Evaluating Frame Dynamics: A Comparative Analysis of Policy Framing within Stakeholder Consultations

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Evaluating Frame Dynamics: A Comparative Analysis of

Policy Framing within Stakeholder Consultations

Laura O’Sullivan S2099616

Thesis Submitted in Requirement for the Degree Master of Public Administration

International & European Governance

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CHAPTER ONE: INTRODUCTION TO THE STUDY

1.1 INTRODUCTION

Modern assessments of stakeholder engagement literature within the academic research field of public administration presents that the role of policy framing remains an important exploratory issue in the area of European Union (EU) regulatory governance. In recent years, the integration of independent regulatory agencies and non-state stakeholders played an influential role in shaping and enforcing policy regulation standards. The creation of regulatory bodies in the EU’s institutional framework actively allows interest groups to participate in policy formulation. These regulatory bodies facilitate coordination between societal actors achieving certain political outcomes, which are in line with their preferences (Dür & Mateo, 2012). In order to do so, EU agencies help to establish public-private networks of regulatory players to shape this dynamic in the policy sphere with responsive, effective information (Ritterberger & Wonka, 2011; Dehousse, 1997). To enrich modern assessments about how EU policies are created, it is important to analyze which policy framing arguments are employed by engaged interest groups.

In theory regulatory agencies should consult stakeholders by encouraging an open platform designed for expressing policy preferences (Finke, 2007; Bunea, 2014), which in effect creates an interactive dialogue harnessed to ensure an effective policy practice (Baumgartner & Jones, 1993; Baumgartner et al., 2009). However, the role of stakeholder engagement, and policy framing, within EU agencies is often coordinated by specific lobbying strategies of stakeholder groups (Bunea, 2015). Studying specific frame contests reflects that not all stakeholder preferences are proportionately evaluated, creating an asymmetrical bias towards interest groups with higher levels of expertise (Baumgartner & Leech, 2001). This research study, however, goes beyond merely identifying stakeholder frames. Emerging studies show individual framing efforts (Boräng & Naurin, 2015) hold substantial importance in political fields because agencies quite frequently alter their policies to better match interest group preferences (Yackee, 2005).While these academic studies contribute significantly to the field of public administration, the frames often represent the impact on public opinion and politics, deprived of exploring which preference contributions are reflected in each frame. This study endeavors to understand why and how substantial variations

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among stakeholder framing occurs via considering which frames stakeholders exchange to motivate impact in agency consultations and regulatory spheres.

Interest groups commonly offer a platform for societal interest to engage as key actors in expressing their policy preferences and effectively solving problems (Finke, 2007; Bunea, 2014). Stakeholders frequently become involved in pushing forward their agenda and contribute influential insight into decision-making areas, often partaking in regulatory processes (Arras & Braun, 2017). Consultations serve a platform where stakeholders participate in voicing preferences to regulatory agencies, enthusiastically so. While incorporating a diversity of voices into decision-making processes is encouraged by EU regulatory governance agencies, questions appear regarding the implication stakeholder frames have, specifically on defining regulatory outcomes of the EU. The portrayal of preferences by stakeholders may impact how the regulatory authorities perceive collecting preferences and determine which actors to respond to, with the potential to grant access to stakeholders seeking to move forward on the policy agenda in these decision-making processes. It is therefore not only important to analyze how stakeholders shape the policy agenda, but also to understand who, and to what extent meaningful narratives are embedded in framing policy issues. Drawing on framing theory, which suggests policy issues individually comprise multiple potential dimensions, framing is a significantly important tool for policy actors (Eising et al., 2015; Baumgartner & Mahoney, 2008; Daviter, 2009). Frames are extremely important because they denote actor positions as ‘what actors perceive to be at stake’ in proposed proposals (Eising et al., 2015Daviter, 2009).

Unambiguously, this inquiry will unpack the context and strategy employed by stakeholder frame dynamics during policy conception, while examining the various ways arguments are framed in the multilevel governance system of EU policymaking. A special emphasis is placed on evaluating one specific EU agency’s recorded interactions with stakeholder policy preferences during the agency open consultation phase of decision making, per agency input recommendations. One way to access policy frames is to measure how stakeholder arguments are reflected in a comment submission period conducted by a regulatory agency. In detail, this research explicitly concentrates on identifying the existence of stakeholder frames, and thus, examines the underlying content of several consultation instruments (Arras, 2017) and stakeholder group type, (Eising et al., 2015).

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Stakeholder positions and frames were coded accordingly from analyzing 905 comment submissions. Furthermore, the aspiration of this research seeks to unravel policy frame input obtained from stakeholders and to pinpoint which framing context are associated with which set of stakeholders.

1.2 PROBLEM DEFINITION AND RESEARCH QUESTION

Research on framing, with reference to stakeholders, began to appear in academic literature around the early 1990s (Benford & Snow, 2000) with inherent focus on defining and operationalizing non-state stakeholders by analyzing effects related to this existence (Kohler-Koch & Finke, 2007). However, published articles analyzing in-depth topics of stakeholder participation in risk regulation did not emerge, despite lobbying successes, until the late 2000s (Liverani et al., 2013). Only in recent years has this literature given greater access to framing influence, with topics such as access and mobilization throughout the 20th century (Baumgartner & Leech, 1998; Mahoney,

2008; De Bruycker & Beyers; 2015; Bunea, 2016). Kohler-Koch and Finke (20017), raise an essential concern for European integration architects in developing an inclusive policy-making process (Bunea, 2014). The problem of regulatory agencies involving stakeholders is a well-known issue among the study of risk governance, however, a missing consensus among the literature exists on who narrates which issue preferences. Researchers have predominately used methods to account for reasons as to why stakeholder participate (Bouwen, 2002), yet despite numerous explanations, researchers have not identified the impacts of which policy frames are put forth by different stakeholder group types who participate in consultation procedures of EU regulatory governance.

One method for challenging frame content is through examining the open consultation period provided by the agency. We know surprisingly little about interests’ stakeholders frame in risk regulation, specifically in the context of the European Food Safety Authority (hereafter EFSA). In order to deliver comprehensive results on food safety advice regulatory agencies, such as the EFSA, convey information found through methods of consulting with national authorities, public consultations and risk assessments conducted by a scientific panel (EFSA, 2019). By investigating potential variations in policy frames regarding stakeholders, one can conclude the overall impacts of how frames vary throughout agency consultation procedures, and which factors explain

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stakeholder diversity in participation opportunities (Arras, 2018; Braun and Yesilkagit, 2014; Chalmers, 2015; Pagliari and Young, 2016). The research question this study seeks to answer is:

To what extent do frames vary across different stakeholder group types and consultations procedures?

