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8-6-2017

Author: Claudia Röling | 1272381

Supervisor: Dr. C.H.J.M. Braun

Second reader: Dr. B. Fraussen

Leiden University, Campus The Hague

Master Thesis Public Administration | International and European Governance

Information & Persuasion

A single-case study examining the influence

of interest groups on the European

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Abstract

The main focus of the state-of-the-art-literature on interest groups influence is directed towards the agenda-setting phase and the way in which interest groups try to gain access to the decision-making process. The factors that determine the success of interest groups in influencing the decision-making process have not yet been thoroughly investigated, this study aims to fill this gap in literature. The scope of this research is concentrated on the EU climate policy domain. This study hypothesizes that interest groups representing the interests of businesses have an advantage over interest groups representing the interests of citizens. Moreover, it is expected that interest groups who choose to use (economic) frames in their written documents will more likely achieve frame congruence with the final proposal of the Commission for a reviewed Energy Efficiency Directive. The study draws on position papers submitted by interest groups during the consultation period of the review of the EED. The findings suggest that there is no causal relationship visible in this single-case study between interest groups representing businesses and more influence in the decision-making process. However, there seems to be correlation between the use of an economic framework and achieving frame congruence.

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Table of contents

Preamble... 6 1. Introduction... 7 1.1 Research question... 8 1.2 Social relevance... 9 1.3 Scientific relevance... 9

1.4 Structure of the thesis... 10

2 Literature review... 11

2.1 Classic literature... 11

2.2 Critics... 12

2.3 Contemporary literature... 13

2.3.1 Framing... 16

2.3.2 Evaluating research methods... 18

2.3.3 Theoretical fundament... 20

2.4 Identifying the gap in literature... 22

2.5 Conceptualisation... 23 2.6 Conceptual Model... 25 2.7 Summary... 26 3. Theoretical argumentation... 27 3.1 Hypothesis I... 29 3.2 Hypothesis II... 30

3.3 Scope condition and selection criteria... 32

3.4 Causal inference... 34

4. Research Design... 35

4.1 Operationalization... 35

4.2 Data collection method I: represented interests... 37

4.3 Data collection method II: detecting frames... 38

4.4 Measuring influence... 39

4.5 Measuring congruence... 42

4.6 Reliability and validity... 42

4.7 Case selection... 43

4.8 Justification of unit of analysis... 46

4.9 Justification of research design... 46

5. Empirical Analysis and Interpretation... 49

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5.2 H1: Business versus citizen interests... 53

5.3 H2: Frameworks applied in position papers... 59

5.4 Framework in the Commission’s final proposal... 61

6. Discussion and Conclusions... 64

6.1 Implications: interpreting the results in context... 65

6.2 Shortcomings and suggestions for further research... 66

Bibliography:... 68

Appendix... 72

Appendix I.I: Example of a coded position paper written by Shell... 72

Appendix I.II: Example of a coded position paper written by Shell... 73

Appendix II.I: Coded final Commission proposal... 76

Appendix II.II: Coded final Commission proposal... 79 Appendix III: Excel figure

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Preamble

Dear reader,

With this master thesis I will finish my International and European Governance specialisation of the Public Administration Master. I have studied the influence of interest groups in the decision-making process of the European Commission in the Climate domain.

This single-case study is directed towards the impact of the sort of interests represented and the use of frameworks in written position papers on the success of interest groups in

influencing the European Commission during the decision-making process of the review of the Energy Efficiency Directive. I have experienced the writing of this thesis as an intensive learning process. My motivation to write about the role of interest groups in the climate domain, stems from the will to contribute to a sustainable environment for our world.

I would like to thank my parents for their unconditional support during the process. I would like to thank my sister and her fiancé for their support and tips throughout the process. I would also like to thank my brother for his trust in me and his motivational words. Then, I would like to thank my boyfriend for his enlightening insights.

Finally, I would like to thank my thesis supervisor Dr. Braun for all her support and positive feedback.

I would like to wish you lots of reading pleasure,

Claudia Röling

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1. Introduction

May 31, 2017. Breaking news, American media spreads rumours indicating that Donald Trump has decided to withdraw the US from the Paris Climate agreement. A few days earlier after a G7-summit and a NAVO meeting, German Chancellor Angela Merkel called on all Europeans to fight for their own future and to stop trusting on others. Hereby, she referred to the changed relationship between the EU and the USA after Donal Trump became the President of the United States. Climate change was one of the difficult discussion topics during these meetings. Despite the heavy pressure expressed by the members of the G7 on the American President and the reassuring statement of Italian premier Gentiloni, the host of the summit on Sicily; who said to be convinced that the US will continue to oblige the

agreements made in Paris (NOS,2017). The opposite seems to become the truth, president Trump will not only reverse the climate policies made by his predecessor Obama, he will also not follow the Climate agreement. Two other major players on the world stage, the European Union and China, will respond to the withdrawal of the US by expressing closer cooperation to combat greenhouse gas emissions, according to sources from Brussels (Financieel Dagblad, 2017).

The European Union is already known as an active actor in the climate and environmental domain. Environmental policy was first founded with a European Council declaration in October 1972. More recently after the Climate agreement, European Commission President Jean-Claude Juncker, emphasized the role of the European Union as a central player

throughout international climate negotiations (Europe.eu, 2015). Miguel Arias Cañeta, EU’s chief negotiator, stresses the leading role of the EU in climate negotiations. The

Commissioner expressed his view on the future as follows: “What has been promised must be delivered. Europe will continue to lead the global low-carbon transition we have agreed upon” (Europa.eu, 2015). With this statement Cañeta commits the EU to succesful pursuing the implementation phase, a crucial condition to achieve the ambitions set out in the accord.

The European Commission is responsible on the EU level for the policy-making process of the Climate domain. The EU has to translate the agreements made on an international level to the EU level. Then, Member States have to adopt and implement the new environmental

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policy. The Commission contributes in this process with executing its legislative tasks in this field which can be expressed in Directive proposals. These proposals are submitted for approval to the European Parliament and Council. The revision of the 2012/27/EU Energy Efficiency Directive is a case in this research and is an example of legislation in the climate domain.

1.1 Research question

The Commission does not operate in a vacuum. In contrary, the Commission is influenced by external factors during the decision-making process. The Commission has the possibility to organize a consultation period. During this period all stakeholders can contribute by

expressing their views on the topic via policy papers. The consultation period is freely accessible and contains contributions of Non-Governmental Organizations (NGO’s),

individuals, EU countries, states outside the EU, regional and local action groups, and interest groups representing businesses. The EU’s openness to stakeholders without formal

governmental positions, deserves attention. Some examples of questions that may be asked here are:

 What are the consequences for the legitmacy of the EU?  How much influence do these stakeholders have on the EU?

