impersonal as the natural sciences. In my opinion an author's position, even in the natural sciences, is of great importance if one tries to communicate one's analysis clearly. I think, therefore, in the political sciences, where one tries to explain how and why people give meaning to certain institutions of power, positioning oneself as a subjective author, even though one might hold the most professional of academic titles, is very valuable, and current-ly underrated.

On 2-5-2015 the said initiative was in the Dutch newspaper de Volkskrant (see website) and on 20-5-2015 in the Amsterdam Student

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Now turning to the subject of examination: the aim of this research is to lyse the influence of European cohesion policy on local policies. The objects of ana-lysis are immigrant-integration programmes of sub-national actors, non-governmental organisations, and civil society organisations in the city of Amsterdam. The focus will be on to what extent the European partnership principle influences local integration-organisations. This thesis thus tries to answer the question: to what extent does

Euro-pean soft law, and specifically the partnership principle of structural funds, influence local immigrant-integration policies in Amsterdam? Theoretically this thesis

contri-butes to the debate on the relation between supranational and local actors in Europe. The social relevance of this thesis lies in contributing to the integration debate on the future of European integration policy.

In the next paragraph the focus will be on explaining theoretical tools which indicate decisive concepts for the analysis. First, multi-level governance theory will be briefly explained. Subsequently the concepts of structural funding and partnership are elaborated on. Next, the data and case-selection will be explained. Than, the me-thodological choices will be highlighted. Subsequently the results will be shown in an orderly manner starting with a modest presentation of European, national and local integration policy, followed by a more extensive analysis of the European policy in-fluence on the local level. The main results indicate at an indirect inin-fluence of part-nership on local policy. The formal policy dynamic between the regional and local level are to a large extend mediated by the national government. However the results show that administrative procedures, attitudes, and the local dynamic between organi-sations have changed. In the conclusion the main results will be summarised and po-sitioned in the theoretical debate. In the discussion recommendations are made for future research, and for possible improvements concerning the multi-level European integration policy.

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Multi-level Governance and Local Actors

In this section the concept of multi-level governance (MLG) will be discussed. Its theoretical value for this thesis lies in understanding relations between different actors who are included in policy formation and policy implementation processes in the Eu-ropean community. The relation between actors is of importance because the relatio-nal capacity of a given context equals power, and power enables a social actor to in-fluence asymmetrically the decisions of other social actors in ways that favour the empowered actor's will, interests, and values (Castells 2009: 10-11). Relational capa-city means that power is not an attribute but a relationship. Furthermore there is never a zero-sum game but always a possibility of resistance that calls into question a po-wer relationship (Castells 2009: 10). Seen from this point of view it seems naturally to interpret the relation between the European Union (EU) and local actors (LAs) with a certain understanding of the role of the latter in multi-level governance theory.

Multi-level governance originally refers to "a complex, multi-layered, decisi-on-making process stretching beneath the state as well as above it" (Marks 1992: 221). The European Union defines MLG as certain co-ordinated action namely: "mul-ti-level governance is co-ordinated action by the European Union, the Member-states and local and regional authorities, based on partnership and aimed at drawing up and implementing EU policies" (European Commission, 2012: 3). According to some 2 MLG has developed into a theory. MLG has been criticised and complimented. However for this thesis its main feature, the empowerment of LAs in European poli-cy, is of great importance (George, 2004: 118-124). The levels in MLG must be un-derstood primarily as territorial levels: supra-national (such as European Commissi-on), national (individual member-states) and sub-national (municipalities) (Piattoni, 2011: 172). Secondly, they must be understood as jurisdictional levels having certain specific functions as governmental, non-governmental or private entities (ibid.).

MLG has been defined as a concept, a model or a theory. For MLG to be a theory it needs to explain causations. Marks and Hooghe

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se two characteristics that combine "multi-level" and "governance", coincide with two theoretical binaries defining the role of local actors in MLG. Firstly, with the contrast vertical and horizontal government, and secondly with type I versus type II governance. Both pairs will be discussed in the next paragraph taking note of their appreciation of another binary, namely inclusion versus influence.

Type I MLG refers to the vertical distribution of power between top-down and bottom-up hierarchal levels of government going beyond the nation-state. Type I MLG therefore explains the political mobilisation in such hierarchies (politics) and the accompanying policy-making arrangements (policy) (Piattoni, 2011: 165-166). The multi-level government debate, from an early period on, thus evolved around the European region or cohesion policy, and reiterates the, according to some , productive 3 dichotomy between the intergovernmental and supranational perspective (George, 2004: 108). "Apart from a generalised presumption of increased mobilisation across levels, they [MLG type I theories] provide no systemic set of expectations concerning which actors should mobilise and why" (Marks et al. 1996: 167). Type II MLG thus concentrates on constructing a multi-level polity which explains who should mobilise and for what reasons (Piattoni, 2011: 169). Ideologically speaking, type II MLG is the opposite of type I because it involves not only governmental actors, but also non-governmental and private actors in governing processes (Piattoni, 2011: 170). It the-refore speaks of horizontal rather than vertical relations and is located in anarchical rather than conventional federal systems of government, hence it speaks of

governan-ce (ibid.). Type II governangovernan-ce can occur where mainstream governmental

organisati-ons are unable to respond flexibly to policy issues that intersect their jurisdictiorganisati-ons (Skelcher, 2005: 94). This occurs when national governments surrender authority to supranational agents, or when supranational agents impose regulations onto lower levels, consequently shifting the balance of resources between the levels of govern-ment (for the former see George, 2004: 115 for the latter see Bachtler and Mendez,

George reviews several critiques MLG has received over the years (2004). According to George MLG has proven its strength because

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2007: 556-558). This impacts LAs, who may argue that the resources they traditional-ly could deploy to achieve some autonomy from central government control have been eroded, or new opportunities are presented by supranational agents (ibid.).

