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Frame conflicts and the formulation of alternatives
FEATURES
FRAME CONFLICTS AND THE FORMULATION OF ALTERNATIVES: ENVIRONMENTAL ASSESSMENT OF AN INFRASTRUCTURE PLAN Helena Valve Environmental Policy Instruments Division, Finnish Environment Institute
The environmental assessment of plans, programs, and policies should serve as an open policy forum where mutual learning among participants takes place. However, problems of communication may occur when the actors cannot agree which alternatives should be examined. It may be unclear what choices the assessment should shed light on. This article studies the conflicts related to the construction of policy alternatives by analyzing the environmental assessment of a transport infrastructure plan. The results indicate that not only the definition of the scope of the assessment task, but also the restrictions of decision-making, are key issues. It is sometimes harder to achieve agreement on freedom of action than to reach consensus about how to assess a particular set of alternatives. 1999 Elsevier Science Inc.
1. Introduction The environmental assessments of plans, programs, and policies should not only review impacts, but also make planning more interactive and decisionmaking more open. Moreover, the principles of environmental assessment stress the importance of exploring several alternatives (Sadler 1996, p. 151; Therivel 1993; Westerlund 1996). The formulation of the alternatives is, in many ways, an important phase. Alternatives affect the range of impact evaluations and public discussions; they define the scope of an environmental assessment. The alternatives are Address requests for reprints to: Helena Valve, Finnish Environment Institute, Environmental Policy Instruments Division, P.O. Box 140, 00251 Helsinki, Finland. E-mail: [email protected] ENVIRON IMPACT ASSESS REV 1999;19:125–142 1999 Elsevier Science Inc. All rights reserved. 655 Avenue of the Americas, New York, NY 10010
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relevant if they deal somehow with the most significant choices related to a decision. There may, however, be diverse views about what these choices actually are; that is, what the plan, program or policy is all about. As a result, the contents of the alternatives often create confusion and disagreements among the participating actors. Alternatives proposed by a responsible authority ma be criticized for being too general, too detailed, inadequate, or even misleading. Scientific arguments can be used to rank competing ideas about the relevant policy options, but they may not solve the controversies. The validity of a composition of alternatives is dependent on how the policy issues and decision-making situations are viewed. People may disagree over what the policy issue is about, what kind of problems are related to it, and which policy instruments are available. In addition, it may be unclear which earlier commitments (explicit or implicit) are relevant for the decision at hand, and which of these can be reopened for discussion. In this article I shall examine an environmental assessment process of a transport infrastructure plan called “the Nordic Triangle in Finland.” I analyze the disagreements that arose during the process about the relevant available planning alternatives in the assessment. My aim is to discuss reasons for the apparent problems of communication that arose during this particular process. I use the concept “framing” to characterize the ways the actors perceive planning issues and situations. Framing describes the processes of interpretation. Views of an issue, policy frames, are the result of selective use of scientific or lay knowledge and causal relationships associated with an issue. Through the policy frames the actors can reduce the flow of information and give it meaning (Gamson and Modigliani 1989). The frames are reflected in the way different descriptions of reality and arguments are used in policy debates to promote certain ends. This means that interpretative struggles concern not only what is at issue, but also what is to be done (Scho¨n and Rein 1994, pp. 29–33). The analysis has three parts. First, I examine the negotiations that took place in the task force that drafted the alternatives. Second, I study the feedback the task force received on its suggestions and analyze what kind of frame conflicts the feedback included. Third, I report the outcomes of the environmental assessment process. 2. Background
The “Nordic Triangle” The Nordic Triangle is defined as the traffic network connecting four Nordic capitals (Figure 1). In Finland, the Nordic Triangle is formed by the Turku– Helsinki–Vainikkala railway and its connections to essential harbors, the E18 highway, the most important south-coast harbors, Helsinki–Vantaa
FIGURE 1. The Nordic Triangle in Finland.
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airport, and various subsidiary functions. The corridor representing the Finnish section of the Triangle forms part of the Trans-European Networks (TEN). The Finnish government has applied for European Union (EU) financing for the Nordic Triangle plan, most of it being allocated to studies and interest subsidies for loans. The estimated total cost of the Nordic Triangle schemes in Finland is about ECU 3,000 million. Most of this is expected to be funded nationally, but Finnish authorities wish to see an increase in EU financing (Tervala 1995). A key issue in the development of the Nordic Triangle is the demands it places on the allocation of scarce resources between different transport modes and routes. This is decided by Parliament, based on the proposal made by the Ministry of Transport and Communications (henceforth called Ministry of Transport). The planning and construction of several Nordic Triangle investment projects had already begun as the environmental assessment process started. The schemes that have so far met the strongest opposition, from several localities and among national environmental organizations, are the development of some sections of the E18 highway and a new harbor of Helsinki. Clearly, these schemes would have a number of significant environmental and social impacts. Regional authorities in particular have campaigned for the development of the E18 highway. They wish to see the existing road upgraded to motorway standard over its complete length of 350 km. To ensure its financing, a special law was even proposed. This idea was discarded, but the proposition raised the need for a strategic environmental assessment.
Organization of the Environmental Assessment On July 31, 1995, the Ministry of Transport formed a task force to assess the environmental impact of the Nordic Triangle transport projects in Finland. The task force was to study and assess traffic development, development alternatives, and the environmental impacts of the alternatives. It consisted only of authorities, representing the Ministry of Transport (with 3 participants), the Ministry of the Environment (2), The Finnish National Road Administration (1), Rail Administration (1), and the Finnish Port Association (1). The task force was given 5 months to complete the assessment. The major objectives were to examine the connections between road and rail investments and to estimate the most likely indirect and cumulative impacts of alternative investment policy scenarios. The task force decided to concentrate on the formulation of alternative development options for the Nordic Triangle in Finland (Figure 2). From the beginning of the work, the task force was unanimous about the communicative and process-oriented nature of environmental assessments. An enlargement of the task force with a representative from a non-governmental organization was proposed, but this was discarded. This
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FIGURE 2. Formulation of development options for the Nordic Triangle.