1.3 PURPOSE OF THE STUDY

The purpose of my research was intended to add to the existing scholarship on the role stakeholders play in regulatory governance systems, by conducting an intra-agency frame analysis, investigating the frames stakeholders communicated to influence risk decision-making. I sought to identify and compare the practices stakeholders used to articulate positions, and further how each frame is altered with different interest group and consultation instrument characteristics. This research expects systematic variation among different consultation instruments and stakeholder group types, specifically focusing on which variables result in usage of target-statement and valence frames. Studying frames allows for conclusions on whether EU attention is skewed towards particular interest and biased towards certain interest groups. This research further expects business interests will carry higher results in strategically influencing frames compared to civil society. The EU is understood to be more receptive towards business interests and groups with larger populations and resources and is relatively detached from constituents (Kohler-Koch, 2013; Berkhout et al. 2017). Additionally, consultations instruments open to stakeholders offer the capacity to impact policy outcomes (Bouwen, 2007; Bunea, 2016), as well as offer transparent, legitimate, and inclusive policy-making processes (Quittkat, 2011; Bunea, 2016). This research also expects open consultation instruments to display higher level of frame prominence. With that, studying frames through testing multiple consultation instruments contributes to EU governance by giving an inside view to possible biases and privileged interest group status in policy making (Bouwen2009; Bunea, 2016).

The central focus of the study was based on learning directly from EFSA public consultations, which frames stakeholders embody for proposing (positive and negative) policy arguments. Patterns of anticipated similarities and differences were observed through the theoretical framework selected to guide this research, existing literature on policy framing, and my individual

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understandings were compared to detect repetitive configurations from the consultation data. The empirical methods of coding associations across variables matching (Dür & Mateo, 2012) was strategically applied to assess the legitimate validity of recent findings and to seek out which stakeholder groups found different discourse frames most effective. Providing new data on successful strategies for stakeholder framing can contribute to addressing the foundational problems associated with allowing stakeholders to frequently participate in steering agency policy agenda decisions and reducing negative outcomes in favor of biased stakeholder preferences.

In addition to speaking to the existing literature on interest group roles in EU regulatory governance, this research contributes to the broader debate on the responsibility of issue frames among private sector and civil society. This research draws on the EFSA because they offer a consultation platform which permits the involvement of a diverse set of stakeholder interests to participate. The EFSA serves as an admirable example analyzing policy frames suggested by stakeholders in the midst of risk governance in regulating uncertainty. However, several implications derive from this case. While the creation and institutional design of this agency are important by nature within European integration architecture (Wonka & Rittberger, 2010), this is inherently more important in determining who has access to the field of influencing EU policymaking. Moreover, this research conceptualizes the role of stakeholders more closely integrating understandings of issue framing and interest group politics with the broader literature on independent agencies and regulatory governance and EU independent agencies (De Bruycker & Beyers, 2015). This directly correlates to the types of stakeholders who participate and consequently those who are constrained from participating in in public consultations. Framing attempts by stakeholders during this agency consultation comment periods display frame dynamics and potential variations depicted by important EU actors. Ultimately, this agency departs from the idea that social implications influence policy outcomes, rather this tests the deployment of ideologies by number and type of interest groups permitted to participate and type of consultation instruments.

1.4 SIGNIFICANCE OF THE STUDY AND ACADEMIC RELEVANCE

This research seeks to contribute to current public administration rhetoric by building upon

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non-state stakeholder research substantial strides investigating formal participation have amplified, yet there remains an ongoing search in understanding how stakeholders frame issues, specifically located throughout comment periods within regulatory agencies decision-making processes (Arras & Braun, 2017). This study aims to go beyond previous understandings of stakeholder roles in policy frames, by comparing content found through several EFSA consultation comment transcripts, in parallel to the guidance of a media analysis codebook and framing literature prominent in the public administration field. These findings will determine potential variations and causalities between stakeholder relationships and framing policy positions. The usage of researching this framing method acknowledges several complex theoretical components as properties of incentives for stakeholders collaborating with regulatory agencies.

While drawing on consultations from the EFSA is an excellent selection of data for this study, it also comes with several implications of studying stakeholder engagement. EU agencies make decisions related to the daily lives of EU and non-EU citizens. Consequently, the EFSA is tasked with addressing risk assessments on food products (Busuioc et al., 2012; Arrs, 2017), which means citizens have little say in holding this agency accountable. Regulators need to design and facilitate consultations in a way that ensures information and associated risk factors stem from a diverse range of stakeholder input. This institutional architecture often means less participation diversity of stakeholders. Given this is a regulatory agency, stakeholders from the regulated sector are more engaged in providing information. One reason is due to the highly technical information required for stakeholders to contribute. For instance, a consultation on food system regulations may call for stakeholders from environmental sectors to actively participate more often than an NGO that advocates for human rights interest. Often, this is due to representing particular interest directly related to their organization and industry, whereas citizens may not be associated with the technical expertise needed to comply. This agency is particularly significant because it does not focus solely on business and non-business interest engagement (Pagliari & Young, 2016; Arras, 2017). However, this technical risk regulatory agency is less suited for the broad study of stakeholder roles because public participation spans to interest with strong incentives to communicate policy preferences.

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Another implication is that the EFSA offers less opportunities for stakeholder involvement compared to other EU agencies. The agency was designed to involve stakeholders however, stakeholders mostly engage through public consultations on draft scientific opinions (Arras, 2017). Other agencies, including the European Medicines Agency and European Banking Authority, offer several platforms for stakeholder participation, including providing access to management board meetings (Arras, 2017). This institutional design of stakeholder involvement is discussed in detail in a later section. Additionally, the context of the policy issues at hand is likely to play a crucial role in shaping the individual and collective framing of argumentation among stakeholders (Baumgartner & Mahoney, 2008). Framing is a crucial method for analyzing these stakeholder engagement implications. Framing is fundamental to EU stakeholder engagement and undeniably enhances the quality of policy outcomes with regard to policy advocacy (Baumgartner & Mahoney, 2008). Despite the more concentrated attention paid to this concept, the underlying theory of framing lacks consensus due to inconsistency and ambiguity around the definition of framing (Cacciatore et al., 2016; Scheufele & Tewksbury, 2007).