One could hypothesise that the autonomy of LAs resulting from this line of theory is that: "sub-national mobilisation could grow as a result of supranational en-trepreneurship or institutional learning; it should probably happen rather evenly across the Union, and should be accompanied by a shift of state sovereignty to the supranational and sub-national level" (Hooghe 1996: 20). But, MLG does not make assumptions about the autonomy of local actors (Marks, 1996: 167). The extend of such autonomy is precisely one of the questions that the MLG research agenda ad-dresses through empirical research (ibid.). But as some argue, the involvement of lo-cal expertise is seen as crucial in bringing European policy-making closer to the reali-ties of the member-states (George, 2004: 118), allowing for greater societal input, and carrying out a grassroots ideal (Batory and Cartwright 2011: 701). However, Scholten argues that local policies, because of their proximity to migrants, are not always more accommodative to ethnic differences. His conclusion rather points to subjective and strategic factors which frame the (local) integration policy (Scholten, 2013: 168).

The debate on European cohesion policy can be briefly summarised as fol-lows. While acknowledging interaction between regional and local levels, some have argued that the nation-state accounts for a subordinate position of LAs in the Euro-pean partnership mechanism (Bache, 2010: 71-72). The partnership mechanism crea-ted in 1988 by the EU insists on consultation between regional, national, and local authorities cooperating in pursuit of a common goal (Bache, 2010: 61). The European Council when they created this principle directed at partnership between different levels of governance. However some argue that the national government's gatekee4 -ping role, the domestic structures, or the social-democratic values of a nation-state undermine its actual influence (ibid.). On the other side, the re-nationalisation thesis

Bache has argued the gatekeeping role of the national governments must not be underestimated (2010). Yesilkalgit and Blom-Hansen

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has been criticised for its lack of fine-grained research, the focus on zero-sum games rather than sum-sum games, the lack of acknowledgement of cooperation rather than competition, and the differences between member-states' structures (Bachtler and Mendez 2007: 557-558). The push-and-pull factors between nation-states, local, and regional actors are clearly unresolved.

Structural Funds and the Partnership Principle

The EU has several mechanisms to influence local actors. In this paragraph some of the key-mechanisms will be covered, namely the structural funds and the partnership principle.

The structural funds were set up in 1975 starting with the European Regional Development Fund (ERDF) to promote economic and social cohesion across Europe reducing disparities between regions and countries (Bachtler and Mendez, 2007: 537). Currently the structural funds include the ERDF, the European Social Fund (ESF), the Cohesion Fund (CF), and some agriculture and fishery funds. Although integration funds are not part of these "big five" (AER, 2012: 2), the funding of inte-gration of third-country nationals is structurally complementary to the European So-cial Fund (website European Commission, 2015a). The structural funds are part of the seven-year policy cycle in which the EU formulates and implements its cohesion po-licy. The cycle has four distinctive phases. In the first phase the European Council together with the Commission decides on the budget and general principles of diffe-rent funds. In the second phase each member-state makes an operational programme (OP) on the fund's objectives specifying policy targets, and monitoring committees (MCs). Further, the operational programme specifies the criteria concerning the allo-cation of funds for individual projects. In the third phase each member-state calls for proposals, and decides how the money will be allocated. In the fourth phase all pro-jects are evaluated by independent experts (Yesilkagit and Blom-Hansen, 2007: 509).

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Four mechanisms through which the structural funds influence national and local policy can be identified. The development of the four mechanisms of the struc-tural funds were described by Bachtler and Mendez as follows:

The landmark reforms of 1988 doubled the budget for the structural funds and introduced a number of principles for their implementation which remain at the core of cohesion policy: programming (the thematic allocation of resources based on strategic, multi-annual plans in-stead of a project-based approach); concentration (the spatial distribution of funding on a limi-ted number of objectives and focused on the least developed regions); additionality (to ensure that EU funding does not substitute for national expenditure); and partnership (the participati-on of natiparticipati-onal, sub-natiparticipati-onal and supranatiparticipati-onal actors in the design and implementatiparticipati-on of pro-grammes). (Bachtler and Mendez 2007: 537)

Leaving the first three principles untouched, I will further investigate the partnership principle because it specifically addresses the inclusion of local actors in the policy design and implementation.

The European Council defined partnership in the European reforms of 1988 as "close consultation between the Commission, the member-states concerned and the competent authorities designated by the latter at national, regional, local or other le-vel, with each party acting as a partner in pursuit of a common goal" (Regulation EEC 2052/88 in Bache 2010: 61). This definition has more or less remained the same (European Commission, 2013: 321). Bache called partnership the "crucial innovati-on" in creating the structural funds (2010: 60). Batory and Cartwright call it a core governing principle of the structural funds which informed successive waves of re-forms aiming to involve an increasingly wide range of stakeholders in the planning and implementation of cohesion policy (2011: 698). In the multi-annual policy cycle MLG has grown in importance: firstly in '89 partnership was extended beyond central governments to sub-national actors, secondly in '93 it extended horizontally to trade unions and industry organisations, thirdly in '99 it extended horizontally to 'other competent bodies', and fourthly in 2006 the role of civil society organisations in

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partnership arrangements was explicitly recognised (Batory and Cartwright, 2011: 698 and see also Bache, 2010: 61-62).

The role of local organisations in designing and implementing partnership policy has been critically reviewed. Ranging from the first period of structural policy to the penultimate (the most recent 2014-2020 period has not been analysed yet), the policy has involved a varying degree of involvement of LAs. In the latest evaluation, partnership between economic and social partners has been considered to have in-creased (Bache, 2010: 65). It remains somewhat unclear whether the inclusion of LAs also leads to their actual influence. The member-states' implementation of the part-nership principle partly shows the influence of LAs through partpart-nership. Member-states are very specific how they implement the principle. There are partnership committees which often consist of several ministries, implementing authorities and to a lesser extent local authorities and NGOs. In some Member-states these partnership committees work on only two levels, consisting of a more general consultative/moni-toring committee and a more specific task force or groups of experts (European Commission, 2010: 18).

Corresponding with the nationalisation versus regionalisation debate on Eu-ropean cohesion policy, some have argued that the development of partnership is thus dependent on domestic policy mechanisms, in the EU15 as well as in the central Eu-ropean countries, resulting in a goodness-of-fit thesis (Bache, 2010: 71-72). Revie-wing partnership in Denmark and The Netherlands, Yesilkagit and Blom-Hansen ar-gue that in general, member-states rather than civil society organisations are in full control of the allocations of EU funds (2007: 520). On the other hand, their re-search shows, considering the case of the Netherlands, that some new policy structu-res where implemented because of the ESF, which would support the claim of regio-nalisation rather than re-natioregio-nalisation (Yesilkagit and Blom-Hansen 2007: 507 and 520). However Yesilkagit and Blom-Hansen argue that The Netherlands is a unique case of multi-level governance because in 1994 supposedly a major fraud with ESF

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money enabled the Commission to pressure the Dutch government to change their implementing structure (2007: 515 and 520). Others have argued, while analysing the concentration and programming processes of the structural funds, that the "re-natio-nalisation" thesis has relied too much on headline policy, budgetary or regulatory changes (Bachtler and Mendez, 2007: 557-558).