would have created the need to invite all relevant NGOs to the task force. Instead, the task force decided to consult experts and arrange a seminar during the process. Certain civil servants and representatives from central interest organizations and NGOs were defined as experts. Some of these consultations were made by the secretaries of the task force only. A seminar was held with participants from a broad range of authorities and NGOs (72 participants in all). This seminar was restricted to invited, organized parties. The Nordic Triangle environmental assessment report eventually was sent to 52 different parties for their comments. Altogether
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23 written statements were received. In this way, some organizations were able to express their opinions at three different stages. Discussions about the content of the relevant alternatives took place mostly at the task force meetings and at the public seminar. 3. Materials and Methods In my capacity as one of the three part-time secretaries for the task force, I made notes about the evolution of the work. From the 11 interviews conducted by the secretariat, seven were taped. All seminar presentations and discussions also were taped. Additional material consisted of 23 written statements by different participants in the process. The study represents action research, which poses some problems. It is hard to say what my role was in the generation of those phenomena that here are considered findings. My aim as a secretary and a co-writer of the assessment report was to contribute to the process so that it would become as open and interactive as possible. I could influence the structure of the seminar in general and the content of the assessment report in particular, although the task force and its chairman had a purpose-oriented view in directing the work of the secretaries. I conducted a qualitative content analysis of the notes, all taped material, and the written statements. In the analysis I used the NUD.IST (nonnumerical unstructured data indexing, searching, and theorizing) program (Scolari/ Sage). A qualitative approach was chosen because the aim was to increase understanding about the problems of communication faced during the environmental assessment. 4. Environmental Assessment Process
Negotiating Policy Alternatives in the Task Force In the task force, general agreement was reached that the formulation of the alternatives is an important phase within an environmental assessment process, but the formulation turned out to be a more difficult task than expected. Some members, including the chairman from the Ministry of Transport, suggested that the formulation should begin by examining traffic forecasts. An overview of recent forecasts was made. However, as such, this was not accepted as a common ground for the alternatives. In particular, a member from the Ministry of Transport argued that forecasts are not matters of facts, but things that should be influenced by transport policy. The hearing of experts was started by inviting a specialist from the Ministry of Transport to speak about the development options for goods transport. The state of current affairs and matters of uncertainty were discussed. The specialist stressed the Ministry’s forecast of development, but some task force members initiated a debate about the sensitivity of
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goods transportation to structural changes. As a result, experts from other ministries were invited to speak about the future trends of production and regional development. Between the task force meetings the secretaries worked hard to get a common understanding on a meaningful approach to the issue. Policy choices were set into various hierarchies that were supposed to present how the making of transport policies proceeds. For example, tiering of various policy statements was discussed. However, none of the outlines considered were successful. Approaches emphasizing identification of policy choices were foreign to the consultants and experts offering advice. As alternatives, they suggested scenarios that were based on differing transport forecasts. Finally, it turned out to be crucial to divide developmental factors into two groups: active choices and background variables (Figure 3). This enabled the task force to discuss the relationships more specifically, i.e.: • •
Which critical factors influence the development of transport demand and modal choice, and How could these factors be controlled.
The task force had to reach agreement on which factors were going to be handled as active choices and which were the main uncertainties and background variables. The task force agreed, for example, that it was impossible to develop an alternative based on limiting the growth of goods transport. This would require changes in national production structure or regional structures that appeared to be unlikely to take place in the foreseeable future. Moreover, useful scenarios were non-existent. The specified alternatives represented the extremes of the possible investment policy. When the effect on transport was evaluated, the alternatives were studied in relation to divergent transport growth scenarios. The basic assumptions behind the scenarios (active choices) differed. The alternatives were as follows: “Max” Implementing all the Nordic Triangle development projects for the different modes of transport “Track” The railway-centered alternative. Implementing all the railway development projects related to the Nordic Triangle, and only those E18 schemes that will be started no later than 1996. “Road” The road-centered alternative. Implementing all the E18 highway development projects, but only those railway schemes that will be started no later than 1996. “Min” Not implementing any Nordic Triangle development projects other than those that will be started no later than 1996. The task force agreed that it was possible to influence the development of passenger transport. Those who had been stressing the principle of
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FIGURE 3. Division of developmental factors.
consumer sovereignty as a basis for policy-making were prepared to modify their standpoints. Alternative investment schemes were examined in relation to actions that could influence demand. However, the task force was unanimous that the full examination and determination of restriction measures were outside the scope of its task. The explicit recognition of the interactive nature of transport investments (supply) and demand was important for the further work of the task force. In this planning context, all representatives of the Ministry of the Transport agreed (implicitly) to broaden the interpretation of the issue, compared with the picture given earlier by the Ministry (Tervala 1995). Connections between the investment projects were acknowledged and studied. Surveys about the relationship between rail and road transportation were ordered from a consulting firm.
Interest Groups’ Conflicting Policy Frames The task force decided to ask experts and interest groups to comment on the draft alternatives by continuing with interviews and consultations and
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by arranging a seminar for a diverse group of interest parties. The interest groups invited to participate criticized the draft alternatives on various grounds. In all, four different policy frames could be identified and used for classifying most of the actors (Table 1). The frames conflicted in two different aspects, although not all of the actors presented views about both of them. First, they perceived the policy issue and the starting points of transport infrastructure planning in contradictory ways. As a result, they also had diverse views about relevant means of achieving policy. Second, they defined the institutional limits of decisionmaking differently. Many actors claimed that the draft alternatives were not in line with earlier policy commitments. It was unclear, however, which commitments were relevant. The issue was seen simultaneously as a matter of regional policy, transport policy, and environmental policy. Sometimes different actors referred to the same past commitments or studies but used them selectively to support their own arguments. Actors with similar policy frames often referred to each other. On the other hand, people who had differing policy frames did not communicate much with each other; when they did, the conversation tended to be unconstructive. In addition, the diversity of the topics raised complicated interaction and communication between actors. In the following discussion, the different actors groups and their policy frames are presented. Each group is named by its characteristic argument. 1. “Alternatives absurd and too broad.” The actors belonging to this group claimed that all but the “max” alternative were unrealistic, and therefore the whole exercise was unsuccessful. The issue was mainly examined from the point of view of goods transportation. These participants saw new transport investments, such as those included in the Nordic Triangle, both as results and as creators of potential new transportation. The motorway investments in particular were seen to be necessary, because of the competitive advantage they would give Finland and the Nordic Triangle transport corridor. More transit and more foreign investments are to be expected. Additionally, according to this view, the new investments do not influence the modal choice; road and railroad transportation complement each other. This group of actors also considered the draft alternatives to be absurd, because they saw the alternatives as raising questions about choices that had already been made: “This [the assessment and the questioning of the Nordic Triangle investment projects] is an attempt to cause a revolution because a budgetary decision has already been made by Parliament that a [Nordic Triangle] corridor shall be made . . . and the Government has tied its hands by sending EU a rather strong document for getting this corridor accepted, and by undertaking to do something for the project . . .” (SouthWest Finland Regional Council). In addition, the reconstruction of some
Group 1: • Confederation of Finnish Industry and Employers • Finnish Road Association • South-West Finland Regional Council • Finnish Trucking Association Group 2: • Two Regional Councils • Finnish Maritime Administration • Association of Finnish Local Authorities
Interest Groups Taxation and the prize of fuel already very high. Further intensification too costly. Markets set the demand: “Goods are not transported without purpose.”