 If they have influence, why do some interest groups succeed in influencing the EU while others don’t?

 Which factors determine their success or lack of success in influencing the Commission?

The focus of this study is to explain the role of business groups and citizen groups by the interests they represent and the frameworks they apply in their written documents, in a single-case study to the review of the Energy Efficiency Directive 2012/27/EU. The success of these types of interest groups in the decision-making process in the climate domain, is studied with examining their success in influencing the European Commission during the decision-making process of the review of the Energy Efficiency Directive.

The central focus of this research captures the above mentioned questions and leads to the following research question:

‘Why are some interest groups more successful in influencing EU decision-making regarding Climate policy than others?’

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1.2 Social relevance

The European Commission is often criticized for its lack of legitimacy (Dür, 2008;559). Members of the European Commission are not directly elected by the citizens of the EU Member States. However, the role of the Commission in the EU is substantial e.g. its initiative for legislation. The Commission strives a battle over scarce resources with the European Parliament and Council. It is in the Commission’s interest to present itself as an active institution. One way of improving legitimacy and presenting itself as an active institution is by creating legislative output. However the Commission initiates legislative policies in an increasingly wide range and is depending on external actors for knowledge and expertise. Business groups representing industry have an advantage over citizen groups because they possess expert knowledge useful for the Commission, for example technical information about a specific domain. However, the effectivity of citizen groups in influencing the Commission should not be underestimated. Directives proposed by the Commission have to be adapted by the European Parliament and Council. Members of these institutions are elected on national and EU level and are held accountable during these elections. The dependence on the EU citizens to be re-elected makes the members of the Parliament and Council reliant on groups representing the interests of citizens. However, business groups and citizen groups are even further away from a democratic controllable process than the Commission. This

motivates the substantive interest of this research and the social relevance of explaining the effectivity of business groups and citizen groups in influencing the European Commission in the policy making process. The pressing issue of climate change, encouraged by the Paris Climate Agreement and the problematic implementation of international climate regulations in the past, adds to the social relevance of this research.

1.3 Scientific relevance

The influence of interest groups was discussed several times in the Public Administration master’s track. State-of-the-art literature concentrating on the influence of interest groups on the decision-making process of governments usually focuses on other pathways of influence, e.g. gaining access and influence during the agenda setting process (Eising, 2008;18). The operationalization and measuring of the concept of access is less difficult than measuring influence. Measuring influence requires a sophisticated approach in order to obtain

generalizable results. Therefore it is relevant to fill the vacuum in the existing literature and study the influence of business and citizen interest groups with a single-case study in which every aspect of the case will be inspected.

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1.4 Structure of the thesis

The literature related to influence and the research question will be identified in the literature review in chapter two. The relevant literature will be discussed and evaluated. The literature overview will show a gap in the state-of-the-art literature, which represents the relevance of this research. The hypotheses and assumptions will be derived from theory in chapter three. The hypotheses and assumptions will result in a proposed answer to the research question and the validity of this answer will be substantiated with arguments. The scope conditions and selection criteria will be discussed and the concepts will be theoretically defined. Next, a conceptual model will be tested with empirical findings. Chapter four will present a

justification of the unit of analysis and research design. The theoretical concepts discussed in chapter three will be operationalized in chapter four together with a discussion of the

reliability and validity of the measurement of influence. Moreover, the full analysis and a discussion of the results of the research will be presented in chapter five. The thesis is completed with the conclusion in chapter six. A summary of the main research findings will be given in this chapter. Followed by a discussion of the contribution of the study presented in this thesis. The last chapter will also deal with the identification and discussion of the

limitations of the analysis. Finally, suggestions for further research and practical implications will be given based on the findings from this study.

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2 Literature review

This chapter zooms in on the existing literature of European Union politics and what has been researched about the influence of interest groups in decision-making processes. Special attention will be paid to literature focused on the effect on influence. of the sort of interests represented by interest groups and on the concept of framing. This attention accompanies the two hypotheses that will be tested. The focus is further specified by paying attention to the role of interest organisations in the international climate policy domain.

2.1 Classic literature

Research conducted by David Truman in 1962 emphasized the importance of interest groups in the governmental process. Truman was one of the pioneers who revealed the significant role of interest groups in the decision-making process. He argued that the political landscape of the government of the United States functioned as fertile ground for interest groups on which they could flourish and position themselves in their role as advocates of interests. Truman emphasizes the effect the institutional background may have on the success of interest groups. This effect is not exclusively visible in the political landscape of the USA during the sixties. Nowadays, more than half a century later, and on the European continent, the institutional context in which interest groups operate, may still have an effect on their success. The effect of the institutional context of the European Commission is included in this research.

Olson writes another classic in the literature in 1965. Olson focuses on the rational behaviour of individuals and connects the effects of this behaviour to advantages and disadvantages of big versus smaller groups. Olson assumes individuals to behave in accordance with

rationality. Olson distinguishes common goods into exclusive and inclusive goods. The supply of exclusive goods is limited, whereas the supply of inclusive goods is not bounded to limitations. The connection between the dissertation of Olson and this research becomes visible when attributing goods related to the climate domain, such as clean air and water, as examples of exclusive goods. The central concern, which the Commission attempts to address with the review of the EED directive, is the scarcity of energy resources. Its sustainable use is highlighted in order to protect exclusive climate-related goods.

Olson (1965) argues that the increasing number of participants in a group, results in reduced revenue for each member. Every firm for example, would like to maximize its profits. Though, every extra group/firm that succeeds in maximizing its profits, results in diminished

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profits for every single firm. Moreover, Olson argues that organizational costs expand together with the rise in-group size. Hereby, Olson challenged the general tendency at that time, based on the assumption that individuals interested in the common will act as a

collective to pursue their interests. The logic of collective action is translated into individuals who will have the incentive to ‘free ride’ on the efforts of others in the collective. According to Olson, small groups will have an advantage over large groups because they face lower costs and maintain incentives to work towards their goals. This research indicates that smaller interest groups will have more success in influencing the European Commission than interest groups representing the interests of more members. This study will focus on; collective action in the climate domain, the sort of interests represented and the effect this has on success in influencing the Commission and finally, the institutional background in which the decision-making process takes place is used as scope condition.