While previous studies (Yackee, 2005; Baumgartner & Mahoney, 2008) indeed make influential contributions to the field of public administration research, they also leave frames at face value, which leads the role frames carry in reflecting interest group positions and directing the status quo, relatively underexplored. This research directly examines stakeholder participation dynamics, consultation procedures, contributing to the volume of observable, if any, levels of variation in frames. In this manner, the hope of this research is to fulfill the gaps among the existing scholarship that have focused on the discourse between policy-makers and stakeholders in risk governance and the representations of framing preferences. The usage of this research will contribute to the relevancy of this topic area throughout diverse settings.

1.5 TRANSITION STRUCTURE

Structured in a series of five conceptually lined chapters, this format allows the reader to navigate through the research study at ease. In the following chapter, Chapter 2, I undertake an in-depth review of literature pertaining to significant applicable information. The literature review contains discussion of previous studies, details the theoretical framework, as well as addresses the gap in existing literature concerning this topic. In Chapter 3, I present the selected case, research

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methodology, and empirical approach to the research. I specify my reasoning for selecting this strategy of inquiry, propose research hypotheses, develop expectations of expected variation in findings, and analyze a more explicit public consultation context. Chapter 4 will present the results of data findings and an analysis of the research conducted. Chapter 5 will conclude with a summary and discussion of the thesis findings, as well as future implications and recommendations for practitioners and future academic research.

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CHAPTER 2 LITERATURE REVIEW AND THEORETICAL

FRAMEWORK

2.1 INTRODUCTION

There is a plethora of literature that studies stakeholder interest groups and the methods they utilize in interacting with governmental agencies through lobbying. While lobbying is largely accepted by government and business sectors, there are several more wide-ranging ways of incorporating societal influence in providing information to decision-makers. This lobbying method takes the form of ‘framing’, which promotes the idea that stakeholders strategically communicate issue-definition specifically to influence policy decisions and attain desired direction (Baumgartner et al. 2008; Baumgartner and Mahoney 2008; Boräng et al. 2014; Boräng and Naurin 2015; Eising, et al. 2015; Klüver Mahone and Opper 2015a; De Bruycker, 2017). This literature review provides interrogative accounts of existing literature on the rationale for this research. This review opens with a discussion on the increasing presence and role of stakeholders in EU regulatory governance, vis-à-vis independent agencies. Subsequently, an explanation is provided on the role of framing in understanding the role of stakeholders in EU regulatory governance. This overview unfolds the critical issue on defining framing. Frames are then linked to the independent variables. These themes are further categorized to set the foundation and provide the reader with the knowledge required for understanding the focus.

2.2. THE RISE OF STAKEHOLDERS VIS-À-VIS EU INDEPENDENT AGENCIES

Ample literature exists that investigates interest groups and how these stakeholders interact directly with policymakers. Involving non-state stakeholders in global governance is largely seen as a fundamental stage towards the process of global democracy (Agné et al., 2015). Without involving non-state stakeholders, it is hard to imagine how the EU and EU initiatives alike would operate (Klüver et al., 2015). However, little attention is given to the study of non-state stakeholders and the way in which they present representation of citizen preferences to respective agencies. Despite advances made in this study of interest groups, gaps remain where practitioners heavily rely on stakeholder engagement within EU regulatory agencies (Arras & Braun, 2017). Therefore, it is imperative for public administration scholars to continue the search into understanding how subsequent concepts shape the role differences stakeholders take in influencing the course of regulatory policy processes.

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The term ‘stakeholder’ referenced throughout this study refers to Andrea Bunea’s (2016) rudimentary definition, “interested organizations and national/regional level authorities that participate in consultations (Bunea, 2016). Stakeholders can include a range of actors, such as academic research institutions, individuals, businesses associations, firms, governments, NGOs, or trade unions (Arras, 2017). Furthermore, ‘position’ refers to the evaluation expressed by stakeholders on the proposed policy change (Bunea, 2016). Stakeholders utilize participation as a way to voice their preferences by enhancing agency outputs. Stakeholder position themselves relative to their interest in policy change, in their interactions and dialogue with agency officials and open consultative practices (Bunea, 2016). The EU is increasingly open to allowing societal actors to achieve policy outcomes aligned with interest group preferences (Dur & Mateo, 2012).

In order to improve our understanding of European Union regulatory decision-making processes, a fundamental background on EU independent agencies is required to explain the increasing rise of stakeholders in EU regulatory governance. Independent agencies play a critical role in influencing the regulations that shape our everyday lives. The structural development of the EU system has been fluid as the EU jointly exercises powers delegated to increasingly integrated administrations (Hoffman, 2008). Decentralizing executive powers through the delegation of power to EU agencies has resulted as a phenomenon of integrated cooperation between supranational and independent actors in the regulatory sphere (Busuioc, 2009). In the quest to develop a harmonious regulatory system, the EU regulatory sphere has initiated a basis for agencies to delegate forms of functional pressures from non-state actors in their decision-making strategies (Rimkute, 2018). These agencies impact the way citizens are protected in terms of health, as they coordinate technical and scientific expertise to the supranational EU level (Vos, 2018).

In the last decade, a mushrooming effect has become very prevalent in EU agencies. Independent agencies are typically autonomous in that their structures are largely decentralized from an executive power, thus comprising of essential access between the agency and external forces in allocating decisions (Borras, 2007). An essential means for the European Commission to ensure credibility as capable policy-makers for the EU is through delegating long-term commitments to independent bodies (Busuioc, 2009). Agencies often operate as decentralized networks working to better EU governance, by addressing the theme of collective action, by ways of influencing

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legislation based on the scientific guidance they produce level (Permanan & Vos, 2010). Furthermore, regulatory agencies utilize their purpose by formulating the preparation of regulatory policy, thus directly impacting EU legislation (Wonka & Rittberger, 2010). Effectively, this resulted in a continuous expansion of delegating policy functions and activities to decentralized agencies, further building the EU capacity (Busuioc, 2009).