As above.
As above.
Feasibility of the Growth Limitation Instruments
Benefits of transportation stressed.
Desirability of the Transportation Growth
TABLE 1. Conflicting Policy Frames of Interest Groups
Possible to influence the selection of modes to some extent.
Impossible or economically unwise to influence the selection of modes. Different transport routes compete.
Connections Between the Modes
As above. Additionally, some investment projects can be viewed as environmental policy means.
Investments viewed as means for industrialization and regional policies. Projects persuade new private investments to Southern Finland.
Role of Investment Projects
(continued)
As above.
The forecasts of domestic traffic reliable. Decisions should be based on them. However, estimates about the development of Russia include much uncertainty.
Accuracy and Significance of the Traffic Forecasts
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Group 3: • Environmental organizations • State Audit Office • Bus and Coach Association • Helsinki Metropolitan Area Council Group 4: • Ita¨-Uusimaa Regional Council • Gulf of Finland Coastal Region Cooperation Group
Interest Groups Limitation to the growth of transportation should be considered.
Desirability of the Transportation Growth
TABLE 1. (continued)
Needs to be examined further. Political commitments concerning the issue exist and they should be followed.
Feasibility of the Growth Limitation Instruments Investments viewed as transport and environmental policy means. Other policy solutions should be considered too.
Investments viewed as transport and environmental policy means. Specific railway and harbor investments should be added to the Triangle scheme.
Different transport modes compete.
Role of Investment Projects
Modes compete to a large extent. Possible to influence the selection of modes.
Connections Between the Modes
Forecasts should not be used mechanically as a ground for choices. Rather, they should be influenced by transport policy.
Accuracy and Significance of the Traffic Forecasts
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E18 sections was considered to show that a decision had been taken concerning the whole highway. According to this group, the focus of the environmental assessment should have been more on the actual realization of planned projects. However, some of these actors accepted the infringement of limiting conditions for methodological purposes, although more “realistic” alternatives would be needed later. 2. “Transport modes compete.” The arguments of the participants forming the second group were very similar to those of the first group. In particular, investment plans that were included in existing land-use plans were seen as planned once already and thus not worth much reconsideration. However, contrary to the first group, the actors in this group saw the transport modes mainly as competitors. Therefore, they were more satisfied with the composition of the alternatives drafted by the task force. The first two frames emphasize that the costs of limiting the supply of infrastructure would be too high and substantial opportunities would be lost. The main questions are, “Do we want development in this country?” and “How would the Triangle increase the competitiveness throughout the whole of Europe?” (researcher, University of Helsinki). Finland, they suggest, cannot afford to choose a no-action option, so such alternatives should not even be considered. This line of argumentation is similar to the justifications of the Nordic Triangle given by the Ministry for Transport (Linnainmaa 1995; Tervala 1995). Changes in international relations are expected to increase interactions between Finland and its neighbors. Around the Baltic Sea, and especially around the Gulf of Finland, a new economic activity is developing. The Nordic Triangle would help to strengthen development, particularly in southern Finland. The planned investments are motivated by existing transportation problems only to a limited extent, although the projects are presented as being more-or-less cost-benefit effective. 3. “More comprehensive alternatives needed.” The third set of actors emphasized the controllability of the transport demand. A representative of an NGO that aims for a new, environmentally friendly traffic policy pointed out that there are several estimates, and “this is the question that should be influenced by transport policy.” Additionally, a representative from the Finnish Nature Conservation Association proposed that environmental goals should form the basis for development and that the alternatives should present possible ways of achieving the main environmental goals via transport policy planning. These actors also criticized the definition of the planning task as being too narrow. The environmental organizations in particular wanted the planning options to be more broadly political; they should take a clear position on
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the policy control of transportation. This was seen to be consistent with certain commitments such as the Rio Declaration and policy measures set by the EU. Together with some interviewees, the environmental organizations saw the demand of different transport modes to be strongly related. As a result, these actors were worried about the long-term effects of the investment projects. Building of new motorways may increase the share of car traffic even more. If the money is given to public transport as subsidies, its share would increase. This would cause an environmentally self-strengthening development. 4. “Specific interests.” Some actors fell outside the three groups. They took a view only on a few specific principles used in the formulation of the alternatives. For example, the Finnish Railway Administration had no particular view on the total development, but they stressed the possibility of influencing the selection of modes by policy actions. The assessment also called forth very narrow, local interests. Certain port and rail investments were demanded as additions to the alternatives formulated by the task force. These schemes had not been defined as part of the Nordic Triangle, but the parties in question considered their development important. These actors presented very limited opinions on issues other than these projects of local importance.