2.2 Critics

Theodore Lowi’s “Interest Group Liberalism” (1969) presented a critical note on the role of interest groups in the United States. Lowi perceived the increasing role occupied by interest groups, as a threat for democracy in the United States. Lowi argued that Congress abandoned its responsibilities by shifting their authority to interest groups, by delegating them to govern via their influence, over the bureaucracy. The implications of this contribution are still valid today, decades later, when we shift our view towards EU politics. The European Union is also criticized for a perceived democratic deficit, as we will see shortly in the discussion of

Böhmelt, Koubi and Bernauer (2014). The citizens of the EU do not directly choose the European Commission, whilst it fulfils significant roles, such as developing legislation and hereby affecting the life of citizens. The role of interest groups in the decision-making process may therefore be scrutinized. Questions rise such as: “Do interest groups enhance or worsen the democratic legitimacy of the European Commission?” Concerns about a democratic deficit highlight the social relevance of studying the influence of interest organizations on the decision-making process of the Commission in the climate domain.

To sum up, this study attempts to draw further on the implications of the discussed classic literature on the role of interest groups in EU politics of today. Before doing so, we will first debate which new insights on this topic have been obtained since.

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2.3 Contemporary literature

The diverging roles of interest groups and the government may result in conflict in political cultures. Interest groups represent the narrow interests of a subset of stakeholders. Their goal is to obtain preferential treatment from the government in their area of concern, whereas the government should include and represent the interests of all citizens. In addition, the

government is supposed to represent impartiality and authority. Although these contradictory goals are a recipe for conflict, both actors are mutually dependent on each other. Government institutions as for example the European Commission depend on expert information derived from interest groups. The Commission allows interest groups to access the policy-making process via different access ways and at different degrees. This varies from setting up formal consultation periods, to informal meetings between lobbyists and bureaucrats, till providing interest groups with financial aid. This research will focus on access granted via the

consultation process of the review of the EED, in the EU Climate domain.

We will now zoom in to the literature relevant for the role of interest organizations in the international Climate domain and in the EU. Hanegraaff (2015) deals in his research with the mobilization of interest organizations representing business interests and NGOs representing citizen interests on the level of UN Climate Summits. Hanegraaff explains the evolvement of interest group communities lobbying the UN climate summits in the last twenty years. A distinction is made between opponents of more-open international organisations, represented in the collective action perspective and proponents who see themselves represented by the neopluralist perspective. The collective action perspective argues that business and

specialized interest groups are privileged, because they face fewer collective action problems (Hanegraaff, 2015;83). In contrast to the neopluralist perspective, which emphasizes the decreasing role of collective action problems, which will result in more diversity in interest representation. To sum up, there is agreement between the collective action perspective in the article of Hanegraaff and this study in the belief that business groups are privileged. However, the belief of Hanegraaff is based on the assumption of fewer collective action problems. This study looks outside interest organisations for their perceived advantage; it takes the

institutional context of the European Commission in which they operate in consideration. The dependence of expert information, assumed to be best provided by interest groups, is seen as the underlying force for the privileged position of interest organizations representing business interests.

Böhmelt, Koubi and Bernauer (2014) explain the successfulness of interest groups representing business interests by addressing the motivation for governments to provide

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access to the decision-making process. They argue that the decision of governments to allow access is motivated with their aim to mitigate the democratic deficit and improve legitimacy. The authors agree to some extent with the research conducted by Lowi in 1969, in his article Lowi also criticized the role of interest groups and the consequences for democracy. The European Union has been prone to criticism concerning a perceived democratic deficit (Böhmelt et al., 2014). Especially the European Commission, since this institution consists of members who are not directly chosen by EU citizens. The institutional characteristics of the EU force the Commission to strive for resources with other institutions, the European Parliament and the Council. The Commission prefers to present itself as an active and effective institution. One way to obtain this goal is to create legislative output. The

Commission depends for information about complex issues on the expertise of interest groups closest to the topic of concern. This study therefore expects that interest groups who represent the interests of businesses have an advantage over other interest groups because they possess information and are therefore useful resources for the Commission in pursuing their goal of creating legislative output. At the same time, cooperating with business interest groups by providing them access and accepting (some of) their interests while receiving technical information improves legitimacy. On the other hand, soothing the concerns about a

democratic deficit by taking the opinion of stakeholders representing businesses into account.

Research conducted by Beyers in 2004 examined European interest associations combining public political strategies with traditional forms of inside lobbying or seeking access to public officials (Beyers, 2004;234). In his study, “Voice and Access, Political Practices of European Interest Associations”, Beyers has chosen to sketch two explanations of the use of influence strategies by interest groups, the theoretical perspective of resource-based explanation

focusing on the nature of the mobilized interest and the institutional account, emphasizing the explanatory power of varying institutional conditions. Beyers and Truman both emphasize the role of institutional conditions. This study will validate the first theoretical perspective in a different setting. The first hypothesis tests if the nature of mobilized interests, business interests, results in more success in influencing the decision-making process of the Commission in the climate domain.

Agné, Dellmuth and Tallberg (2015) contribute to the discussion of democratic legitimacy with their article: “Does stakeholder involvement foster democratic legitimacy in international organizations?” What stands out in comparison with other authors concentrating on the democratic legitimacy, is the normative sound of this research question and the emphasis on

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testing one of the possible solutions for the perceived democratic deficit. Whereas Lowi (1969) solely questions the role of interest groups in the democratic deficit. Besides this, Böhmelt et al. (2014) and Agné et al. (2015) share the belief that governmental institutions allow access based on the motivation to improve legitimacy and reduce the democratic deficit. Agné et al. (2015) address the so-called sociological variant of the stakeholder argument and test this empirically. The sociological statement argues that institutions do not allow access by including or giving affected people the chance to represent their interests in order to accommodate the interests of those affected. To the contrary, the inclusion of stakeholders is motivated by the goal to create a perception of democratic legitimacy among stakeholders. They test the sociological argument by asking stakeholders how they perceive the argument, focused on representation, accountability and deliberation (Agné et al., 2015;467). The results are remarkable, stakeholders do not support the argument and representativeness scores low. The authors try to explain this outcome by pointing out the differences in the role of states, which have had more time to establish their position in international organizations when compared to stakeholders. Furthermore, the limited availability of resources such as money for stakeholder organizations are also addressed as a reason for the low representativeness score (Agné et al, 2015;484). In this study, together with other studies such as the study of Lowi (1969) and Böhmelt et al. (2014), the social relevance is shown for European citizens who are affected by the decisions of the EU with regard to taking action to counteract climate change.