Developing an inclusive and participatory policymaking process amongst the European Union has remained a constant concern for European Union integration architects (Kohler-Koch and Finke, 2007; Bunea, 2014). The emergence of new entities within the EU system, in the past decade, represents development from the unceasing evolvement of European institutional architecture (Geradin & Petit, 2004). The stakeholder phenomena prevailed as a popular method for engaging participatory policymaking for several reasons. One of which, namely the theory of legitimacy, highlights how stakeholder engagement is critical for regulatory governance. Arras (2017) reveals two of which are mechanisms for legitimacy, including increasing transparency and accountability (McCubbins & Schwartz, 1984; Schillemans, 2008; Seffeck & Ferretti, 2009); increasing expert information in decision-making (Coglianese et al. 2004; Steffek and Ferretti 2009); and finally, increasing credibility as an autonomous authority (Busuioc and Lodge 2016; Carpenter 2001). Stakeholders can indirectly represent citizens and account for the lack of direct access to the public in input legitimacy (Arras, 2017; Furlong and Kerwin, 2004). These stakeholders act as resources, or “policy goods”, for the regulatory agencies to depend on in obtaining strategic, legitimate interests from beyond the agency (Braun, 2012). Involving stakeholder positions serve as a resource of control and responsive communications for agencies (Rourke, 1984). This information stakeholder actors provide are often used as a strategy for reducing uncertainty about scientific risk factors and legislation consequences (Rourke, 1984; Hrebenar, 1997; Wright, 1996). The positive affiliations stakeholder engagement produces drives EU institutions, and other forms of non-majoritarian governance, to actively reach out to involve stakeholders in their decision-making processes by installing consultation procedures (Arras, 2017).

Non-state stakeholders play a critical role in offering informational attributes. Resources distinguish stakeholders as necessary for engagement an influencing varied policy outcomes. Such resources include knowledge, expertise, legitimacy, information, representativeness, and financial

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means, each of which non-state stakeholders can offer associated practices. Regulatory decision-makers engage stakeholders to obtain expertise as part of a knowledge and resource exchange (Arras & Braun, 2017). These interactions are conceptualized as a form of an exchange relationship (Arras & Braun, 2017; Bouwen 2002; Braun 2012; Coen and Katsaitis, 2013). The theory of access plays a critical role in EU institutions fulfilling their institutional role by exchanging interactions with private sector interest groups (Bouwen, 2004). Regulatory agencies use resources as an access practices to stay informed on relevant developments. Interest groups also offer policy goods to regulatory governance policymakers in return for the possibility to access agencies and have influence in policy decisions (Arras & Braun, 2017). The information stakeholders provide helps regulatory agencies to more effectively create policies (Arras & Braun, 2017). Some resources, including representativeness, can be serve as a relatively cheap resource, while other resources depend on the strength of their membership base (De Bruycker, 2017). Resource-rich interest groups often have more voices participating in defining specific interests vis-à-vis independent agencies (Klüver, 2010). As such the first hypothesis is:

EU decision-makers are favorably interdependent on interest groups as they rely on policy feedback, technical information, in addition to legitimacy claims (Bunea, 2013). BÖhmelt et al.,

(2014), found international policy-making institutions to involve civil society organizations (CSOs) in global governance arenas. Policy trajectories of regulatory outcomes are important because they are often shaped by those who engage in varying degrees of providing input positions. Regulatory agencies interact with stakeholders and interest groups with the intent of obtaining ‘policy goods’, which are the resources agencies obtain from interest groups and other external forces (Braun, 2012). One advantage interest groups offer is that they can often offer something which agencies cannot easily do (Yackee, 2005; Rourke, 1984). Policy trajectories of regulatory outcomes are important because they are often shaped by those who engage in varying degrees of providing input positions. However, more often than not, stakeholder groups cannot be influential in their endeavors when lacking access to key points of decision-making processes (Ainsworth, 1993; Truman, 1995).

The European Union is a multilevel governance system, where authority is divided amongst member state institutions and independent agencies. Therefore, much of the EU decision making

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powers draw from the relations which manifold through ongoing developments of EU and national institutions, sub-national actors, interest groups (De Bruycker, 2017; Marks, 1993). At the EU level, the need for coordination and cooperation between all involved stakeholders is emphasized. Independent agencies therefore play a critical role for the EU Commission as delegated policy entrepreneurs who construct policy frames that bind together relevant political actors (De Bruycker, 2017; Stone et al. 2001; Daviter, 2009). National governments bring forth domestic affairs, which is a crucial component of EU decision making. This variety of policy advocated involved in framing competition proves how stakeholder groups directly engage in lobbying activities vis-à-vis independent agencies.

Interest group literature shows the growing concern of diversity amongst interest group systems (Baumgartner and Leech, 1998; Beyers et al. 2008; Arras, 2017). Interest representation patterns, especially where agencies are basing legislative decisions, are of crucial importance in determining the magnitude of influence and disproportional interests (Lowery and Gray, 2004; Arras, 2017). The representational capacity of stakeholder actors across tend to vary across EU-level interest vary across different dimensions (Berkhout et al., 2017). For example, EU-level environments relatively favor interest groups where political ideals are articulated to policy-makers themselves. This highlights attention to the types of policy views communicated to policy-makers (Berkhout, 2017). Stakeholders best able to mobilize resources are more actively participating in consultations, thus gaining more access to policy-makers, such as businesses compared to civil society (Dür and Mateo 2012; Dür and Mateo 2016; Eising 2007; Arras; 2017). Citizens tend to be more actively involved when asked to represent personal involvement, and more often they represent higher educated class citizens (Arras, 2017). The increasing number of frames is often linked with an increasing number of stakeholders and institutional policies (Eising et al. 2015). Studying the expansion of interest group actors supports in identifying crucial factors, including polity conflicts, public awareness and citizen visibility of issues, amplitude of resources, and policy advocates’ competition (Eising et al., 2015). Through addressing the number and prominence of stakeholders, public administrations researchers can explain influence and dominance of specific interest across supranational governance systems. As such, the first hypothesis is:

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Hypothesis 1: The more actors involved in a consultation, the greater the number of frames.

2.3 THE ROLE OF FRAMING

In recent decades, the evolution of frames and framing studies have vertically expanded (Entman, 1993; D’Angelo, 2002; de Vreese, 2007;). Framing gained popularity among scholars in academia for its ability to interpret information and perceptions. We interpret information from what the evidence captures as well as represents, in the use of language or images (Sturken and Cartwright, 2001). Framing theory suggests each policy issue obtains multiple potential dimensions, characterized by different attributes and is a fundamental tool for policy actors (Baumgartner and Mahoney, 2008; Daviter, 2007). Framing theory further contends that by selecting certain aspects of an issue, framing can evoke the relevance on certain interests, often at the expense of other interests (Daviter, 2009). Though there is a body of information pertaining to research on media communication of framing through the news and pictures, this thesis is interested in the capacity in which non-state stakeholders construct frames through integrating values and beliefs into European regulatory governance.