Outcomes of the Environmental Assessment The task force did not change the alternatives it had drafted. The comments it had received were discussed, and these had some influence on the focus of the impact evaluations. The investigations of the task force were superficial and were based mostly on existing information. Totally new studies were, however, made about the effects of the alternatives on transport. The contents and wording of the final conclusions were given much attention. It was unclear to the task force what could be concluded on the basis of the available investigations. The disagreements were reflected partly in the ambiguity of the wording in the final report. The Task Force stated that “the investments forming part of the Nordic Triangle can be used to some extent to affect the demand for transport and the relative shares of the various modes of transport” (Ministry of Transport and Communications 1996; p. 44). This is the case in long-distance passenger transport and for Russian imports and exports particularly (pp. 23–24). In another context it is stated that “Nordic Triangle investments do not greatly influence transport demand and the role of traffic modes” (p. 3). Although the task force was unanimous, the environmental assessment did not help to solve the political struggle concerning the Nordic Triangle. When the assessment report was delivered, the chairman of the task force
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used his authority to influence the media. He gave the impression that the environmental impacts of the E18 highway would be mostly positive (e.g., in Finland’s largest newspaper, Helsingin Sanomat 1996); this was not what the task force had concluded. The task force set out guidelines concerning the further planning of all the investment projects. Decisions should state how the Nordic Triangle assessment had been taken into account. In addition, there is a recommendation in the report that says the relationship between the assessment and decisions to be made in the intermediate economic plans must be clarified (Ministry of the Transport and Communications 1996, p. 45). Neither of these recommendations has been followed. Decision-making is proceeding project by project. Some projects are split into smaller units, for example, into several road sections. They appear to be planned and decided without reference to the Nordic Triangle environmental assessment. 5. Discussion The actors in Nordic Triangle environmental assessment process discussed the alternatives, that is, the policy solutions available. Simultaneously, the interpretative struggles were about the correct problem definitions. This confirms the claim that policy problems, which typically are ambiguous, complex, and characterized by many uncertainties, must be structured before something can be done to them (Feldman 1989; Hajer 1995; Roe 1994; Scho¨n and Rein 1994; Stone 1989). According to Hajer (1995, p. 15), policymaking is to be analyzed as a creation of problems that institutions can handle and to which solutions can be found. The controversies that appear during policy preparation often are understood as the result of misunderstandings or conflicting values and interests (Amy 1987). Within an environmental assessment process, the negotiations between specific interests are seen as important (O’Riordan and Sewell 1981). Values and interests are, however, affected by the way policy issues and situations are viewed (Benton 1981; Hajer 1995; Rydin 1997; Scho¨n and Rein 1994). In addition, as the studied process showed, the actors may not express their preferences explicitly. Instead, the actors used claims tactically presenting the planning task so that their propositions appeared as beneficial, necessary, or inevitable. The identified policy frames gave impressions of either a narrow or large freedom of action. Those actors who considered the policy feasibility low also claimed that the institutional limitations were very limiting and vice versa. Some actors tried to limit the assessment to technical questions, whereas some others wished it to cover reconsideration of fundamental policy principles. The parties criticizing new investment schemes questioned the official problem definition of the Ministry of Transport. They claimed the environ-
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mental assessment to include features of non–decision-making, although they did not refer to this concept. By non–decision-making, Bachrach and Baratz (1962) refer to the limitation of public consideration to only those issues that are comparatively innocuous for those in a powerful position. The groups that stressed the necessity of the new investment schemes, in turn, pointed out that lengthy reconsiderations might cause a loss of a historical opportunity to develop the transport system. In addition, one group of actors viewed the assessment process as a policy window (Kingdon 1984) where they could run their very specific concerns. Many actors viewed the discussion about the impacts of the drafted alternatives fruitless, because the alternatives were, according to them, absurd or too limited. An agreement on the alternatives would have been needed for making the discussion of the significance of specific impacts and their mitigation meaningful. If this does not happen, some groups may be marginalized from the public debate, as there is no problem definition that can reflect their opinions and objectives (Gregory and Keeney 1994). Did the assessment process function as a learning process? Glasbergen (1997) distinguishes between cognitive learning, where knowledge is a dominant variable, and social learning, which is based on responsive communication leading to reframing of the policy issue. In the studied case, cognitive learning occurred, but the policy of the Ministry of Transport did not change. It seems that the assessment process failed to promote social learning. The time table, only 5 months for the whole exercise, is an obvious partial explanation for the lack of social learning. Policy frames tend to change over long time periods (Scho¨n and Rein 1994), and it is difficult to specify the role of an individual environmental assessments in this process. Decisions on individual investment schemes had been taken before the environmental assessment about the whole Nordic Triangle was carried out. It is, however, difficult to say what the correct timing of the assessment should have been, because there were various views about the progress of the policy process. In addition, the powerful parties may carry out prior, but concealed, maneuvers that limit future considerations (Miller et al. 1996). One important reason for the lack of learning was that the Ministry of Transport did not expect the assessment process to bring any changes to the planning and implementation of the investment schemes. Neither did it participate in the negotiations with an open and reflective attitude. Instead, as the results indicate, the environmental assessment was, for the Ministry of Transport, a gesture it was pressed to carry out, but which could simultaneously support the legitimacy of the Nordic Triangle. The motive for getting an environmental assessment done thus may be to convince the audience and other financiers that environmental matters are taken care of and that the decision-making is carried out in an appropriate manner.
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However, the shortcomings of the assessment did not totally exclude its function as a communicative process (Rydin 1997). The exercise demonstrated that environmental assessments can bring actors, who otherwise may have few opportunities to participate, into policy debates and planning. 6. Conclusions An environmental assessment process is meaningful if it can have input into policy outcome; if at least some freedom of action exists. This means that environmental assessments are about examining different policy alternatives. Comparison of several alternatives is useful because the environmental impacts often appear most easily as distinctions between the alternatives. If just one planning alternative is considered, the future development is shown as more-or-less inevitable. The choices made within a plan, program, or policy are various and multi-dimensional. Some of these are related to the basic assumptions made in a planning situation and others are about the details of the plan. This complexity makes the formulation of the alternatives difficult. Sometimes it may be useful to focus on certain main alternatives and to examine some specific questions or entities separately. Identification of crucial choices and new possibilities to act thus may become a major task of an assessment. The formulation of alternatives is not only a technical problem. Environmental assessments function as arenas where interpretative struggles about the planning problem and existing freedom of action take place. During environmental assessments official problem definitions may be contested. New information about environmental and other impacts are not likely to solve these controversies as such. Resources given to data collection, analyses, and public hearings may be wasted, if the controversies related to problem definition are left unexamined. Agreement in principle on the options available is a primary condition if the parties are to consider an assessment relevant to decision-making. Some of the problems faced in the case studied might have been easier to tackle, if their likelihood had been acknowledged beforehand. The formulation of the alternatives was seen as an important and demanding task, but the variety of the problem definitions and perceptions surprised the task force. In addition, the demands on the utilization of the assessment report proved to be insufficient, and the political decision-makers did not know the report or did not bother to ask for it. Stronger public pressure or an ex-post evaluation system might have increased the effort that was put to the Nordic Triangle environmental assessment. In the future, however, benefits are likely to be achieved if the authority preparing a plan, program, or policy realizes the value of cooperation and reflection. In assessment processes characterized by social learning, new ways of thinking and acting can be found. As a result, authori-
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ties may become better equipped to respond to the environmental policy demands they constantly face. This paper has benefitted from comments by Per Mickwitz, Timo Peuhkuri, and Anders H.H. Jansson. I am especially grateful to Dr. Mikael Hilde´n for his advice and valuable remarks.