Eising (2008) provides a critical review of the existing literature in his living review, “Interest Groups in EU Policy-making”. Whereas the other discussed literature focused on consequences of interest groups gaining access to the political process for democratic legitimacy (for example Truman, 1962; Lowi, 1969; and Böhmelt, Koubi and Bernauer, 2014) and pays attention to characteristics of interest organisations (Olson, 1965). Instead Eising discusses the gap and controversies in the literature. Eising argues that they are the result of a set of factors among which the difficulty to nail the concept of interest group to the wall. There exist many different conceptualisations of interest groups in the literature. Moreover, Eising argues that the variety of theoretical perspectives stands in the way for an accumulation of knowledge. The research conducted by Eising suggests that researchers should commit themselves to more rigorous theory testing. This research will just do that. According to Eising, scarce communication among scholars impedes the accumulation of knowledge. Eising (2008): “The poor communication is an important reason for the lack of transparency in the literature and the emergence of contradictory points of view is the compartmentalization of theoretical

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traditions” (Eising, 2008;6). The author believes that EU institutions create and shape the arenas of interest intermediation. This study will check this with the consultation period of the review of the EED.

Eising reviews that scholars agree on the importance of EU regulation as stimulus for interest groups to mobilize, seek access and exert influence on EU policies. Furthermore, there is agreement on the idea that resources; policy information and financial means, are important prerequisites for access and influence. From this review it appears that policy information is perceived to be a crucial exchange good by many authors. This latter argument justifies the first hypothesis of this study and is translated to the sort of interests represented as exchange good to the Commission tested in the Climate domain. This study acknowledges the belief that information is an important exchange middle for interest organizations, and sees the dependence for information from the Commission as the underlying motivation for the mutual relationship between the Commission and interest organizations.

The research conducted by Dür and de Bièvre in 2007 addresses the difficulties in analysing influence. In “The Question of Interest Group Influence”, Dür and de Bièvre address the difficult operationalization of the concepts of power and influence, the construction of reliable indicators and empirical measurement. Their aim is to improve the state-of-the-art literature. They argue that influence of interest groups can be visible in two guises of political outcomes. Official positions taken by public authorities and the final implementation of the policy (Dür and de Bièvre, 2007;3). The field of environmental and climate policy is often criticized to fail to deliver its promises, due to difficulties in the implementation stage. However, this study concentrates on the first guise of political outcomes, consisting of the official statements taken by the Commission in its final proposal. Dür and de Bièvre (2007;5) approve the

argument by Eising (2008) that institutions of the EU may shape a fruitful environment for interest groups. This study shares the assumption that politicians depend on resources for re-election, and interest groups may fill this gap by exchanging their resources, e.g. information, for influence over outcomes.

2.3.1 Framing

We will now shift our focus to literature on framing. Klüver, Mahoney and Opper (2015) examine how interest groups employ framing to lobby the European Commission in the policy formulation stage. They study the same stage of the policy-making process as this research is intended to do. Framing is described as: “Strategically highlighting some aspects of a policy proposal while ignoring other aspects on purpose” (Klüver, Mahoney and Opper,

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2015). By doing so, the interest groups try to gain an advantage in the policy debate. The central argument reads that frame choice is a complex process, which is affected by interest groups and contextual characteristics. All interest groups can apply framing, irrespectively of the resources they possess. However, the available types of frames are constrained to interest group characteristics. The choice of frame is a strategic decision. Interest groups respond to the logic of membership or the logic of influence when they decide on their frame choice. When they follow the logic of membership they are required to behave in accordance with their constituency structure to ensure a continued stream of resources. Examples derived from this study are associations representing the interests of firms operating in the energy sector. The argument is based on the basic survival interest of interest groups. On the other hand, the logic of influence demands for exercising influence over decision-makers and policy-making outcomes. Klüver et al. (2015) differentiate interest groups into firms and associations. This study also differentiates between various sorts of interest groups.

Boräng and Naurin (2015) study the appearance of frame congruence between lobbyists and European Commission officials, which they define as: “The degree to which key

policymakers’ frames correspond to the frames of lobbyists” (Boräng and Naurin, 2015;499). They emphasize the importance of two contextual factors, the scope of the conflict and the media coverage of EU legislative proposals. They use generic frames and distinguish between; self-, other-, public-, and ideal-regarding frames.

Interviews were conducted with respondents representing interest groups and Commission officials responsible for preparing the specific proposal after the consultation phase. The interviewees were asked what they perceived to be at stake in the proposal at hand, instead of asking which frames existed (Boräng and Naurin, 2015;505). The examination of congruence in frames used by the interest organisations and the Commission has been an inspiration for the theoretical framework and formulation of the second hypotheses in this thesis.

Chong and Druckman (2007) come up with definitions for framing and framing effects in their article “Framing Theory”. Framing in communication is defined as the “key

considerations emphasized in a speech act”, (Chong and Druckman, 2007,107). The definition of these authors is more directed towards framing in communication via speech than the definition employed by Klüver et al. (2015). However, they both define in different ways, the importance of appointing ‘key considerations’ or ‘highlighting some aspects’ in framing. The research defines framing effects as: “How frames in the communications of elites (e.g., politicians, media outlets, interest groups) influence citizens’ frames and attitude” (Chong and Druckman, 2007;109). Börang et al. (2014) give a different definition for the

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concept of framing: “selecting and highlighting some features of reality while omitting others”, (Börang et al. 2014,190). Again, the notion of highlighting, key considerations (Chong and Druckman,2007) or highlighting some aspects (Klüver et al., 2015). While Chong and Druckman don’t use words pointing out neglecting or omitting other features or aspects of the policy proposal. The definition of framing in this study resembles most the definition of Börang et al.

Research conducted by Iskander de Bruyker last year (2016) presents a research agenda for interest group studies specifically directed towards framing and advocacy. De Bruyker discusses the contrast in level of analysis and how influence is determined. A distinction is made between issue-specific and generic frames and between equivalence and emphasis frames. Furthermore the differences in unit of analysis are described as macro- and micro-level framing. Here, the author points out what’s missing in his view: “An analysis that links the framing efforts of interest groups to the macro-level of policy debates” (De Bruyker, 2016;6). The article ends with suggestions for further research in which questions about framing as political strategy and the effectiveness of frames must be addressed.

Baumgartner and Mahoney (2008) discuss two faces of framing, individual-level framing and collective levels. They argue that interest groups do not individually determine the framing of an issue; instead they are constrained because other policy actors also try to frame an issue in a certain way. They emphasize that the dimension dominating the debate at a certain point in time is determined endogenously as well as exogenously. By endogenously, they mean

through the efforts of individual lobbyists. Exogenously the dominant dimension in the debate is affected through stochastic events, crises and developments (Baumgartner and Mahoney, 2008;436). This distinction is valuable and the implications of it have to be taken into account for this study as well. This research concentrates on endogenously effects, however

exogenously effects, such as in the review of the EED case, the event of a crisis related to climate change, have to be held constant because this may bias the outcome of the decision-making process.