Robert Entman vastly improved our understanding of framing when he contributed to existing scholarship, the conceptualizations of framing (Entman, 1993). Framing offers a highlighted version of a communicating text (Entman, 1993). According to Entman (1993), “To frame is to select some aspects of a perceived reality and make them more salient in a communicating text, in such a way as to promote a particular problem definition, casual interpretation, moral evaluation, and/or treatment recommendation for the item described”. Frames highlight smaller aspects of communication and are indispensable because they call attention to different elements, causing different reactions to viewers (Entman, 1993). In his commonly cited clarification of frames, Entman (1993) offers four classifications of frames including: (adapted from Entman, 1993).

- Defining problems (how a causal agent uses costs and benefits) - Diagnose causes (establish root causes of the problem)

- Make moral judgments (evaluate the causal agent along with their effects) - Suggest remedies (offer solutions and articulate likely effects).

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Thus, framing an issue provides an understanding of possible policy negotiations and outcomes (Junk & Rasmussen, 2018). Framing plays an important role in shaping the public policy debate, as interest groups strategically frame certain fragments of policy proposals while excluding other fragments (Klüver et al., 2015).

Chong and Druckman (2007) emphasize framing as the process where people develop conceptualizations of particular issues. In order to explain variations of the framing concept for this research, it is imperative to delve into the foundations of framing theory. Framing emerged from the discipline of psychology by two renowned pioneers, Kahneman and Tversky (1970, 1984) (Cacciatore et al., 2016). Kahneman’s research describes human choice as “reference dependence” and a result of how the information is contextualized (Cacciatore et al., 2016). This psychology-rooted concept of framing emphasized variation in how information is cultivated and presented to an audience (Cacciatore et al., 2016). Ajzen & Fishbein (1980), take a conventional psychological approach by explaining an individual’s attitude through an expectancy value model. They provide the equation: Attitude = Σ vi * wi. More specifically, vi represents the evaluated value the subject assigns to the attribute I, while wi represents the salience weight the subject assigns to the attribute (Ajzen & Fishbein, 1980). Essentially, this model conceptualizes the subjects’ attitude toward an object as a weighted sum of combined beliefs (Ajzen & Fishbein, 1980).

Deborah Stone (2012), defines framing an issue as “selecting some aspects of perceived reality and make them more salient [important or visible]… in such a way as to promote a particular problem definition, causal interpretation, moral evaluation, and/or treatment recommendation.” The way the policy problem is defined constructs the issue frame technique, influencing [un]intended responses. Furthermore, Stone (2012), discusses the power legislators give citizens and the people facing the effects of public policy. Stone asserts advocates commonly argue the positions that will produce better, more effective policies aligning with their goals. Additionally, Stone (1989), posits that assigning blame to policy conflicts is a powerful framing strategy, and further notes how actors can potentially affect an audience’s beliefs on who is to blame as they define the problem. In essence, diagnostic framing identifies sources of causality or blame agents (Benford & Snow, 2000), and is correlated to prognostic framing, which is a proposed articulated solution (Benford & Snow, 2000). Stone (1989) also conceptualized that assigning blame is a

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powerful tactic in policy conflict, namely when actors attribute blame for the problem, which alters substantially alters beliefs on issue portrayal. Participants link their independent propositions to address beliefs about social problem causes. Often their political choices are motivated by addressing social responsibilities through concluding the point of contention.

Academic scholarship often describes media framing by displaying how frames develop over time, and/or through comparing the framing perspectives of different issues (de Vreese et al., 2001). Interest groups frequently take polarized positions on policy issues as part of overarching policy proposal harmonization (Klüver et al., 2012). Since the EU governance sphere is a multilevel system, it is imperative to analyze the underlying foundations and ideational structures of public policies by understanding the variety of issue advocacy actively participating in framing competition to shape EU regulations (Eising et. al, 2014). EU policy issues are often understood by a series of collective frames, which emerge through varied interactions among actors who contribute means and communicate messaging (Voltolini, 2016; Bicchi, 2007). Frames allow public responses to be observed by comparing perceived information determinants with the message and pinpoints the representative ideals interest groups are putting forward. Baumgartner and Mahoney (2018), differentiate between ‘two faces of framing’ (Boräng & Naurin, 2015). The first face relates to which individual framing efforts policy advocates communicate in their positions (Boräng & Naurin, 2015). The second refers to collective issue definition, which relates to the different individual frames that are mixed into general frames (Baumgartner & Mahoney, 2008); Boräng & Naurin, 2015). The latter in particular, remains relatively, weakly understood by political scientist.

Although the study of frames often overlaps with media and communication disciplines, scholars occasionally study one type of frame, testing how this shapes a person’s views on a particular subject. However, the study of frames often is seen through two types of frames. Chong and Druckman (2007) distinguish two distinct types of frames: issue frames (or emphasis) and equivalency frames (or valence). For the purposed of this study, issue frames directly correspond to target-statements. Frame valence is described as an attribute or event as being framed positively or negatively (Levin, 1987). Valence exerts influence on decision-making processes (Issac & Poor, 2016). Boin et al., (2009) focus on the policy impacts of frames when

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confronted with crises. Their scholarship alludes to two types of policy frame contests including: significance of events and causality. The former refers to the significance of the status of issues – are they of high or low importance, while the latter refers to what or who drives the progression of occurrences (Boin et al., 2009). As such, causal issue framing, reasonable strategies and solutions (Benford & Snow, 2000), strategies link ideologies to policy implementations and agency (Mcbeth et al., 2007). Boin et al., (2009) continues to propose another interesting suggestion on how proponents aim to ensure their frame prevails and is accepted by political institutions and/or public opinion (Stone, 2001). Results showed configurations implemented by two types of games. The first, the political ‘game’ is a conflict between a government and opposition, while the second, the policy ‘game’ is the conflict between advocates for change and regulatory and administrative status quo proponents (Boin et al., 2009). Likewise, they found perfect strategies for guaranteeing an inherently stable outcome, yet several degrees of policy implications may arise as a result of policy framing (Boin et al., 2009).

Two important contextual factors are provided to further the explanatory value of variations in policy frames; including generic frames and specific frames. Generic frames are more general in the sense that they can be applied to a variety of contexts across policy areas (Eising, et al., 2015; de Vreese, 2005). Whereas, specific frames wholly relate to the issue of discussion. While institutional structures emphasize the requisite for coordinating participation with stakeholders, literature depicts generic institutional frames as ‘frames as emerging from institutional settings and relating to the governance procedures of the political entity’ (Eising, 2015). Specific policy frames refer to detailed information of the specific policy detailed issues at hand. The underlying structure of governance models and actor constellations generate such variations in policy areas because actors and institution vary, and shape policies accordingly.