Batory and Cartwright have argued that partnership as currently practiced does not live up to the expectations of civil society or of the EU, but should not be dismissed as useless or unnecessary (2011: 714). They view the monitoring commit-tees as the primary institutional expression of partnership. Monitoring commitcommit-tees (MCs) are bodies that member-states are obliged to establish as part of the institutio-nal framework for receiving EU assistance under cohesion policy. The MCs meet a few times a year and consist of representatives of the MA (managing authority) of the given OP (operational programme) designated by the Member-state, and the Euro-pean Commission. The MC’s main function is to oversee the management of the structural funds' (Batory and Cartwright, 2011: 699-700). The MCs key function to interact between the European Union, local NGOs and civil society organisations is not necessarily well established (Batory and Cartwright, 2011: 714). Batory and Cartwright are disappointed in the role of the MCs and found their working rather formalistic and the bodies' purpose ambiguous (ibid.). They conclude that both the EU and national governments have some way to go to secure genuine societal invol-vement in and control over European cohesion policy. MCs do provide important opportunities for networking and information exchange for a wide and diverse set of actors and should certainly be regarded as a useful part of the institutional structure (ibid.). MCs can be seen as an important tool to test the functioning of partnerships.

Partnership is thus an indirect mechanism for the European Commission (EC) and for local organisations to cooperate. The partnership principle holds member-sta-tes responsible for forging relations between different levels. Because the subsequent research focusses on the local level it is of importance how this relation is defined,

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and to what extend the EU influences local policies through, or irrespective of, the mediator role of a national government. Partnership should be understood as a Euro-pean ambition to include local organisations in policy formation and implementation, and it could be hypothesised that local organisations have a strategic relevance for European cohesion policy. Furthermore the preceding theoretical paragraphs have shown that while multiple deficits remain, structural funds and partnership show promising opportunities for multi-level governance to divide (new) competencies among actors from the supranational and subnational level. It thus provides the right theoretical context to examine power relations between levels, or if you like: influen-ce of one level over another. In the next paragraph the methods to conduct such re-search, and the data which it requires are laid out.

Data and Methods

The aim of this research is to interpret the influence of European cohesion policy on local policies. To accomplish an understanding of and point to possible explanations for this multi-level governance dynamic, use has been made of a case study. A case study has some advantages and some limitations which will be explained below. Se-condly, in the next paragraph will be explained which data were used to accomplish the research and for what reasons. Lastly, in the next paragraph it will be explained what methodological choices had to be made, and how important definitions are ope-rationalised.

Case Selection

The advantage of a case study is the rich, in-depth information, allowing for a detai-led understanding for the processes at work (Bryman, 2008: 54). The disadvantage is that a generalisation can only be made on several conditions and it will always lack some extern validity because of case-specific attributes Bryman, 2008: 57). Because of the engagement with the real-life context, the case study design could stimulate

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ecological validity. Ecological validity is a research criterion “concerned with the question of whether social scientific finders are applicable to people’s everyday, natu-ral social settings” (Bryman, 2008: 33).

To account for the intern validity the case selection process shall be briefly explained. Integration policy is an EU-third pillar policy which makes it is not the most evolved european cohesion policy-field. Partnership is, however, an important mechanism to further develop this policy precisely because the lack of European hard law on migrant-integration. Because of the pressing issue of refugees migrating in large numbers to European countries, the integration policy is under pressure to de-velop. This makes integration an interesting subject in relation to the influence of Eu-ropean policy on local policies.

The Netherlands as a member-state is not necessarily interesting because of its numbers of refugees (in which case Italy or Spain would be more interesting), but there is an anti-immigrant attitude among some Dutch politicians and civilians that has been found problematic in the integration-process of third-country nationals. The Netherlands is further known for its inburgeringscursussen , which require an active 5

participation to integrate before being able to acquire Dutch citizenship (Wet Inburge-ring 2007). Amsterdam as a case study is interesting as it is a relatively large urban area where, together with the three other Dutch big cities (Utrecht, The Hague, Rot-terdam), most migrants reside. The Amsterdam integration policy is known for its relative tolerance, but also for its general, opposed to group specific policy which is more evident in cities like Rotterdam and The Hague (Blom, S. 2014: 6).

Data Selection

The European funds under investigation are the European Integration Fund (EIF), and the Asylum Migration and Integration Fund (AMIF). This selection is

Inburgering is the Dutch name for the process of an immigrant adapting to the Dutch society, it additionally refers to the inburgering

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-sexamen which is a civic and language test every immigrant has to pass to receive temporary or permanent permits, inburgeringscur-sussen thus refer to civic and language courses (Bruquetas et al., 2011).

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sed upon their funding integration projects, and because they are considered to be a vehicle for the partnership principle. In 2007 the EIF was established and in 2013 the AMIF, hence they will both be included in the analysis. All local projects in the city of Amsterdam which where funded by EIF are listed in Annex I. Before the EIF exi-sted, the European integration fund was INTI . This fund was active until 2006. Be6 -cause of the delimitation of this research, the INTI will only be partly included in the main analysis. The specific analysis of the EIF and INTI evaluations can be found in Annex III. Other funds that occasionally finance integration projects, such as the Eu-ropean Social Fund, are excluded.

Several interviews are conducted in Amsterdam with local immigrant-inte-gration organisations who received funding from the EIF, or are currently applying for funding from AMIF. There are three jurisdictional levels of organisations: sub-national actors (SNAs), which in this case is the social department of the city of Am-sterdam , non-governmental organisations (NGOs), which refers to non-profit organi7 -sations, and thirdly civil society organisations (CSOs), which refers to a combination of profit and non-profit based organisations. Educational institutions and health care institutions were excluded. The selected interviewees were approached by means of purposive sampling; because of their involvement in an EU application procedure or in a funded project (Bryman, 2008: 375). Five organisations located in Amsterdam have received EIF funding in the past five years. Interviews were held with respon-dents from three of them. Two interviews were held with responrespon-dents from the social department of the city of Amsterdam (afdeling Werk en Inkomen) referred to below as respondent number 1 and 2. Three respondents were interviewed from the Civil Soci-ety Organisation S-IPI (Stichting interculturele participatie en integratie), referred to as respondent number 3, 4 and 5, and one respondent was interviewed from the

INTI was the first European fund to support the integration of third-country nationals. It was established in 2003, and ended in 2006.