2.3.2 Evaluating research methods

In the study named: “Pressure and Expertise: Explaining the Information Supply of Interest Groups in EU legislative Lobbying”, de Bruyker (2016b) uses an analysis of interviews with lobbyists to discuss two modes of information supply.

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- The first mode is characterized by the transmission of technical, legal and economic expertise. This mode is known as the general description of the interaction between lobbyists and policy-makers.

- The second mode is characterized by the supply of political information. De Bruyker (2016b;599-600) argues that organized interests try to put pressure on policy-makers to consider acting in accordance with the preferences of the members and supporters they represent, by supplying them with political information.

In accordance with Dür et al.(2015) in “When and why does business lose?” on the advantages and disadvantages in exerting influence related to the background of the issues represented, a distinction is made between directly elected principals and principals who cannot directly be held accountable by voters. Because of this fact de Bruyker (2016) expects that political information is least likely to be communicated to the Commission in comparison with the European Parliament and Council. While the Commission is most likely the receiver of technical, economical and legal information when compared to the same institutions (de Bruyker, 2016b;603). This part of the research conducted by de Bruyker will serve as a theoretical cornerstone for the first hypothesis in this thesis. Furthermore, it will also be used for the second hypothesis, in combination with theory on framing. In contrast to the research design implicated by de Bruyker, which uses 125 European legislative proposals, this research will take a closer look by testing the hypothesis in a single case study concerning the review of the EED.

Dür (2008) discusses the advantages and disadvantages of three different methods to measure interest group influence in the EU; process tracing, assessing attributed influence and gauging the degree of preference attainment. Dür argues that the difficulties involved in measuring influence, result in controversies and a gap in the literature. Three problems hamper measurement of influence; the existence of different channels of influence, occurrence of counteractive lobbying and the fact that influence can be wielded at different stages of the policy process (Dür, 2008;561). The central question of how much influence does interest groups have on policy outcomes in the EU is only addressed in a small number of studies. This master thesis underlines the existing gap in the literature, and aims to contribute with addressing this question by applying the method of assessing the degree of preference attainment. I value the notion on methodology of Dür because the evaluation of methods is very useful in the consideration concerning the method section of this research. Furthermore, I agree with the author on the definition of influence: “Influence is an actor’s ability to shape a

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decision in line with her preferences or a causal relation between the preferences of an actor regarding an outcome and the outcome itself” (Dür, 2008;561). In the conclusion Dür stresses the importance of the issue of influence because it is indispensable to explain policy outcomes and the impact interest groups have on policy outcomes is central to debates concerning the EU’s democratic legitimacy (as discussed by Truman, 1962; Lowi, 1969; and Böhmelt, Koubi and Bernauer, 2014).

The contribution of Lowery (2013) to the literature on interest groups is valuable because it explains the null results in existing research. Lowery argues that null results merit

explanation; knowledge about the reason for many null hypothesis may provide solutions for overcoming problems in future research. According to Lowery, the answer may lie in the conceptualisation of influence. The article looks back on classic literature on urban power. The urban power literature field struggled with similar questions about defining and observing the related concept of power. The article sums op a template of null hypotheses and discusses how these bear on interpreting the many null findings. What stands out in this article is the focus of a majority of the literature on controversial issues. Selecting on issues based on media attention has implications. Salient issues might be least expected to be influenced by interest groups, precisely because public opinion constrains the policy making process. The case central in this study, the review of the EED did not receive a lot of media attention or contributions in comparison with other cases such as REACH, which received 6400 contributions compared to 61 non-survey based contributions for the review of EED

(Europa.eu;2015b) Consequently, the salience of this issue is fewer and suggests that we deal with a less controversial issue. According to Lowery (2013), the lesson to be drawn from the inventory of null hypotheses is one of modesty. The author agrees with earlier discussed opinions of other researchers in the field stressing the complexity of observing influence. Therefore, Lowery argues that research is limited to capture brief snapshots, nonetheless these snapshots are important.

2.3.3 Theoretical fundament

Klüver (2011) aims to overcome shortcomings in literature by presenting a new theoretical exchange model that identifies; information supply, citizen support and market power of lobbying coalitions as key determinants of interest group influence on policy formulation in the EU. The work of Klüver is valuable for this research because of the similarity in research methods. Klüver empirically evaluates hypotheses based on quantitative text analysis. The

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text analysis is applied to an online survey among interest groups. This research will apply text analysis as well, however this will be done by manual coding and will be applied to policy papers contributed during the consultation period. In “Lobbying in coalitions: Interest group influence in European Union policy-making” (2011), Klüver measures influence by comparing policy preferences of interest groups with the position of the Commission before and after the consultation period. This master thesis will measure the independent variable, influence, in a similar fashion. However, influence in this research will be measured more thoroughly, since it is a single-case study. This limits the scope of the research and may result in implications with generalisation. However, investigating influence on a micro level will develop worthy results as well. Another difference is related to the level of analysis. Whereas Klüver looks at the level of coalitions of lobby organisations based on the assumption that lobbying cannot be understood as individual endeavour, I disagree and assume that

understanding lobbying is also possible as individual endeavour.

The article “When and why does business lose?” written by Dür, Bernhagen and Marshall (2015) forms the basis for one of the hypotheses. Dür et al. discuss the division in the

literature on lobbying in the EU. One spectrum of the literature perceives business actors to be more successful in influencing policies. In contrast to the other spectrum in literature, which links the institutional structure of the EU to be beneficial for citizen groups. Business groups defend the status quo; they are not supportive of further regulation in the form of new policies that may restrict their activities. Maintaining the status quo equalizes zero legislative output. Whereas citizen groups tend to prefer policy change, in other words modifying the status quo. Modifying the status quo equals productivity in terms of legislative output for the European Commission. Since the Commission competes with the Council and European Parliament for scarce resources, it aims to present itself as an active institution. Creating legislative output not only means carrying out its tasks, it may also involve expanding competences, since the Commission is usually assigned to monitor the implementation of policies. However, the Commission depends on the Council and Parliament. These institutions have to adopt their policy proposals. These institutions can be held accountable during elections, in contrary to the Commission. Members of European Parliament and Prime-Minsters of member states, depend on support from society. Citizen groups may provide this support when they are capable to mobilize their members to vote for politicians who act in line with their interests. This creates a privileged position for citizen groups compared with business groups.

However, Dür et all assume that business actors are more successful when policy issues know little conflict and when the EP has limited legislative powers (Dür, et all, 2015). This study

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tests a contradictory hypothesis with expects that not citizen groups, but business groups will be more successful.