Policy scholarship on framing emphasizes the influence ideas hold in the policy process, especially when pushed forward by a group representing that specific interest in the dynamic policy problem (Koon et al., 2016). Ideas inject purpose for external actors to join the political debate (Koon et al., 2016; Be’land and Cox, 2011) and provide policy researchers with clear linkages to institutions (Koon et al., 2016; Schmidt, 2011). Framing offers insights into the political debate by providing an understanding of agency and structure in the policy process (Koon et al., 2016). Researching

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the concept of framing is important as this indicates possible associations concerning several inputs of patterns of stakeholder risk perceptions and independent agency output policy goods (Furlong & Kerwin, 2004).

The study of frames adds to the transformative debate that actors may strategically highlight different preferences of EU policies. By focusing on issue frames we can disentangle their specific arguments and pinpoint the contextual effects of framing patters while understanding there impact (Eising et al. 2015). Identifying framing effects answers several vexing questions of the expansion of the scope of EU regulatory governance issues and how best political institutions use their resources to respond to these conflict situations. Furthermore, the study of frames allows academics to identify which policy proposal dimensions appeal to interest groups and how problem poses normative implications. Frames additionally highlight policy measures in terms of how EU regulatory governance addresses social welfare effects (Entman, 1993; Eising et al., 2015).

Framing activities increasingly highlight the cross-national differences across EU multilevel systems. The representational capacity of stakeholder actors tend to vary in several dimensions across EU-level interest (Berkhout et al., 2017). For example, EU-level environments relatively favor interest groups where political narratives are articulated to policy-makers themselves. This highlights attention to the types of policy views communicated to policy-makers (Berkhout, 2017). Stakeholders best able to mobilize resources are more actively participating in consultations, thus gaining more access to policy-makers, such as businesses compared to civil society (Dür and Mateo 2012; Dür and Mateo 2016; Eising 2007; Arras; 2017). I expect interest groups that rely on government resources and local constituencies are less likely to mobilize at the EU level. It is more challenging for interest groups to have direct contact with EU independent agencies; therefore, business interest groups are more involved, causing a belief that independent agencies are more biased towards business stakeholders. Citizens tend to be more actively involved when asked to represent personal involvement, and more often they represent higher educated class citizens (Arras, 2017). As interest group associations exhibit strong determinations to strategically broadcast their preferences to regulatory agencies through using public consultations to act as an important venue of exchanging preferences, it is therefore hypothesized that stakeholders will exhibit framing differences by addressing a diversity of stakeholders when given the opportunity

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to participate preferences. It is on this basis that the second hypothesis for this research study was formulated.

Hypothesis 2: Business actors be more likely than NGOs to use a target-statements or valence frames.

2.4 FRAMING IN EU REGULATORY GOVERNANCE

Framing plays a valuable role for studying stakeholder roles, by stimulating group representation in shaping alternative evaluations. In line with the theory of framing, the emergence of variations in policy frames leading to policy outcomes interestingly highlighting a new dimension of policy processes. Expanding the constricted policy community is imperative in EU regulatory governance systems. Frames allow for the discussion of understanding how different stakeholder interest throughout varied consultation procedures are affected by the regulations they shape (Arras & Beyers, 2017). Policy conflicts greatly affect EU citizens and the power balance amongst supranational and national systems. By studying frame dynamics researchers are allowed to observe a reverse in power balance, or evidently, a skewed bias among interest with high membership fees and resources (Boräng & Naurin, 2015). Frame research further allow for understanding which interests are relevant and how groups perceive these issues, and the effects of collective issue-definitions (Boräng & Naurin, 2015). Frame analysis often display constraints and opportunities for upsetting the equilibrium. By judging competing frames in in regulatory agencies, we are able to explain how dominant ideologies are framed by outsiders from the policy realm. Furthermore, this mechanism changes the direction of understanding policy conflict arguments and pinpoint the success of lobbyist promoting ideal- and self-regarding frames (Boräng & Naurin, 2015).

Eising et al, (2015) focus on the essential frames of EU policy proposals. These scholars highlight definitions where the number of essential frames serves to shine a light on the convolution of the policy issue, the significance of the conflict and probable causes of shifts of attention, whereas the types of essential frames indicate the true meaning of EU policy issues (Eising et al., 2015). Interest groups often frame a policy issue around the information available (Klüver et al., 2015). Mahoney (2008) found interest groups often strategically adapt frame choices differing by a contingent of the EU policy context (Klüver et al., 2015) Institutions also play a central role in

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shaping framing choices (Klüver et al., 2015). Policy issues can systematically differ across institutional settings and perpetuate such frame variations. This research posits on the distinction that policy issue definitions shape ensuing political dynamics and processes (Daviter, 2009).

Number of Stakeholders Mobilizing

Generally, public administration studies on non-state stakeholder interest groups focus on institutional and organizations diversity (De Bruycker & Beyers, 2015). For instance, business interests compared to civil society groups, or high resources versus less resource heavy organizational interest’s, gain more recognized attention compared to other groups (De Bruycker & Beyers, 2015). However, there is a gap in scholars analyzing whether this distribution of interest’s groups corresponds to the number of citizen interests sharing perspectives. At the European level, institutions emphasize the need for cooperation amongst stakeholders, especially in the role of policy entrepreneur for the European Commission (Eising et al., 2015). These stakeholder actors contribute highly relevant external information and construct policy frames. Stakeholders seek to influence policy goods through a variety of institutional venues (Klüver et. al, 2015). With reference to EU policy-making, the early stages offer the best outlet for interest groups to gain policy influence opportunities (Bunea, 2013). During the early phase, stakeholders are formally invited to the agency to explicitly express preferences and offer policy input centered on their interests (Bunea, 2013; Bouwen, 2009). Affected stakeholders often act as a form of expertise as they mobilize to shape and support the outcome of the policy debate in favor of their preferences (Klüver et. al, 2015).

Non-majoritarian agencies seem to be relatively open to promoting engagement with non-state stakeholders – such as academic institutions, NGOs, business associations, and trade unions – as these interactions provide structures of cooperation between citizens and national levels of authority, thus improving legitimacy and accountability concerns (Arras, 2017; Borrás et al. 2007; Kelemen 2002; Thiel 2014). Actors can range from individuals, to governmental states, to groups varying in size (BÖhmelt et. al 2014). Consultations are designed with the intent of policymakers receiving information from a diverse set of stakeholders (Arras, 2017; Borrás et al. 2007). Explaining the extent of diversity of stakeholders is narrowly detected through observing the types of stakeholders providing information during agency public consultations.