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Rydin, Y. 1997. Can we talk ourselves into sustainability? Paper presented at the seminar “Society, Environment and Sustainability—The Nordic Perspective,” August 25–27, 1997, Oslo, Norway. Sadler, B. 1996. Environmental Assessment in a Changing World: Evaluating Practice to Improve Performance. International Study of the Effectiveness of Environmental Assessment. Canadian Environmental Assessment Agency, International Association for Impact Assessment. Scho¨n, D.A., and Rein, M. 1994. Frame Reflection. Toward the Resolution of Intractable Policy Controversies. New York: Basic Books. Stone, D.A. 1989. Causal stories and the formulation of policy agendas. Political Science Quarterly 104(2):281–300. Tervala, J. 1995. The Strategy of the Nordic Triangle in Finland. The Conference on the Nordic Triangle in Helsinki 10.-11.10.1995. Therivel, R. 1993. Systems of strategic environmental assessment. Environmental Impact Assessment Review 13:145–168. Westerlund, S. 1996. Genuine environmental impact assessments (EIA) and a genuine EIA concept. In Miljøkonsekvensvundering—i et retligt perspektiv, E.M. Basse (ed). København: GadJura.
FRAME CONFLICTS AND THE FORMULATION OF ALTERNATIVES: ENVIRONMENTAL ASSESSMENT OF AN INFRASTRUCTURE PLAN Helena Valve Environmental Policy Instruments Division, Finnish Environment Institute
The environmental assessment of plans, programs, and policies should serve as an open policy forum where mutual learning among participants takes place. However, problems of communication may occur when the actors cannot agree which alternatives should be examined. It may be unclear what choices the assessment should shed light on. This article studies the conflicts related to the construction of policy alternatives by analyzing the environmental assessment of a transport infrastructure plan. The results indicate that not only the definition of the scope of the assessment task, but also the restrictions of decision-making, are key issues. It is sometimes harder to achieve agreement on freedom of action than to reach consensus about how to assess a particular set of alternatives. 1999 Elsevier Science Inc.
1. Introduction The environmental assessments of plans, programs, and policies should not only review impacts, but also make planning more interactive and decisionmaking more open. Moreover, the principles of environmental assessment stress the importance of exploring several alternatives (Sadler 1996, p. 151; Therivel 1993; Westerlund 1996). The formulation of the alternatives is, in many ways, an important phase. Alternatives affect the range of impact evaluations and public discussions; they define the scope of an environmental assessment. The alternatives are Address requests for reprints to: Helena Valve, Finnish Environment Institute, Environmental Policy Instruments Division, P.O. Box 140, 00251 Helsinki, Finland. E-mail: [email protected] ENVIRON IMPACT ASSESS REV 1999;19:125–142 1999 Elsevier Science Inc. All rights reserved. 655 Avenue of the Americas, New York, NY 10010
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relevant if they deal somehow with the most significant choices related to a decision. There may, however, be diverse views about what these choices actually are; that is, what the plan, program or policy is all about. As a result, the contents of the alternatives often create confusion and disagreements among the participating actors. Alternatives proposed by a responsible authority ma be criticized for being too general, too detailed, inadequate, or even misleading. Scientific arguments can be used to rank competing ideas about the relevant policy options, but they may not solve the controversies. The validity of a composition of alternatives is dependent on how the policy issues and decision-making situations are viewed. People may disagree over what the policy issue is about, what kind of problems are related to it, and which policy instruments are available. In addition, it may be unclear which earlier commitments (explicit or implicit) are relevant for the decision at hand, and which of these can be reopened for discussion. In this article I shall examine an environmental assessment process of a transport infrastructure plan called “the Nordic Triangle in Finland.” I analyze the disagreements that arose during the process about the relevant available planning alternatives in the assessment. My aim is to discuss reasons for the apparent problems of communication that arose during this particular process. I use the concept “framing” to characterize the ways the actors perceive planning issues and situations. Framing describes the processes of interpretation. Views of an issue, policy frames, are the result of selective use of scientific or lay knowledge and causal relationships associated with an issue. Through the policy frames the actors can reduce the flow of information and give it meaning (Gamson and Modigliani 1989). The frames are reflected in the way different descriptions of reality and arguments are used in policy debates to promote certain ends. This means that interpretative struggles concern not only what is at issue, but also what is to be done (Scho¨n and Rein 1994, pp. 29–33). The analysis has three parts. First, I examine the negotiations that took place in the task force that drafted the alternatives. Second, I study the feedback the task force received on its suggestions and analyze what kind of frame conflicts the feedback included. Third, I report the outcomes of the environmental assessment process. 2. Background
The “Nordic Triangle” The Nordic Triangle is defined as the traffic network connecting four Nordic capitals (Figure 1). In Finland, the Nordic Triangle is formed by the Turku– Helsinki–Vainikkala railway and its connections to essential harbors, the E18 highway, the most important south-coast harbors, Helsinki–Vantaa
FIGURE 1. The Nordic Triangle in Finland.
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airport, and various subsidiary functions. The corridor representing the Finnish section of the Triangle forms part of the Trans-European Networks (TEN). The Finnish government has applied for European Union (EU) financing for the Nordic Triangle plan, most of it being allocated to studies and interest subsidies for loans. The estimated total cost of the Nordic Triangle schemes in Finland is about ECU 3,000 million. Most of this is expected to be funded nationally, but Finnish authorities wish to see an increase in EU financing (Tervala 1995). A key issue in the development of the Nordic Triangle is the demands it places on the allocation of scarce resources between different transport modes and routes. This is decided by Parliament, based on the proposal made by the Ministry of Transport and Communications (henceforth called Ministry of Transport). The planning and construction of several Nordic Triangle investment projects had already begun as the environmental assessment process started. The schemes that have so far met the strongest opposition, from several localities and among national environmental organizations, are the development of some sections of the E18 highway and a new harbor of Helsinki. Clearly, these schemes would have a number of significant environmental and social impacts. Regional authorities in particular have campaigned for the development of the E18 highway. They wish to see the existing road upgraded to motorway standard over its complete length of 350 km. To ensure its financing, a special law was even proposed. This idea was discarded, but the proposition raised the need for a strategic environmental assessment.