In: “Legislative lobbying in context: Towards a conceptual framework of interest group lobbying in the European Union”, Klüver, Braun and Beyers (2015) focus on two sets of contextual factors. The first set consists of interest group activities shaped by policy-related factors; complexity, policy type and salience. The second set focuses on varying institutional factors within the political system of the EU and national political systems. The authors agree with Eising (2008) and Böhmelt et al. (2014) on the view that European institutions seek expertise and support from organized interests, which makes up one side of the mutual relationship between the EU and interest groups. Another point of agreement is visible in the assumption that the institutional environment of the EU sometimes enables interest groups to pursue their interests. The assumptions made in this study are equivalent. This study also assumes that the institutional environment wherein the Commission sets up a consultation period is beneficial for interest groups to pursue their interests concerning the review of the EED.

2.4 Identifying the gap in literature

This study aims to give more insight in a puzzled and understudied concept of EU politics: the influence of interest groups on the decision-making process in the EU on the Climate domain. Few researches have ventured to study the influence of interest groups because of difficulties related to conceptualisation and measuring. Many authors stress the need for further research on this topic and especially on the influence of framing (De Bruyker, 2016; Eising et al. 2015). The objective of this study is to add to the existing knowledge by combining two approaches discussed in this literature review. First, the different success rates of interest groups grounded on their characteristics, representing citizen interests or business interests will be empirically tested with help from the preference attainment methodology discussed by Dür (2008). Based on the theory discussed in: “Interest group success in the European

Union: When (and why) does business lose?” (Dür et al., 2015). The second theory is derived from the article of Klüver et al (2015), Börang and Naurin (2015), and de Bruyker (2016b) and will test the effect of interest groups employing framing, on their influence to lobby the European Commission. Studies examining frames applied by interest groups are very rare; this gap in the literature will be addressed in this study. The combination of examining the effects of applying frameworks in written documents and interest organization characteristics,

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the sort of interests represented, on the success of influencing the decision-making process, seems to be unique in this research field.

2.5 Conceptualisation

We will now continue with the conceptualization of the key concepts that are central to this research, the conceptualisation is based in part on the reviewed literature. Before we start the conceptualization process it is important to define the word itself. What are concepts? In his book “Research Design in Political Science”, Toshkov defines concepts as abstract

generalizations that represent a class of objects (Toshkov, 2016;84-85). The structure of concepts consists of multiple elements; term, intension, extension and indicators. This sequence will be used to conceptualize;

 Interest groups,  Interests,  Influence,  Frame,  and framing.

These are the main concepts on which this study and its hypotheses, the main explanatory variables and outcome variable are built.

There is great variety in the literature on the label appropriate for the concept of interest groups. Other wordings for interest groups who are used interchangeably in the literature and in this study are: interest organizations, pressure groups, lobby organizations and lobbyists. The concepts central term in this study is: interest groups. We prefer to leave out the word lobby, because some interest groups might be offended when this term is used. Now we shift our focus to the analytic definition of interest groups, which resembles its intension (Toshkov, 2016;90-91). The Merriam-Webster Dictionary defines interest group as: “A group of people who try to influence politics or the policies of government, business, etc., in a way that helps their own interests”. This research defines interest groups in the same manner as is done in the Merriam-Webster Dictionary, only a small adjustment is made concerning the part which policies are the goal of influencing practices. Thus interest groups are defined as follows: “A group of people who try to influence politics or the policies of government, on a national or international level, in a way that helps their own interests”. The extension of a concept refers to the objects the concept refers to. The concept of interest groups refers to all the interest groups who pursued their interests via submitting position papers during the consultation period of the review of the EED. The most important indicator for interest groups in this study

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is the mere fact that they submitted a position paper during the consultation period, which defines them as interest groups that strive to pursue their own interests.

From the conceptualisation of interest groups we will now passage to the conceptualisation of interests. The Merriam Webster Dictionary defines interests as: “To induce or persuade to participate or engage” or as “To engage the attention or arouse the interest of”. These definitions point to attracting the attention/interest of someone to a particular topic. This is basically what interest groups are trying to do in their activities; framing is a good example of this. However, attaching them to a particular interest group can further specify interests in this study. There are differences in the interests that are represented by interest groups, for

example between interests related to business and interests related to environmental NGOs. The intension of interests is: “Interests are pursued and represented by an interest

organization”. The extension of interests in this study refers to all the different interests that are pursued in the submitted position papers. Distinctions between sorts of interests are made based on their background or nature, e.g. interests related to business (employment, economic welfare, jobs etc.). Indicators of interests become visible in sentences and words in the texts of position papers, examples of such sentences and words are; we strive to, our main goal is to, we think it is very important that...

The concepts of frame and framing are obviously closely related to each other and are therefore discussed at once. Framing is defined by the Merriam Webster Dictionary as: ´The arrangement of parts that gives something its basic form”. Authors in the classic and

contemporary literature disagree on the definition of framing and the concept of frame. Entman (1993;53) defines frames as: “Highlight some bits of information about an item that is the subject of communication, thereby elevating them in salience”. Hereby, Entman also discusses the perceived effects of using frames, or increasing salience about a particular item (as cited by Börang et al 2014;190). Framing is defined by Entman (1993;52) as: “Selecting and highlighting some features of reality while omitting others”. Daviter (as cited by Börang et al.,2014), on the other hand, argues that policy frames “Identify what is at stake in an issue”. I would like to add to this definition; “according to the opinion of an interest group”. Börang and others also refer to how Schattschneider defined frames and its consequences for political conflicts: “What is perceived to be at stake is likely to matter greatly for the scope of a political conflict = and the scope of a conflict will have a large impact on its outcome” (as cited by Börang et al.,2014;190). I would like to take over Entman’s definition of framing, since I agree with his conceptualisation, so framing is defined as: “Selecting and highlighting some features while omitting others”. The intension and extension of frames are defined as:

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“Selected and highlighted parts in the position papers submitted by interest groups, which clearly relate to the interests the particular interest groups pursue”. The classification justification of frames will address indicators of different frames.

Influence is defined in the Merriam Webster dictionary as: “The power to direct the thinking or behaviour of others usually indirectly”. The outcome variable of this research is influence. The success in influencing the European Commission in the decision-making process of the review of the EED is measured as the similarity in statements made by interest groups in their position papers and statements made by the Commission in their final proposal, this resembles the extension of the concept. Interest groups try to convince the Commission of the

importance of their interests and arguments via submitting position papers and sometimes via applying frameworks. In the literature review different conceptualisations of the concepts were discussed, as well as the concept of influence. The definition of Dür (2008;561) is most appropriate to practise in this research: “Influence is an actor’s ability to shape a decision in line with her preferences or a causal relation between the preferences of an actor regarding an outcome and the outcome itself”. This definition also captures this study’s method to measure influence.