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It was evaluated in 2006 bin the European Commission (European Commission, 2006: 3).

The Amsterdam department responsible for monitoring inburgering is Werk en Inkomen (see website Amsterdam).

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sterdam bureau of the NGO Vluchtelingenwerk, referred to as respondent number 6 (Vluchtelingenwerk Amstel tot Zaan).

Local integration policy is analysed by studying European, national and local policy and law. Additionally some literature is reviewed to get a better understanding 8 of the European, Dutch, and Amsterdam integration policy.

Definitions and Operationalisations

Some definitions and operationalisations need to be examined in detail. Respectively immigrant-integration, integration practices, integration policy, and partnership will be operationalised.

The concept of immigrant-integration is ambiguous. Therefore, in this thesis it refers to people who migrated from a non-European country (third-country natio-nals) into the European Union and the two-way process of mutual accommodation by all immigrants and residents of Member-states (European Commission). No explicit distinction will be made between "Western" or "non-Western" migrants, although in practices differences could be observed. The definition of integration as was set out by the European Commission reads: "Integration is a dynamic, two-way process of mutual accommodation by all immigrants and residents of Member-states." Thus

immigrant-integration will be understood as a two way process, and as something

accommodated by immigrants and residents of member-states. It must be noted that

only third-country nationals and not European citizens migrating within the EU are considered by the EC, thus European migrants are likewise excluded from the analy-sis. Integration practices will be operationalised in a broad manner to encompass as many aspects of the integration process, namely: "all actions in relation to language

skills, education, intercultural dialogue, capacity-building of actors, and development of methodological tools such as indicators or methods" (European Commission,

Reviewed literature on integration policy includes Scholten (2013), Bruquetas et al. (2011) Bruquetas and Doomernik (2015) Ver

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2010). Relating policies of either local government or CSOs or NGOs will be consi-dered as integration policy.

Multi-level governance is closely linked to partnership. In the preceding the-oretical framework two types of MLG were presented.Type I characterises co-ordina-tion between multiple levels of government, and type II represents the multiple juris-dictional actors involved in governing. Drawing on these types, and recognising the distinction Piattoni makes between policy, politics and polity (see page 5-6)

partner-ship can be operationalised consisting of three aspects: the first is the practical

(poli-cy) aspect, operationalised as the factual cooperation. Second, the political aspect answers the question why actors cooperate. The third aspect is the polity structure which is operationalised as who is dominant in what aspect of cooperation. Following Mérand, cooperation will be defined as "exchange of important information and joint

work towards the development of common positions" (2011: 127). Remembering

Cas-tells, power lies in this co-production of meaning, complemented by access to coerci-ve capacities and communicaticoerci-ve resources (2009: 13). These cooperaticoerci-ve aspects will be leading for the subsequent analysis. Next to documents or communications,

infor-mation will also refer to financial flows, because money can be seen as a

communica-tive means. To be absolutely clear, the actors examined in this so called "cooperacommunica-tive state" are local integration organisations in Amsterdam and the European Commissi-on, specifically DG Home , which is responsible for the EIF and AMIF (website DG 9 Home). Their joint work towards the development of common positions refers to the integration of third-country nationals into the Dutch state, making use of European integration policy and specifically European integration funds. The interviews were analysed according to this operationalisation of partnership, as can be found in Annex II.

The Directorate-General for Migration and Home Affairs (DG HOME) is a Directorate-General of the European Commission created

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in 2010 when the DG Justice, Freedom and Security was split in two. The role of the "DG HOME" is ensure the EU's security, aiming to create an area of freedom, security and justice (website DG Home).

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Partnership at the Local Level

This section will present the results on the partnership between European funds and Amsterdam integration policy. Firstly, the European integration funds and their poli-cies are elucidated. Dutch integration law and Amsterdam integration policy are in-cluded in the analysis. Secondly, the organisational characteristics which define the partnership between the European funds and the LAs are explained.

The European Union has made several attempts at converging member-states' migrant-integration policy. On the one hand this has resulted in some hard law on 10 European migration and asylum policy. On the other hand it resulted in mainly soft law on European integration policy. Soft law on integration consists of several 11 cross-European communication forums (or networks), structural funds, guidelines, annual reports, handbooks, consultancies, and benchmarks. The European policy-ma-king on integration is based on 11 common basic principles of integration (CBPs) listed below (European Council 2004: 16).

Common basic principles on integration:

1. Integration is a dynamic, two-way process of mutual accommodation by all immigrants and resi-dents of Member-states.

2. Integration implies respect for the basic values of the European Union.

3. Employment is a key part of the integration process and is central to the participation of immi-grants, to the contributions immigrants make to the host society, and to making such contributions visible.

The Europeanisation of integration policy developed from the Amsterdam Treaty onwards, the Treaty coming into effect in 1999

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(Bruquetas and Doomernik, 2015: 4 and Bourdrez, 2010: 17). The Treaty provided the Commission with more competencies to form directives (hard law) on migration and integration. Consequently in 2000 two directives where passed on anti-discrimination fixing the equal treatment in employment and occupation, which indirectly corresponds with integration policy (2000/78/EC in Bourdrez, 2010:19). Secondly a directive passed on the right to family reunification. This directive includes a clause which states that member-states may require third-country nationals to comply with integration measures, in accordance with national law (2003/78/EC and Bourdrez, 2010: 19). Lastly a directive passed which set out the rights of long term residents of third-country nationals in the EU (2003/109/EC). Thus employment, family reunion, and rights of long term residents where covered, leaving actual integration policy in the hands of member-states. But, European soft law and 'soft influence' has been created after the turn of the millennium which sets criteria, guides and pressures member-states' policy.