Organization of the Environmental Assessment On July 31, 1995, the Ministry of Transport formed a task force to assess the environmental impact of the Nordic Triangle transport projects in Finland. The task force was to study and assess traffic development, development alternatives, and the environmental impacts of the alternatives. It consisted only of authorities, representing the Ministry of Transport (with 3 participants), the Ministry of the Environment (2), The Finnish National Road Administration (1), Rail Administration (1), and the Finnish Port Association (1). The task force was given 5 months to complete the assessment. The major objectives were to examine the connections between road and rail investments and to estimate the most likely indirect and cumulative impacts of alternative investment policy scenarios. The task force decided to concentrate on the formulation of alternative development options for the Nordic Triangle in Finland (Figure 2). From the beginning of the work, the task force was unanimous about the communicative and process-oriented nature of environmental assessments. An enlargement of the task force with a representative from a non-governmental organization was proposed, but this was discarded. This
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FIGURE 2. Formulation of development options for the Nordic Triangle.
would have created the need to invite all relevant NGOs to the task force. Instead, the task force decided to consult experts and arrange a seminar during the process. Certain civil servants and representatives from central interest organizations and NGOs were defined as experts. Some of these consultations were made by the secretaries of the task force only. A seminar was held with participants from a broad range of authorities and NGOs (72 participants in all). This seminar was restricted to invited, organized parties. The Nordic Triangle environmental assessment report eventually was sent to 52 different parties for their comments. Altogether
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23 written statements were received. In this way, some organizations were able to express their opinions at three different stages. Discussions about the content of the relevant alternatives took place mostly at the task force meetings and at the public seminar. 3. Materials and Methods In my capacity as one of the three part-time secretaries for the task force, I made notes about the evolution of the work. From the 11 interviews conducted by the secretariat, seven were taped. All seminar presentations and discussions also were taped. Additional material consisted of 23 written statements by different participants in the process. The study represents action research, which poses some problems. It is hard to say what my role was in the generation of those phenomena that here are considered findings. My aim as a secretary and a co-writer of the assessment report was to contribute to the process so that it would become as open and interactive as possible. I could influence the structure of the seminar in general and the content of the assessment report in particular, although the task force and its chairman had a purpose-oriented view in directing the work of the secretaries. I conducted a qualitative content analysis of the notes, all taped material, and the written statements. In the analysis I used the NUD.IST (nonnumerical unstructured data indexing, searching, and theorizing) program (Scolari/ Sage). A qualitative approach was chosen because the aim was to increase understanding about the problems of communication faced during the environmental assessment. 4. Environmental Assessment Process
Negotiating Policy Alternatives in the Task Force In the task force, general agreement was reached that the formulation of the alternatives is an important phase within an environmental assessment process, but the formulation turned out to be a more difficult task than expected. Some members, including the chairman from the Ministry of Transport, suggested that the formulation should begin by examining traffic forecasts. An overview of recent forecasts was made. However, as such, this was not accepted as a common ground for the alternatives. In particular, a member from the Ministry of Transport argued that forecasts are not matters of facts, but things that should be influenced by transport policy. The hearing of experts was started by inviting a specialist from the Ministry of Transport to speak about the development options for goods transport. The state of current affairs and matters of uncertainty were discussed. The specialist stressed the Ministry’s forecast of development, but some task force members initiated a debate about the sensitivity of
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goods transportation to structural changes. As a result, experts from other ministries were invited to speak about the future trends of production and regional development. Between the task force meetings the secretaries worked hard to get a common understanding on a meaningful approach to the issue. Policy choices were set into various hierarchies that were supposed to present how the making of transport policies proceeds. For example, tiering of various policy statements was discussed. However, none of the outlines considered were successful. Approaches emphasizing identification of policy choices were foreign to the consultants and experts offering advice. As alternatives, they suggested scenarios that were based on differing transport forecasts. Finally, it turned out to be crucial to divide developmental factors into two groups: active choices and background variables (Figure 3). This enabled the task force to discuss the relationships more specifically, i.e.: • •
Which critical factors influence the development of transport demand and modal choice, and How could these factors be controlled.
The task force had to reach agreement on which factors were going to be handled as active choices and which were the main uncertainties and background variables. The task force agreed, for example, that it was impossible to develop an alternative based on limiting the growth of goods transport. This would require changes in national production structure or regional structures that appeared to be unlikely to take place in the foreseeable future. Moreover, useful scenarios were non-existent. The specified alternatives represented the extremes of the possible investment policy. When the effect on transport was evaluated, the alternatives were studied in relation to divergent transport growth scenarios. The basic assumptions behind the scenarios (active choices) differed. The alternatives were as follows: “Max” Implementing all the Nordic Triangle development projects for the different modes of transport “Track” The railway-centered alternative. Implementing all the railway development projects related to the Nordic Triangle, and only those E18 schemes that will be started no later than 1996. “Road” The road-centered alternative. Implementing all the E18 highway development projects, but only those railway schemes that will be started no later than 1996. “Min” Not implementing any Nordic Triangle development projects other than those that will be started no later than 1996. The task force agreed that it was possible to influence the development of passenger transport. Those who had been stressing the principle of
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FIGURE 3. Division of developmental factors.
consumer sovereignty as a basis for policy-making were prepared to modify their standpoints. Alternative investment schemes were examined in relation to actions that could influence demand. However, the task force was unanimous that the full examination and determination of restriction measures were outside the scope of its task. The explicit recognition of the interactive nature of transport investments (supply) and demand was important for the further work of the task force. In this planning context, all representatives of the Ministry of the Transport agreed (implicitly) to broaden the interpretation of the issue, compared with the picture given earlier by the Ministry (Tervala 1995). Connections between the investment projects were acknowledged and studied. Surveys about the relationship between rail and road transportation were ordered from a consulting firm.
Interest Groups’ Conflicting Policy Frames The task force decided to ask experts and interest groups to comment on the draft alternatives by continuing with interviews and consultations and
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by arranging a seminar for a diverse group of interest parties. The interest groups invited to participate criticized the draft alternatives on various grounds. In all, four different policy frames could be identified and used for classifying most of the actors (Table 1). The frames conflicted in two different aspects, although not all of the actors presented views about both of them. First, they perceived the policy issue and the starting points of transport infrastructure planning in contradictory ways. As a result, they also had diverse views about relevant means of achieving policy. Second, they defined the institutional limits of decisionmaking differently. Many actors claimed that the draft alternatives were not in line with earlier policy commitments. It was unclear, however, which commitments were relevant. The issue was seen simultaneously as a matter of regional policy, transport policy, and environmental policy. Sometimes different actors referred to the same past commitments or studies but used them selectively to support their own arguments. Actors with similar policy frames often referred to each other. On the other hand, people who had differing policy frames did not communicate much with each other; when they did, the conversation tended to be unconstructive. In addition, the diversity of the topics raised complicated interaction and communication between actors. In the following discussion, the different actors groups and their policy frames are presented. Each group is named by its characteristic argument. 1. “Alternatives absurd and too broad.” The actors belonging to this group claimed that all but the “max” alternative were unrealistic, and therefore the whole exercise was unsuccessful. The issue was mainly examined from the point of view of goods transportation. These participants saw new transport investments, such as those included in the Nordic Triangle, both as results and as creators of potential new transportation. The motorway investments in particular were seen to be necessary, because of the competitive advantage they would give Finland and the Nordic Triangle transport corridor. More transit and more foreign investments are to be expected. Additionally, according to this view, the new investments do not influence the modal choice; road and railroad transportation complement each other. This group of actors also considered the draft alternatives to be absurd, because they saw the alternatives as raising questions about choices that had already been made: “This [the assessment and the questioning of the Nordic Triangle investment projects] is an attempt to cause a revolution because a budgetary decision has already been made by Parliament that a [Nordic Triangle] corridor shall be made . . . and the Government has tied its hands by sending EU a rather strong document for getting this corridor accepted, and by undertaking to do something for the project . . .” (SouthWest Finland Regional Council). In addition, the reconstruction of some
Group 1: • Confederation of Finnish Industry and Employers • Finnish Road Association • South-West Finland Regional Council • Finnish Trucking Association Group 2: • Two Regional Councils • Finnish Maritime Administration • Association of Finnish Local Authorities
Interest Groups Taxation and the prize of fuel already very high. Further intensification too costly. Markets set the demand: “Goods are not transported without purpose.”