Influence and frame congruence are causally closely related. In the second hypothesis frame congruence is seen as influence. Frame congruence can be defined as general agreement in the framework applied by an interest group in their position paper and the final proposal designed by the Commission. When the Commission adopts the framework applied in a position paper, or in multiple position papers in which the same framework is chosen, this is called frame congruence. It is assumed that frame congruence is a signal for attained influence.

2.6 Conceptual Model

The central concepts of this study are visually displayed in the model below. Connecting lines denote the causal relations between concepts. With this conceptual model this study aims to understand unfolding empirical outcomes in the decision-making process concerning the review of the EED in the climate policy domain. Two equal outcome variables are present; frame congruence and influence. Since these variables are interchangeable they are connected with each other through a line with arrows on both sides. The main explanatory variables are; interest groups representing business interests and the use of (economic) frames in position papers contributed by interest groups during the consultation period. This study deals with these two variables separately. It is expected that the variables on the left have an effect on the outcome variable.

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2.7 Summary

To sum up, there are several trends to be distinguished in the literature on interest groups and politics of the European Union. Some scholars focus on the effect of interest group

characteristics on the success of influencing the decision-making process (Olson, 1965). Whereas others tend to focus more on the institutional context in which policy development takes place and the consequences for democratic legitimacy of the political process (Truman, 1962; Lowi, 1969; and Böhmelt, Koubi and Bernauer, 2014). Another discrepancy is made whereby the successfulness of interest groups is attributed to the sort of interests they represent, business or citizen interests (Klüver, et al.,2015). Another part of the literature emphases on how interest groups try to affect governmental institutions. How can interest groups gain access to policy makers? Hanegraaff (2015) focus is on the influence of interest organisations in the international climate domain of UN Climate Summits. Other scholars focus on how interest groups can try to persuade policy makers by offering information about certain policy issues (Klüver, 2011;De Bruyker, 2016b; and Böhmelt, Koubi and

Bernauer;2014). Another way to convince policy makers of the importance of their interests is by strategically applying frameworks (Klüver, Mahoney and Opper, 2015; Börang and

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3. Theoretical argumentation

The general goal of this research is to explain the outcome of the efforts of the contributors, the interest groups, in trying to influence the European Commission with their submitted policy papers during the consultation period of the review of Energy Efficiency Directive 2012/27/EU. Before this general goal can be achieved, the first fundamental question has to be answered: “Have interest groups influenced the European Commission?” According to the assumption, adopted in this research, interest groups did have influence on the European Commission. This assumption is based on the institutional nature of the Commission and the policy-making process. The institutional nature of the Commission causes the need for

technical expert information in order to develop the Energy Efficiency Directive (De Bruyker, 2016). In addition, information provided by non-business interest groups, containing

information about the opinion of the public, is also assumed to be welcomed by the Commission since they need approval for their proposal by the elected European

Parliamentarians and Heads of State in the Council. It is assumed that these reasons have contributed to the decision to create a consultation period in which stakeholders can submit their vision on the issue.

The proposed answer to the research question raised in the introduction is twofold. The successfulness of interest groups in their attempts to influence the EU decision-making process regarding Climate policy will be explained with help from two hypotheses based on various theoretical ideas derived from the existing literature. The first hypothesis will examine the role of the first explanatory variable, the interests represented by the contributor or interest group. Two general sorts of represented interests are distinguished, business and citizen related interests. The first one, business interests is further refined based on the type of business being represented, because business related interests make up the majority of the non-survey based contributions. An overview of the classification of categories in citizen and business interests will be discussed later on.

The first hypothesis is based on the assumption that the European Commission seeks to present itself as a valuable institution. The European Commission strives for scarce resources, e.g. money and time, with the European Parliament and the Council. There are many

differences between the institutions. The difference that is central for this research is visible inside the organisation. The employees of the Commission, Commissioners and their

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member states. In contrast, all EU citizens entitled to vote elect members of the European Parliament. The Heads of State and/or government leaders are elected on a national level. This characteristic could create changes and differences in the behaviour of European Parliamentarians and members of the Council versus Commissioners. The theory of de Bruyker (2016) is in line with the vision of this research and forms the foundation for this hypothesis, assuming that these factors influence the admissibility of the European

Commission for various types of information. The assumption that the Commission does not depend on the citizens of the European Union in regard of being re-elected, leads to the proposition that the European Commission is more receptive for information provided by interest groups representing business. I assume that in general, interest groups representing businesses can better provide the European Commission with detailed expert information on policy issues, than other interest groups. Because other interest groups, as for example NGOs and other interest groups representing citizen’s interests, do not possess over such

information.

In regard of political information, De Bruyker (2016) expects that the Commission is least likely to receive political information, when compared with the European Parliament and Council, because the Commission is not elected and this form of information is therefore less valuable for the Commission than for the other two institutions. Given the institutional characteristics and the function of the European Commission as main legislator of the EU, it is assumed that the European Commission is more acceptable towards and the most

‘appropriate’ EU institution to exert legal, technical and economic information for interest groups. The Commission is dependent on expert information in order to carry out its task as legislator. The Commission lacks the capabilities to have high expertise on every policy field due to its limited capacities. From the wide range of possible influencers, representing the interests from industry, whether it is private companies, or associations representing sectors of industry, are assumed to possess the most valuable knowledge. Other influencers, for example individuals or non-governmental organisations (NGOs) will probably have relevant

knowledge as well. However, it is assumed that influencers representing the interests of industry/businesses surpass their level of knowledge. In addition, it is assumed that Commission bureaucrats pursue goals in line with the interests of the EU as a whole. Therefore it is assumed that Commission employees desire to receive the best and most complete information about the issues at stake.

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The different streams of influence are one of the three reasons that make it so difficult to define influence according to Dür (2008).

This research will test the hypothesis on the influence expressed by submitting position papers during the consultation period set up by the Commission. It is assumed that the fact that the Commission initiates a consultation period is a sign of their admissibility for influence in the form of legal, technical and economic information.

3.1 Hypothesis I

The literature on interest group influence in the European Union is divided. The article written by Dür, Bernhagen and Marshall (2015), “When and Why Does Business Lose”, is a good example of the different perceptions on interest group influence. These authors argue that not businesses but citizen groups have an advantage in influencing the EU due to the same institutional structure. Whereas, this research bases its assumptions leading up to the hypothesis that due to the institutional structure in which Commission employees are not dependent on re-election, they are more admissible to expert information provided by interest groups representing business interests. Dür et al. (2015) argue that groups representing business interests often have significantly less influence because they usually defend the status quo. While citizen groups tend to strive for a modification of the status quo, because of the assumption made by Dür et al. that the Commission prefers to present itself as an active institution by producing legislation, the citizen groups are said to have an advantage. Since new legislation is similar to modifying the status quo. Dür et al. formulated three hypotheses in their article, the most applicable to my research is the first hypothesis, this hypothesis contradicts my proposed answer to the research question: “Business actors are less successful than citizen groups” (Dür et al, 2015). As we will see shortly, the hypothesis in this research expects the opposite.