Soft law in this case refers to the non-binding regulations which are not included in European Directives. Integration, in contrast to

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migration and asylum, is part of the European Directorate General (DG) of Home affairs, and Justice and is therefor part of the third, and not first, pillar of European policy-making. This has consequences for the priority of the partnership principle which applies most strongly for first pillar policy of the Common Strategic Framework Funds, namely the ERDF, ESF, CF, EARDF, and FEAMP (Euro-pean Commission 2012a: 3 en AER 2012: 3). Although the complexity of integration policies and the differences between member-states concerning integration and social rights, partnership is still encompassed in the nature of integration policy as can be found in several policy papers and of European integration funds which will be discussed in the next paragraphs.

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4. Basic knowledge of the host society's language, history, and institutions is indispensable to inte-gration; enabling immigrants to acquire this basic knowledge is essential to successful integration. 5. Efforts in education are critical to preparing immigrants, and particularly their descendants, to be more successful and more active participants in society.

6. Access for immigrants to institutions, as well as to public and private goods and services, on a basis equal to national

citizens and in a non-discriminatory way is a critical foundation for better integration.

7. Frequent interaction between immigrants and Member-state citizens is a fundamental mechanism for integration. Shared forums, inter-cultural dialogue, education about immigrants and immigrant cultures, and stimulating living

conditions in urban environments enhance the interactions between immigrants and Member-state citizens.

8. The practice of diverse cultures and religions is guaranteed under the Charter of Fundamental Rights and must be

safeguarded, unless practices conflict with other inviolable European rights or with national law. 9. The participation of immigrants in the democratic process and in the formulation of integration policies and measures, especially at the local level, supports their integration.

10. Mainstreaming integration policies and measures in all relevant policy portfolios and levels of government and public services is an important consideration in public- policy formation and im-plementation.

11. Developing clear goals, indicators and evaluation mechanisms are necessary to adjust policy, evaluate progress on integration and to make the exchange of information more effective (European Commission) (European Council, 2004).

The member-states are supposed to implement European integration funds while ack-nowledging and respecting these principles (European Council, 2004).

European Integration Funds

The structural funds on integration started with the establishment of the INTI fund in 2003, which was converted into the EIF, RF, ERF in 2007 and transformed into 12 AMIF in 2013 (website European Commission, 2015b). AMIF has four main

European Integration Fund (EIF), European Refugee Fund (ERF) European Return Fund (RF), and Asylum, Migration, Integration

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ves. The first objective is to strengthen and develop the Common European Asylum System by ensuring that EU legislation in this field is efficiently and uniformly ap-plied. The second objective is supporting legal migration to EU States in line with the labour market needs and promoting the effective integration of non-EU nationals. The third is enhancing fair and effective return strategies, which contribute to combating irregular migration, with an emphasis on sustainability and effectiveness of the return process. The last objective is making sure that EU States which are most affected by migration and asylum flows can count on solidarity from other EU States (website DG Home). Integration is thus mentioned in objective two, which considers the effec-tive integration of legal migrants supported in line with labour market needs.

In image01 the financial flow of the structural funds is made visible. The main features of the development and evaluation of INTI and EIF can be found in Annex III.

In theory the performance of the AMIF has improved compared to the EIF. For instance the application procedure has simplified, the target group has widened,

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and solidarity and responsibility-sharing between member-states has increased, espe-cially for countries most affected by migration and asylum issues (ECRE, 2012: 7). The AMIF distributes 84%, compared to 93% of the EIF, to national programmes and reserves 16% for Union Actions , European networks and Emergency measures 13 (ECRE, 2012: 7). The Commission is authorised to divide the 16% in line with cur-rent developments in member-states focussing for instance on boat-refugees, or pro-jects created in third countries (ibid.). The AMIF distributes 75% of the amount going to member-states on the basis of programming and concentration (i.e. distribution according to the number of citizens, and the GDP), and 25% on the basis of the wil-lingness of states to carry out specific AMIF activities such as resettlement (ECRE, 14 2012: 13).

To some, the adoption from EIF and ERF into AMIF is thus a welcomed change and improvement in the area of integration. Article 12 of the general provisi-ons of AMIF lays down the same partnership principle as present in the EIF (Euro-pean Commission, 2014: 122). The Commission claims AMIF will provide better and easier access to beneficiaries to Home Affairs funding (European Commission, 2011: 11). Overall the increase of Union Actions seems to be the biggest change concerning local integration policy, because less recourse will be made to bureaucratic procedu-res which are time-consuming and labour intensive (European Commission, 2011: 11). Union Actions will i.a. be implemented in civil society organisations in the part-nership framework (ibid.).

National and Local Implementation of the European Integration policy

Because of the "soft" character of the European integration policy, member-states interpret the CBPs and divide the finances according to European and national

Union Actions are the former Community Actions. In the case of a Union Actions the Commission directly funds, manages and

13

monitors transnational asylum, migration or integration project without shared management with member-states (ECRE, 2012: 10). Resettlement refers to the process in which refugees from outside the European Union (EU) are resettled to one of the

Member-14

states. Resettlement is one of the durable solutions offered to refugees, whose needs for protection have already been established. European Commission, 2009 act 456.

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ria. The current Dutch operational programme, in which European integration objec-tives are converted to national ones, the CBPs are recognises. However in the OP the emphasises lies on the newcomers' active, opposed to the residents' passive, attitude:

integratie is een wederkerig proces waarin van de migrant wordt verwacht dat hij de taal leert, een baan vindt en de normen en waarden van de Nederlandse samenleving omarmt. Dit betekent dat migranten de ruimte moeten krijgen om volledig aan de sa-menleving deel te nemen (SZW, 2014: 19). In the OP integration accounts for 19% of

the current European integration and migration fund (AMIF). Asylum accounts for 27%, and Return for 49%, with 7% left for technical services (SZW, 2014: 3). Return policy thus clearly has a Dutch national preference. Also in the current Dutch OP partnership is not elaborated on in any way but the fact that the Dutch government invites partners to implement the policy (SZW, 2014: 29). Further the monitoring committee which is supposed to include representatives from NGOs and SNAs is so-lely occupied by ministerial staff: "Er is voor gekozen, om partners die niet horen bij

de betrokken ministeries, niet te betrekken bij het Monitor Comité" (SZW, 2014: 31).