As above.
As above.
Feasibility of the Growth Limitation Instruments
Benefits of transportation stressed.
Desirability of the Transportation Growth
TABLE 1. Conflicting Policy Frames of Interest Groups
Possible to influence the selection of modes to some extent.
Impossible or economically unwise to influence the selection of modes. Different transport routes compete.
Connections Between the Modes
As above. Additionally, some investment projects can be viewed as environmental policy means.
Investments viewed as means for industrialization and regional policies. Projects persuade new private investments to Southern Finland.
Role of Investment Projects
(continued)
As above.
The forecasts of domestic traffic reliable. Decisions should be based on them. However, estimates about the development of Russia include much uncertainty.
Accuracy and Significance of the Traffic Forecasts
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Group 3: • Environmental organizations • State Audit Office • Bus and Coach Association • Helsinki Metropolitan Area Council Group 4: • Ita¨-Uusimaa Regional Council • Gulf of Finland Coastal Region Cooperation Group
Interest Groups Limitation to the growth of transportation should be considered.
Desirability of the Transportation Growth
TABLE 1. (continued)
Needs to be examined further. Political commitments concerning the issue exist and they should be followed.
Feasibility of the Growth Limitation Instruments Investments viewed as transport and environmental policy means. Other policy solutions should be considered too.
Investments viewed as transport and environmental policy means. Specific railway and harbor investments should be added to the Triangle scheme.
Different transport modes compete.
Role of Investment Projects
Modes compete to a large extent. Possible to influence the selection of modes.
Connections Between the Modes
Forecasts should not be used mechanically as a ground for choices. Rather, they should be influenced by transport policy.
Accuracy and Significance of the Traffic Forecasts
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E18 sections was considered to show that a decision had been taken concerning the whole highway. According to this group, the focus of the environmental assessment should have been more on the actual realization of planned projects. However, some of these actors accepted the infringement of limiting conditions for methodological purposes, although more “realistic” alternatives would be needed later. 2. “Transport modes compete.” The arguments of the participants forming the second group were very similar to those of the first group. In particular, investment plans that were included in existing land-use plans were seen as planned once already and thus not worth much reconsideration. However, contrary to the first group, the actors in this group saw the transport modes mainly as competitors. Therefore, they were more satisfied with the composition of the alternatives drafted by the task force. The first two frames emphasize that the costs of limiting the supply of infrastructure would be too high and substantial opportunities would be lost. The main questions are, “Do we want development in this country?” and “How would the Triangle increase the competitiveness throughout the whole of Europe?” (researcher, University of Helsinki). Finland, they suggest, cannot afford to choose a no-action option, so such alternatives should not even be considered. This line of argumentation is similar to the justifications of the Nordic Triangle given by the Ministry for Transport (Linnainmaa 1995; Tervala 1995). Changes in international relations are expected to increase interactions between Finland and its neighbors. Around the Baltic Sea, and especially around the Gulf of Finland, a new economic activity is developing. The Nordic Triangle would help to strengthen development, particularly in southern Finland. The planned investments are motivated by existing transportation problems only to a limited extent, although the projects are presented as being more-or-less cost-benefit effective. 3. “More comprehensive alternatives needed.” The third set of actors emphasized the controllability of the transport demand. A representative of an NGO that aims for a new, environmentally friendly traffic policy pointed out that there are several estimates, and “this is the question that should be influenced by transport policy.” Additionally, a representative from the Finnish Nature Conservation Association proposed that environmental goals should form the basis for development and that the alternatives should present possible ways of achieving the main environmental goals via transport policy planning. These actors also criticized the definition of the planning task as being too narrow. The environmental organizations in particular wanted the planning options to be more broadly political; they should take a clear position on
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the policy control of transportation. This was seen to be consistent with certain commitments such as the Rio Declaration and policy measures set by the EU. Together with some interviewees, the environmental organizations saw the demand of different transport modes to be strongly related. As a result, these actors were worried about the long-term effects of the investment projects. Building of new motorways may increase the share of car traffic even more. If the money is given to public transport as subsidies, its share would increase. This would cause an environmentally self-strengthening development. 4. “Specific interests.” Some actors fell outside the three groups. They took a view only on a few specific principles used in the formulation of the alternatives. For example, the Finnish Railway Administration had no particular view on the total development, but they stressed the possibility of influencing the selection of modes by policy actions. The assessment also called forth very narrow, local interests. Certain port and rail investments were demanded as additions to the alternatives formulated by the task force. These schemes had not been defined as part of the Nordic Triangle, but the parties in question considered their development important. These actors presented very limited opinions on issues other than these projects of local importance.