In contrast, this study is assuming that Commission officials do not base their agenda setting, in which is discussed where new legislation needs to be developed or existing legislation needs to be adopted, solely on the wish to legitimate their existence by creating enough output. Instead, I expect the Commission officials to act in accordance with the goals of the European Union as a whole, with no expressed preferences for their own institution. The EU benefits more from technical funded legislation than only creating legislation, which alters the status quo for the mere fact of carrying out its legislative task and by doing so, underlining its reason d’être. The effect of the main explanatory variable, the nature of interests represented by an interest group will be tested by means of the following hypothesis.

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H1: In general, interest groups representing businesses interests are more likely to have influence on the decision-making of the Commission regarding Climate policy.

Based on the assumptions derived from the theory, an expectation of the answer to the research question can be given. The research question introduced in the beginning of this research was: ‘Why are some interest groups more successful in influencing EU decision-making regarding Climate policy than others?’ I expect that some interest groups, specifically interest groups representing business interests, are more successful in influencing EU

decision-making regarding Climate policy than others because of the nature of the interests they represent together with and in the institutional context of the decision-making process of the review of the EED. I think this answer is valid because of the expectation that the nature of interests represented has a significant effect on the admissibility of the involved

Commission officials. Their admissibility is a first step towards further attention for the opinions expressed by the interest group and can eventually lead to recognition of their perspectives and congruence in the frames used by the particular interest group. Congruence in frames is perceived as influence. The effect of congruence between the frames used by interest groups and the Commission will be discussed in the next part of this theoretical argumentation.

3.2 Hypothesis II

The second hypothesis concentrates on the theory concerning congruence in the frameworks used by interest groups and the European Commission. When the Commission decides to adopt a certain framework, this is an indicator of influence. Applying frameworks is non-excludable and thereby all interest groups may choose to use this means. The amount of resources an interest group owns does not count in this respect. However, Kluwer et al. (2015) assume that the availability of frame types is constrained by the interests the stakeholder represents. Choosing for a certain framework is a conscious strategic decision. Interest groups choose between the logic of membership and the logic of influence. A frequent respondent of the consultation period of the review of the EED are associations representing the interests of businesses from different industrial sectors. The existence of associations depends on the support of their members. Therefore, associations or foundations are assumed to follow the logic of membership. This constrains their behaviour, the framework that is expressed needs to be in accordance with their constituency structure, or in other words with the interests of

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the members they represent. Firms are not constrained by the logic of membership because they represent only their own interests and cannot be held accountable by members. The second logic, the logic of influence demands from interest groups that they choose frames that allow them to exercise influence over decision-makers and policy-making outcomes (Klüver et al. 2015). Since the majority of the interest groups of the non-survey based contributions represents business interests, this group needs to be examined on a zoomed in level. The interest groups representing businesses interests will be distinguished in; industry/business, private firms, workers organisation/association/trade union and utility. An overview of the background of the represented sectors will be given in the results section.

The definition derived from the study of Boräng and Naurin (2015) considering the

congruence between interest groups and the European Commission as: “The degree to which key policymakers’ frames correspond to the frames of lobbyists”, will be adopted in this research. Hereby this study responds to the call from de Bruyker (2016) for further research on framing in relation to interest group influence, especially with regard to political strategy and the effectiveness of frames. The following hypotheses are developed as a combination of the discussed theories and call for further research. The hypothesis establishes a causal relationship between the main explanatory variable, the type of framing, and the outcome variable influence, which is measured as frame congruence:

H2: In general, interest groups who apply economic frames (and thus represent the interests of businesses) in their position papers are more likely to achieve frame congruence between their position papers and the final proposal of the European Commission.

This hypothesis is based on the assumption that when the Commission adopts in their final proposal, which will be send for approval to the European Parliament and Council, the frames used by interest groups in their policy papers, this equates to frame congruence. Frame

congruence between interest groups and the Commission is seen as an equivalent of influence. Based on the assumptions belonging to the hypothesis regarding frame congruence, the

second part of the proposed answer to the research question can be given.

I expect that interest groups, who succeed in achieving frame congruence in the frames between their position papers and the framework used by the Commission in their final proposal, have been successful in their goal to influence EU decision-making regarding Climate policy. In contrast to interest groups who do not succeed in convincing the

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assumption that congruence is equivalent to influence. It is assumed that interest groups, who succeed in persuading the Commission to apply a similar framework, and thus reach

congruence, are influential. This answer is based on the expectation that when there is frame congruence between a particular interest group and the Commission, the latter will

presumably accept and take over the ideas and arguments of this interest group.

3.3 Scope condition and selection criteria

Dür and de Bièvre (2007) as well as Eising (2008) agree with each other that the context in which the interest groups operate in the European Union, creates a supportive environment to exert influence, e.g. because of the existence of consultation periods initiated by the

Commission. Here, the institutional context can be defined as a variable, which has an effect on the outcome variable, influence. The institutional context could have influence on the framing effect; it could either enhance or reduce the effects of framing. In this study, the institutional context is constant; the decision-making process is made in the institutional context of the European Commission during the consultation period, set up by the

Commission. The role of the Commission in the EU as not directly elected institution with the initiative to develop legislation could enhance the effects of framing because Commission officials are in general more depending on information provided by stakeholders (interest groups) and may therefore be more likely to adopt the framework of a position paper with which they agree and perceive as useful for the decision-making process. It is less likely that Commission officials adopt a framework from a position paper with which they disagree and do not see the added value. However, the institutional context is constant in the time frame of the review of the EED, subject of this research, thereby it is a scope condition. Although, the propositions examined by Dür and de Bièvre (2007), and Eising(2008) are very valuable and trustworthy. We know in advance that the interest group characteristics show variance whereas the institutional context is constant. Besides, it is expected that these values will be more able to explain the variance between interest group successes in influencing the EU Decision-making process regarding Climate Policy.

The impact of the salience of a particular policy area is discussed in detail in “Legislative lobbying in context: Towards a conceptual framework of interest group lobbying in the European Union”, by Klüver, Braun and Beyers (2015). Furthermore, Lowery (2013) in his attempt to explain the many null results in the literature on interest group influence, argues that null hypotheses may be caused by the conceptualisation of influence. The major portion of the literature focuses on issues that can be considered controversial in any aspect.

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