Currently the Dutch laws on integration originate from the Dutch political climate which since the '90s has increasingly taken an assimilationist turn, and has been focussing perceptibly on certain concepts of "citizenship" and "self-responsibili-ty" (Bruquatas et al. 2011: 145-150). Since 2007 newcomers are obliged to pass an exam, that covers the Dutch language and general knowledge concerning Dutch cul-ture and society, before they enter the country. Immigrants have to pass the exam in order to be granted both temporary and permanent permit renewals (ibid.). Since 2007 all newcomers have been expected to find and fund (with help from social cre-dit) the civic integration courses themselves (Bruquetas et al. 2011: 149). For refu-gees the fee is remitted after having past the test.

The Dutch national government holds executive power, which influences le-gislation. From 2007 onwards local authorities' responsibility towards newcomers has changed: although local governments have to monitor newcomers, their

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organisatio-nal and financial resources to promote such processes have been minimised (Bruque-tas et al. 2011: 149). The story of all respondents confirmed, and expressed disap-pointment in, their decreased control on the integration of third-country nationals, and mainly the integrations of family reunion-migrants (Annex II). The new immigration laws also gradually privatise the integration courses enabling their 100% market me-chanism in three years from now (resp. 2 Annex II). Municipalities thus increasingly serve as employers to CSOs.

National integration laws must not be overestimated though, because several authors have noted that local subjective and strategic factors have been more influen-tial to integration policy than traditional integration models, which have exclusively focused on national integration schemes (Borkert and Caponio, 2010: 14). Actual in-tegration policies are much less consistent over time, and their mutual relation is much less coherent as suggested by national models of integration (Scholten, 2013: 167). Integration policy in Europe has increasingly become a local affair. Multiple factors can explain this "local shift of integration".

Scholten argues that while national models in the EU have been characterised as increasingly converging towards assimilationist policies, local policies, formally negating ethnic differences, actually cooperate more pragmatically with migrant or-ganisations (2013: 154). Furthermore pragmatic elements of problem-coping and po-licy routines play a central role at the local level in the perseverance of group-specific policies (Scholten, 2013: 154, see also Vermeulen and Stotijn, 2010: 131 and Uiter-mark, 2007). Scholten, in his analysis of Dutch multi-level migrant-integration poli-cies, argues the twenty-first century marks a period of not only national-local diver-gence, but also a period where policies at both levels seem to have become increasin-gly contradictory (2013: 168). Also, the difference between the two largest cities, Amsterdam and Rotterdam, has become more marked (2013: 166).Aside from the local pragmatism, Borkert and Caponio notice a more market based approach among local policies (2010: 23). Schmidtke additionally argues that an "entrepreneurial

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ad-ministration and favourable fiscal-political climate" are conditional for local organi-sations to increase their international cooperation with the objective of developing their distinctive local policy (2014: 92-92).

In Amsterdam, while being traditionally known for its policy of tolerance, pluralism, and recognition of ethnic groups, Scholten recognises the same assimilati-onist turn as national integration policy (2013: 160). Scholten argues though, that Amsterdam's city government continues to cooperate with migrant organisations or accommodate ethno-cultural differences for various pragmatic reasons (2013: 162). Vermeulen and Stotijn argue Amsterdam has few accommodative elements in the po-licy framework left: immigrant organisations have no major role and there are no group specific programmes for immigrants (2013: 131). But, in practice, they argue that Amsterdam's individual based approach does leave room for cultural and ethnic differences (Vermeulen and Stotijn, 2010: 131). Further, the Amsterdam coalition agreement does not once mention the term integration but does implement an inclusi-ve and individual approach to all inhabitants focussed on social inclusion and em-ployment (Coalitieakkoord, 2014 and Blom, 2014: 16). The respondents from the municipality indicated during the interview that they feel they operate more pragma-tically than national governments' policy expectations, which correspondents with the literature (Annex II).

From 2010 until 2014 in total five local organisations have received EIF fun-ding in Amsterdam: one NGO, three CSOs, and the municipality of Amsterdam itself (Annex I). Some of the funded organisations are simultaneously key players in the conduction of national civic examinations. Actually all but two officially legitimised examination organisations, who are not solely profit-based, have received EU funding (website Blik Op Werk). The funding was not for civic courses but mainly for empo-werment activities or language courses (ibid.). All these projects have received EU

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funding through the national managing authority and have done so by digitally ap15 -plying at the OP Agentschap SZW (ibid.). The municipality of Amsterdam additional-ly receives funding from a direct submission at DG Justice (which is currentadditional-ly part of DG Home) but the project is solely targeting refugees (resp. 2 Annex II).

European Influence on the Local Level

To determine the influence of one actor over another one has to observe change. Se-veral changes are mentioned above concerning the policy development. Certain changes have also been extracted from the interviews. The European funds have in-fluenced local actors in three ways. Firstly, all LAs show signs of organisational

change. Second, the attitude, or frame, of the LAs towards the EU has changed.

Third, the local dynamic between the LAs, and to some extend also between LAs and the national government, has changed. The interviews were analysed focussing on the

factual cooperation, why actors cooperate, and who is dominant in what aspect of cooperation (Annex II).The results will be explained below.

The organisational changes are twofold. Firstly, administrative procedures within LAs have advanced, and second organisational practices have professionali-sed. When talking about the administrative procedure all respondents mentioned the expansion of their planning and designing of their integration projects, because of the strict admission requirements of the European funds (resp. 1-6 Annex II). The clear format which is used for the online application through the national agency, is much appreciated because of the well defined expectations (resp. 4 and 5 Annex II). Once the projects where running, the monitoring and evaluation administration had become more thorough in all LAs because of the accountability requirement of the funds (resp. 1-6 Annex II). For instance all working hours have to be registered and signed weekly by managers (resp. 1, 2, and 6). Also, the funds require the LAs to provide

The Dutch minister responsible for the EIF, currently AMIF, and also responsible for the European Social fund (ESF), is the minister

15

of social affairs and employment. However, the minister has delegated these competences to the Social Affairs an Employment Agency (Agentschap SZW), as 'managing authority' (Yesilkagit and Blom-Hansen, 2007: 514).