Outcomes of the Environmental Assessment The task force did not change the alternatives it had drafted. The comments it had received were discussed, and these had some influence on the focus of the impact evaluations. The investigations of the task force were superficial and were based mostly on existing information. Totally new studies were, however, made about the effects of the alternatives on transport. The contents and wording of the final conclusions were given much attention. It was unclear to the task force what could be concluded on the basis of the available investigations. The disagreements were reflected partly in the ambiguity of the wording in the final report. The Task Force stated that “the investments forming part of the Nordic Triangle can be used to some extent to affect the demand for transport and the relative shares of the various modes of transport” (Ministry of Transport and Communications 1996; p. 44). This is the case in long-distance passenger transport and for Russian imports and exports particularly (pp. 23–24). In another context it is stated that “Nordic Triangle investments do not greatly influence transport demand and the role of traffic modes” (p. 3). Although the task force was unanimous, the environmental assessment did not help to solve the political struggle concerning the Nordic Triangle. When the assessment report was delivered, the chairman of the task force
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used his authority to influence the media. He gave the impression that the environmental impacts of the E18 highway would be mostly positive (e.g., in Finland’s largest newspaper, Helsingin Sanomat 1996); this was not what the task force had concluded. The task force set out guidelines concerning the further planning of all the investment projects. Decisions should state how the Nordic Triangle assessment had been taken into account. In addition, there is a recommendation in the report that says the relationship between the assessment and decisions to be made in the intermediate economic plans must be clarified (Ministry of the Transport and Communications 1996, p. 45). Neither of these recommendations has been followed. Decision-making is proceeding project by project. Some projects are split into smaller units, for example, into several road sections. They appear to be planned and decided without reference to the Nordic Triangle environmental assessment. 5. Discussion The actors in Nordic Triangle environmental assessment process discussed the alternatives, that is, the policy solutions available. Simultaneously, the interpretative struggles were about the correct problem definitions. This confirms the claim that policy problems, which typically are ambiguous, complex, and characterized by many uncertainties, must be structured before something can be done to them (Feldman 1989; Hajer 1995; Roe 1994; Scho¨n and Rein 1994; Stone 1989). According to Hajer (1995, p. 15), policymaking is to be analyzed as a creation of problems that institutions can handle and to which solutions can be found. The controversies that appear during policy preparation often are understood as the result of misunderstandings or conflicting values and interests (Amy 1987). Within an environmental assessment process, the negotiations between specific interests are seen as important (O’Riordan and Sewell 1981). Values and interests are, however, affected by the way policy issues and situations are viewed (Benton 1981; Hajer 1995; Rydin 1997; Scho¨n and Rein 1994). In addition, as the studied process showed, the actors may not express their preferences explicitly. Instead, the actors used claims tactically presenting the planning task so that their propositions appeared as beneficial, necessary, or inevitable. The identified policy frames gave impressions of either a narrow or large freedom of action. Those actors who considered the policy feasibility low also claimed that the institutional limitations were very limiting and vice versa. Some actors tried to limit the assessment to technical questions, whereas some others wished it to cover reconsideration of fundamental policy principles. The parties criticizing new investment schemes questioned the official problem definition of the Ministry of Transport. They claimed the environ-
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mental assessment to include features of non–decision-making, although they did not refer to this concept. By non–decision-making, Bachrach and Baratz (1962) refer to the limitation of public consideration to only those issues that are comparatively innocuous for those in a powerful position. The groups that stressed the necessity of the new investment schemes, in turn, pointed out that lengthy reconsiderations might cause a loss of a historical opportunity to develop the transport system. In addition, one group of actors viewed the assessment process as a policy window (Kingdon 1984) where they could run their very specific concerns. Many actors viewed the discussion about the impacts of the drafted alternatives fruitless, because the alternatives were, according to them, absurd or too limited. An agreement on the alternatives would have been needed for making the discussion of the significance of specific impacts and their mitigation meaningful. If this does not happen, some groups may be marginalized from the public debate, as there is no problem definition that can reflect their opinions and objectives (Gregory and Keeney 1994). Did the assessment process function as a learning process? Glasbergen (1997) distinguishes between cognitive learning, where knowledge is a dominant variable, and social learning, which is based on responsive communication leading to reframing of the policy issue. In the studied case, cognitive learning occurred, but the policy of the Ministry of Transport did not change. It seems that the assessment process failed to promote social learning. The time table, only 5 months for the whole exercise, is an obvious partial explanation for the lack of social learning. Policy frames tend to change over long time periods (Scho¨n and Rein 1994), and it is difficult to specify the role of an individual environmental assessments in this process. Decisions on individual investment schemes had been taken before the environmental assessment about the whole Nordic Triangle was carried out. It is, however, difficult to say what the correct timing of the assessment should have been, because there were various views about the progress of the policy process. In addition, the powerful parties may carry out prior, but concealed, maneuvers that limit future considerations (Miller et al. 1996). One important reason for the lack of learning was that the Ministry of Transport did not expect the assessment process to bring any changes to the planning and implementation of the investment schemes. Neither did it participate in the negotiations with an open and reflective attitude. Instead, as the results indicate, the environmental assessment was, for the Ministry of Transport, a gesture it was pressed to carry out, but which could simultaneously support the legitimacy of the Nordic Triangle. The motive for getting an environmental assessment done thus may be to convince the audience and other financiers that environmental matters are taken care of and that the decision-making is carried out in an appropriate manner.
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However, the shortcomings of the assessment did not totally exclude its function as a communicative process (Rydin 1997). The exercise demonstrated that environmental assessments can bring actors, who otherwise may have few opportunities to participate, into policy debates and planning. 6. Conclusions An environmental assessment process is meaningful if it can have input into policy outcome; if at least some freedom of action exists. This means that environmental assessments are about examining different policy alternatives. Comparison of several alternatives is useful because the environmental impacts often appear most easily as distinctions between the alternatives. If just one planning alternative is considered, the future development is shown as more-or-less inevitable. The choices made within a plan, program, or policy are various and multi-dimensional. Some of these are related to the basic assumptions made in a planning situation and others are about the details of the plan. This complexity makes the formulation of the alternatives difficult. Sometimes it may be useful to focus on certain main alternatives and to examine some specific questions or entities separately. Identification of crucial choices and new possibilities to act thus may become a major task of an assessment. The formulation of alternatives is not only a technical problem. Environmental assessments function as arenas where interpretative struggles about the planning problem and existing freedom of action take place. During environmental assessments official problem definitions may be contested. New information about environmental and other impacts are not likely to solve these controversies as such. Resources given to data collection, analyses, and public hearings may be wasted, if the controversies related to problem definition are left unexamined. Agreement in principle on the options available is a primary condition if the parties are to consider an assessment relevant to decision-making. Some of the problems faced in the case studied might have been easier to tackle, if their likelihood had been acknowledged beforehand. The formulation of the alternatives was seen as an important and demanding task, but the variety of the problem definitions and perceptions surprised the task force. In addition, the demands on the utilization of the assessment report proved to be insufficient, and the political decision-makers did not know the report or did not bother to ask for it. Stronger public pressure or an ex-post evaluation system might have increased the effort that was put to the Nordic Triangle environmental assessment. In the future, however, benefits are likely to be achieved if the authority preparing a plan, program, or policy realizes the value of cooperation and reflection. In assessment processes characterized by social learning, new ways of thinking and acting can be found. As a result, authori-
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ties may become better equipped to respond to the environmental policy demands they constantly face. This paper has benefitted from comments by Per Mickwitz, Timo Peuhkuri, and Anders H.H. Jansson. I am especially grateful to Dr. Mikael Hilde´n for his advice and valuable remarks.
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