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External actors play an important part in shaping the policy development process. The policy position documents of stakeholders represent a valuable data source (Bunea & Ibenskas, 2017). Bunea (2013), highlights interest groups within the EU are commonly perceived as ‘channels of societal representations of policy demands’ and act as beneficial problem solvers (Finke, 2007). Interest groups possess the power to communicate messages and preferences of ordinary citizens, business groups, advocacy groups, food producers, academia, governments, etc. Institutional structures shape ‘incentives and constraints’ for stakeholders and frequently determine levels of stakeholder preference attainment within the policy-making process (Bunea, 2013; Beyers, 2004). Agency design plays a crucial role in determining who and how actors participate and whether their preferences are distributed throughout the functional pressures of policy making, specifically in policy output of regulatory environments. The institutional design vastly differs in terms of how many actors they allow to participate. This often depends on the types of stakeholder involvement where substantial numbers of stakeholders meet on a regular basis.

Type of Stakeholders

Stakeholders can include a diverse range of actor characteristics and types, such as citizens, business associations, firms, civil society, professional organizations, academic and research institutions, or trade unions (Arras, 2017). The multitude of characteristics and behaviors of interest groups increasingly expand in lobbying EU regulatory risk institutions. Existing studies text whether there is diversity in EU lobbing, alluding to evidence that there is a bias in interest group diversity, namely a bias towards business interest groups (Berkhout et. al, 2017). Concerns have emerged over the EU developing biases towards business groups because technically their proportion exceeds domestic interest groups, causing the EU to be more receptive towards business groups (Berkhout et. al, 2017). This stems from variations in types of resources interest groups possess. For example, business associations are thought to possess more expertise and information compared to other association types (Dur & Mateo, 2012). Another interesting point (Berkhout et. al, 2017) articulate is interest groups tend to be more detached from domestic constituents (Kohler-Koch, 2013), and continue to become more interested in the logic of membership, which may be problematic as interest groups are more willing to relay policy-maker’s interest over members (Berkhout et al, 207).

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General stakeholders – such as NGOs - lack the resources and technical capacities of stakeholders comprising of industry or businesses directly affected by the regulation. This lack of resources and expertise often decreases the opportunity for stakeholders representing non-business interest to participate in open consultation procedures (Arras, 2017). Variations in resources tends to differ associations in stakeholders across the amount of resources they possess (Dür & Matteo, 2005). These resources include financial means, organizational capacity, legitimacy and representativeness, membership fees, knowledge and expertise (Dür & Matteo, 2005). These resources are important to the access interest groups have in influencing decision-makers.

The theory of access plays a critical role of EU institutions fulfilling their institutional role by exchanging interactions with private sector interest groups (Bouwen, 2004). Businesses organizations have the advantage of having resources and increased access to executive institutions, while citizens’ groups have increased outside lobbying undertakings (Dür & Matteo, 2012). Resources inform interest groups about the agenda setting policies and decision-making procedures (Dür & Matteo, 2012). These resources -legitimacy, information and expertise – can be exchanged with EU agencies for access in influencing decision-makers (Dür & Matteo, 2012). EU decision-makers are favorably interdependent on interest groups as they rely on policy feedback, technical information, in addition to legitimacy claims (Bunea, 2013; Mazey and Richardson 2015). BÖhmelt et. al, (2014), found international policy-making institutions to involve

civil society organizations (CSOs) in global governance arenas. One advantage interest groups offer is that they can often offer something which agencies cannot easily do (Yackee, 2005; Rourke, 1984). Yet, more often than not, stakeholder groups cannot be influential in their endeavors when lacking access to key points of decision-making processes (Ainsworth, 1993; Truman, 1995). Ainsworth (1993), further insists access for interest groups is no more than an “intermediate objective”. Hanegraaff et. al (2015), offers two prominent perspectives for addressing transnational advocacy by organized interest groups; one focuses on the political opportunities and consequences organized interest groups are offered by the global political arena, and the second focuses on domestic resources and regime types. Moreover, domestic resources and access prove to resourceful and supportive for interest groups to become increasingly politically active at the EU level (Hanegraaff et. al, 2015). The bulk of high resource organizations tend to be business sector, academic institutions, and national authorities.

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Consultations

One of the most prominent ways stakeholders can engage with policy-makers is perhaps through participating in public consultations. While the inclusion of stakeholders in regulatory consultation processes is necessary, empirical testing of stakeholder preference, through non-media frame analysis is lacking in this field. Examining frame variations enables testing consultation instruments for associations, if any, between the type of stakeholders involved and circulated frames. Stakeholder consultations are widely used policy instrument employed by policy-makers to design policies across multiple levels of government (Bunea, 2016). Consultation instruments establish a direct communication link between decision-makers and actors affected by policy issues, as they constitute an important channel where policy feedback is adopted into the potential challenges of policy developments (Bunea, 2016; Rasmussen et al., 2014). In terms of EU governance, stakeholder consultations play a key role in the intuitional power of balance between the EU Commission and agencies because they constitute as a source of legitimate information in policy conflicts (Bunea & Thomson, 2015). Public consultations are a realistic platform for the public to participate in offering quality preference data and expertise to institutions.

Stakeholder consultation procedures strategically contribute to increasing transparency in decision-making by increasing opportunities to examine the public information provided by concerned parties (Arras, 2017). Policymakers own power to design consultation procedures with the aim of diversifying the set of stakeholders from whom they receive information (Borrás et al. 2007). Public consultations are considered a useful tool to gather information from a diverse set of stakeholders. Given the low threshold and relatively low costs to participate compared with face-to-face meetings with policymakers, public consultations have been promoted by the European Commission, as a tool to foster the participation of non-business groups such as environmental NGOs or consumer groups (Bunea 2014; Furlong and Kerwin 2004; Klüver 2012; Quittkat 2011; Quittkat and Kohler-Koch 2013; Rasmussen and Carroll 2014; Yackee 2006; Yackee 2013; Yackee 2014).

Consultations are generally performed through submitting online statements to the organization. E-submissions increase the number of actors participating and provides transparency in

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stakeholders and agency. Open online consultations direct the wider public of stakeholders and interested parties to participate, giving equal change to access the agency, even though this may not guarantee impact results (Quittkat, 2011). Closed consultations are limited to specific interested parties, such as public authorities, specialist, business organizations (Quittkat, 2011). Consultations provide an open forum where political institutions can gain further insight into the structural diversity of preferences in the subsystems of political arenas. The early phases of consultation periods and agenda-setting stages within the European Commission are the most promising venues for interest groups to influence legislative content (Bunea, 2013). The consultation space allows external parties to represent their own interest. The way in which, interest groups articulate their preferences during consultation comment rounds, or any consultation instruments, affects the influence strategies this formulates (Bunea, 2014).