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information on their "clients", such as social security numbers, and dates they partici-pated in the projects (resp. 1-6 Annex II). Respondent 2 mentioned submitting an ap-plication for European funds is a "sport", and requires "expertise" (Annex II). The SNA perceives the application-procedure as a game of being able to find the right format to present a project to the EU. Although they are experienced in applying for EU funding, they do plan to change some administrative procedures, namely expan-ding their staff to expand their capacity to submit more applications (resp. 2 Annex II).

Secondly, the organisational practices in the NGO and the CSO have profes-sionalised because of European requirements. While the municipality is more expe-rienced in accountability procedures the NGO solely uses volunteers to process and keep up the administration. Respondent 6 mentioned some people just cannot handle the accountability procedures and are therefor excluded from the organisation (Annex II). Although it has taken a while, most people can adjust though (resp. 6 Annex II). Respondent 4 mentioned their CSO makes good use of the tools the EU provides to evaluate the programmes and keep up with their administration. This has changed their organisational practices but is not undesirable because most funds, not just Eu-ropean funds, have strict accountability requirements (resp. 4 and 5 Annex II).

The second result points to the attitude, or frame, the LAs have towards, and because of, the EU. This attitudinal change is twofold. First a certain willingness was created to cooperate with the EU. Second the CSO and the SNA feel to some extend empowered by the EU. A joint feature all respondents mentioned is the complementa-rity of the European funds next to national, or local governmental funding (resp. 1-6 Annex II).

The municipality receives some national funding but mostly has to finance integration, or inburgering, themselves (resp. 1 and 2 Annex II). They have adopted a positive attitude towards the EU because they receive funding on projects not suppor-ted by the national government. For instance they have received funding from the EIF

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for a Language and Parenting-course for third-country nationals (Annex I and resp. 1 and 2 Annex II). The municipality has further adopted a welcoming attitude towards the EU because of the possibilities to expand their (international) network to draw on more funding opportunities (resp. 2 Annex II).

The NGO does not receive national funding, but does receive structural fun-ding from the municipality for their regular programme for immigrants, focused on social assistance, such as helping to find housing, apply for benefits, and enrol into a civic training course (resp. 6 Annex II). More extensive projects focussing on langua-ge skills, education, intercultural dialogue, and capacity-building of actors, are funded by private funds or European funds (ibid.). However, some language courses are fi-nanced by the municipality. This is the case when the NGO gets contracted by the municipality as an employee (resp. 6 Annex II). To the NGO the European funds are thus a welcome opportunity as well, to finance integration projects (ibid.). Although the administrative procedures can be a drag they have a positive attitude towards the EU because of their financial support (ibid.).

The CSO receives no national funding but does occasionally receive funding from the local government (resp. 4 and 5 Annex II). The European funds are com-plementary for them because the municipality only tends to fund projects based on getting immigrants a job as soon as possible (resp. 2 and 3 Annex II). The CSO has a distinctive bottom-up approach to integration, developing projects based on the de-mands they experience in the city (resp. 3 and 5 Annex II). To some extend the Euro-pean CBPs are a welcome extension to the national and local governments' definition of integration, and they use some European funding to make their projects happen. However, in 2012 they have waived funding from the EIF. At the last minute it beca-me clear the target group of the EIF was too narrow to include all participants targe-ted for their project (resp. 3 and 5 Annex II). The CSO has thus welcomed the change from EIF into AMIF which has widened the target group (resp. 4 Annex II). With their bottom-up approach the CSO observes important factors for integration, which

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change according to varying needs in society (resp. 3 and 5 Annex II). The CSO feels they thus can contribute to policy "from above" by developing indicators (resp. 3, 4, and 5 Annex II). They hold a positive attitude toward the EU because of the useful tools the AMIF hands them to evaluate their projects (resp. 4 Annex II). The CSO has participated in a European international project once which shared best practices (resp. 4 Annex II). The aim of the project was researching their integration methods and sharing the outcomes. The CSO was very pleased to receive a scientific evaluati-on their methods, and happy to be able to develop their expertise (resp. 4 Annex II). Unfortunately the CSO did not feel very involved in any part of the European policy process, but they do have a willing attitude towards being more involved (resp. 4 An-nex II).

Thirdly, changes in the local dynamic between the LAs are defined. Because of their size, experience and network, municipalities are unequally empowered to ap-ply to, and to be granted, European funds. The municipality is the only actor coopera-ting directly with the European Commission through submitcoopera-ting applications for Union Actions at the DG Home Affairs and at the DG Justice (resp. 2 Annex II). They also submit applications at the national agency, just like the NGO and the CSO, but they have had professionals working on these kind of applications for more than 20 years (ibid.). Respondent 2 has noticed the national agency prefers working with, pre-ferably larger, municipalities over CSOs or NGOs because they hold established rela-tions and are seen as trustworthy parters (Annex II). The municipality thus holds an unequally good position to apply for grants at the national agency, and at the Euro-pean Commission directly.

What enhances this position is the ability SNAs have to employ CSOs and NGOs for certain integration activities, such as language courses or

inburgeringstrai-ningen. All respondents have indicated they like partnering in such

employer-em-ployee constructions (resp. 1-6 Annex II). The input of the CSOs and the NGOs in the policy-process is completely negated though, and dependent on individual project

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leaders from the municipality, which is not always beneficial for the former (resp. 4 Annex II). Finally what also influences the local dynamic is the difference between the nature of the LAs. The NGO does not calculate any money into the application to be spend on administrative procedures, which are done by volunteers (resp. 6 Annex II). The entire amount of funding is reserved for the benefit of their clients. To share the load, the CSO has an inclusive administration procedure involving several collea-gues in different parts of the submission and administrative process (resp. 5 Annex II). The municipality has several professionals working on administrative procedures and holds power to, on the one hand, transfer administration to the executive organi-sations (the NGOs and CSOs) and, on the other hand to include administration costs in their application for funding (resp. 2 Annex II).

Lastly, changes in the dynamic between the municipality and the national government can be defined. The municipality has received EIF funding, and is cur-rently applying at AMIF, for projects concerning the integration of family-reunion migrants (resp. 2 Annex II). This group is not formally included in their monitoring-responsibility, hence they do not receive national funding. But, the municipality would like to meet immigrants' needs in their "self-responsibility" for the integration process, which is why they apply for European funding. The national agency is eager to provide the municipality with funding for this project because they recognise a need in society (resp. 2 Annex II). Thus respondent 2 indicated the national agency has a certain pragmatism towards local needs (Annex II). The municipality thus en-forces their capacity to signal national policy deficiencies and put forward different policy priorities, which is seen as part of the natural policy-making process (resp. 2 Annex II). The municipality's cooperation with the national agency thus to some ex-tend empowers their independence from national government, or at least, empowers their position to bring forward their model of integration-policy implementation (ibid).