The interactive dialogue between policy-makers and stakeholders display institutionalized patterns identified across the EU system of governance (Bunea, 2016; Richardson & Coen, 2009). Stakeholder engagement organized by policymakers and formal institutions use consultations and access instruments interchangeably as a tool for involving stakeholders (Arras, 2017). It is important to note here, that not all consultation instruments were taken into account here. In public administration research, consultation procedures range depending on the agency. A distinction between open and closed access instruments is made on defining the degree of inclusiveness (Arras, 2017; Pedersen et al. 2015). The European Commission has implemented several platforms for a wide spectrum of external parties to participate in consultation mechanisms. Many of these stakeholder-oriented instruments encourage experts and citizens alike to participate in the policy discussion (Quittkat & Kotzian, 2011). For instance, the Commission embraces citizen-oriented tools such as online forums or European Citizens’ Conferences as methods for including a wider public interest (Quittkat & Kotzian, 2011). Extending consultation instruments to specific demographics is likely to result in observable patterns among stakeholder actors and preference interest.

EU agencies welcome external assistance from stakeholders because addressing comments by external parties proves instrumental in the policy-making process (Yackee, 2006). Consultation instruments vary, yet they generally take the form of organizing online forums at the request of

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knowledge pertaining to specific policy issues, especially in relation to regulations and risk

assessments (Borras, et al., 2007). Business groups often rely on direct access to policy-makers or

consult expert committees and such selective consultation forums (Mahoney, 2004; Bunea 2014). Consequently, they are considered less interested in the open consultation round. Consultation instruments vary in design and purpose, yet they all aim toward including representatives of varied interests for reasons increasing legitimacy, transparency, accountability, and expertise. Outsourcing for expertise from stakeholders underlies the foundation for consultation instruments (Kohler-Koch and Finke 2007). Open consultations serve as a platform for involved stakeholders to convey their preferences of support or opposition, most often through proposing strategic frames of policy preference changes to legislation. Consultations further serve agencies as a source of collecting sectoral expertise from stakeholders.

Consultation instruments represent different interest according to the agency. For example, the agency the EFSA hold structured consultations with stakeholders and scientist through the Scientific Colloquia and their Annual Colloquia’s (Borras, et al., 2001). Scientific colloquiums offer an interactive, participatory structure entailing speakers, group work and breakout discussion groups. Involving stakeholders, via consultation procedures, establishes a positive relationship between stakeholders and agencies. Another common form of consultation instruments within the EFSA agency are Management Board meetings, which entails four members holding backgrounds in organizations representing consumer or other interest associations in the food sector (EFSA, 2017) This provides more transparency in the agency governance structure. One influential study on EU agencies. Arras & Braun (2018) highlight different venues or access instruments, where independent agencies choose to work with stakeholders via:

- Public Consultations – open initiatives inviting citizens to participate in responding to questions or evaluations on existing policies (similar to European Commission Consultations)

- Stakeholder Bodies – permanent number of members are stakeholders who meet on a regular basis

- Representation in Management Boards – Agencies provide closed access to stakeholders who observe management board meetings.

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By opening consultations to a more diversified group, organizations increase their regulatory legitimacy. Furthermore, stakeholders are motivated to translate their suggestions into policy outcomes. Moreover, consultations provide benefits to all parties and foster positive engagement relationships. As such, the third hypothesis is:

Hypothesis 3: Open consultation instruments result in a higher likelihood of a target-statement frames to occur.

2. 6 SUMMARY OF HYPOTHESES

The above literature has paved the path for the development of the subsequent theoretical model for clarifying the relationship between policy frames during consultation processes and resulting stakeholder recommendations produced in agency policy output. Most studies focus on the contextual factors and incentives driving stakeholders in the European Union to use politicians and independent agencies to affect policy formulation (Borras et al., 2017). In looking at these studies, it is fundamentally ubiquitous to gather data to develop theories and evaluate practices.

As described throughout the above literature review, a series developed hypotheses are presented below:

Hypothesis 1: The more actors involved in a consultation, the greater the number of frames.

Hypothesis 2: Business actors be more likely than research institutions to use a target-statements or valence frames.

Hypothesis 3: Open consultation instruments result in a higher likelihood of a target-statement frames to occur.

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CHAPTER 3: RESEARCH METHODS AND DESIGN

3.1 CASE SELECTION

This evaluation builds upon similar studies conducted previously to design a data collection series and analysis to understand the different framing effects of non-state stakeholders in working to influence risk policies at an EU agency level. The population of this study was drawn from nine consultations conducted by the European Food Safety Authority. The EFSA was selected as the primary agency of analysis for a number of reasons. Firstly, the EFSA is a prominent example of how an EU independent agency, not only exerts credibility as an agency which produces risk assessments of scientific uncertainties (Rimkute, 2018), but also one which examines the expressed preferences of participatory non-state stakeholders. Secondly, this case explores stakeholder diversity nested in individual consultation processes. While this is a highly technical agency, it serves as a platform for engaging a more balanced array of stakeholders, yet indicates critical effects of biased participation (Arras, 2017). This is often observed through the different stages of regulatory decision-making, particularly through identifying which voices transcend outcomes from the preeminently different coalition of interests. Thirdly, this highly scientific agency, nonetheless, serves as a platform for communicating advice to legislators on scientific uncertainty and risks mainly associated within food systems. Thus, through this interesting case I expect to observe multiple types of frames across several interested parties and consultation instruments. For example, business interests and governments exerting stronger indications on regulatory frame competencies over those frames by academic research institutions.

In 2002, the European Union established a European agency called the European Food Safety Authority (EFSA, 2019). The creation of this agency followed the mishandled public health crisis of BSE, otherwise known as mad cow disease. This EU funded agency operates independent of the EU Commission, Council, Parliament and Member States (EFSA, 2019). As a result, the EFSA is responsible for providing scientific advice, based on risk assessments of risks associated with food security in the EU (EFSA, 2019). Effectively, the EFSA serves as an independent regulatory agency, which produces scientific advice for EU legislation related to food safety and environmental impacts on plants and animals (EFSA, 2019). Technically, legal law commits the EFSA to ensuring “The Authority shall develop effective contacts with consumer representatives,

Evaluating Frame Dynamics: A Comparative Analysis of Policy Framing within Stakeholder Consultations