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Conclusion

The aim of this research was to get a better understanding of the European multi-level governance by analysing the influence of European soft law on local migrant-integra-tion policy. As we have seen the European partnership influences local immigrant-integration policy in three ways. Firstly, partnership influences LA's organisational practices, namely it expands administrative procedures, such as monitoring and eva-luating integration projects. Second, it influences LA's attitude towards the EU, na-mely it creates a positive attitude towards the EU because of the financial support the funds provide. Third, it influences the dynamic of the local organisation of integrati-on, namely, compared to the CSO and NGO, it unequally empowers the municipality of Amsterdam and its integration policy.

In a multi-level environment these results are interesting because the partner-ship principle has been criticised for its relative impact caused by the gatekeeping role of the nation state. As we have seen partnership indeed has an indirect rather than direct influence on local actors. The results point to a minimal effort of the Dutch na-tional managing authority to include local partners in the policy process. Apart from the communication between the municipality of Amsterdam with the DG Justice in Brussels, no direct exchange of information can be observed. However, several indi-rect communication mechanisms cause the soft power of the EU to influence local practices to some extend. The CBPs complement national and local integration poli-cy, and the OPs allow the sub-national government to promote a certain local pragma-tism at the national level.

Considering Type I multi-level governance there can be concluded that the influence of the supranational partnership on the local level policy is a dynamic pro-cess of administrative, and attitudinal change, promoting European cohesion through indirect communication mechanisms, caused by European integration funds. Conside-ring Type II MLG there can be concluded that partnership unequally influences diffe-rent jurisdictional actors, namely its communication mechanisms are more easily

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ac-cessed by local governments than by civil society or non-governmental organisations. Assessing the development of the European integration fund, evolving from the INTI into the EIF into the current AMIF, there seems to be an improvement considering the involvement of civil society actors into the European community. By simplifying AMIF application procedures, proving evaluation tools, and widening application criteria such as broadening the target group, small local actors are met in there bottom-up policy approach.

Considering the regionalisation versus the re-nationalisation debate, there can be concluded that this research holds an ambiguous position. On the one hand it shows the national Dutch government formally holds an important gatekeeping posi-tion, controlling much of the configuration of European integration policy into natio-nal objectives. Integration accounts for the smallest share of the AMIF, compared Asylum and Return. On the other hand the current AMIF, has increased the share of Union Actions which means more money can be freely spend to the Commission's objectives. Also a quarter of the total amount of AMIF is distributed by the Commis-sion to member-states according to member-states' willingness to spend it on the Commission's priorities, such as resettlement (i.e. resettle refugees from third coun-tries into a member-state). The indirect effects of partnership demonstrate that local actors are becoming more aware of European policy on integration. However, local indicators are not easily communicated, thus this research does not show local influ-ence on European policy-making. It does show a positive attitude among local actors towards future cooperation, either with the Commission or other international stake-holders.

Considering the debate on the decentralising tendencies of national integrati-on policy, there can be cintegrati-oncluded European partnership to some extend causes LAs, and specifically sub-national government, to shape and, more importantly, create lo-cal integration policy. The national government has retrieved responsibility from SNAs to provide inburgeringscursussen and thus does not support initiatives to

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inte-grate migrants. However, European integration funds to some extent empower LAs to provide integration programmes for migrants.

Discussion

This discussion will start with a reflection on the concluded results, and recommend directions for further research. This thesis will end with a modest attempt making re-commendations to European integration policy directed at the local level.

Simplifying AMIF submission procedures and widening the target group is concluded to have a positive effect on the cooperation specifically between smaller CSOs and the AMIF. However, this research does not include data on LAs which have never received EU funding. Also this research did not include interview data from the national managing authority who mediate in European funding. The results are therefore relative to the general accessibility to AMIF, which has not been inclu-ded in this research. Future research could focus on analysing more extensively the accessibility of integration funds. As has been noted, European citizens migrating within Europe are not included in the European integration framework. Future re-search could also include the local dynamic of European-migrant-integration.

European partnership is concluded to have a positive effect on organisational changes and the attitude of LAs towards the EU. This points to a productive base for future cooperation. However, this research included limited data on cooperation. The cooperation between the EU and LAs suggests a certain interdependency. This sug-gests future research could focus on configurations of cooperation. An interesting theoretical framework could be to analyse communication power, framed in network theory, such as Castells' (2009). Means to communicate exist in various configurati-ons and result in different forms of network power. On the one hand the focus could be on the EU as a network, and the role of accountability mechanisms of local actors in legitimising European cohesion policy. On the other hand the focus could be on the agenda-setting power of local actors in the European network.

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This research concluded European policy is, in theory, more accommodative towards integration as a two-way process compared to the Dutch national policy. However, this research does not necessarily claim that local policies, because of their proximity to migrants, are always more accommodative to immigrants' needs. This research did not include data on other municipalities than Amsterdam, or other mem-ber-states than The Netherlands. This suggests future research to focus on cross coun-try, and cross-city differences between implementing European policy on local and national level focussing on accommodating integration as a two-way process.

Finally this research has shown several features of integration policy to be connected to economic policy, such as labour-market needs, employment policies, and privatising civic migrant-integration courses. However this research has not in-cluded data on economic aspects of migrant integration. Future research could focus on how economic and integration policies are connected, focussing on the differences between governance levels.

To improve European integration policy directed at the local level, this re-search points out two possible recommendations. On one hand, to promote a more equal distribution of funds, the results indicate that the EU could invest more in direct cooperation between them and smaller CSOs or NGOs. Simultaneously the EU could provide incentives for LAs to keep working bottom-up, and to cooperate rather than compete with other LAs. When LAs change into more professionalised organisations, accountable towards the EU, the equivalent should compensate LAs for keep working bottom-up. As an author who does not want to underestimate the unequal access to institutions which define and distribute "wealth", I would recommend incentives such as rewarding mechanisms for including community organisations, or immigrants' in-put in integration programmes.

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