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Ann Glover, as reported on Euractiv (here):

But it appears she also found it difficult to disentangle the Commission’s evidence gathering processes from what she calls the “political imperative” that’s behind them. …

To back its policy proposals, the Commission often outsources the evidence-gathering part of the job to external consulting firms, which provide ‘impact assessment studies’ or ‘research’ that are often branded as ‘independent’. However, Glover says such consultancies have little incentive to produce evidence that contradicts the Commission’s political agenda. “If they want repeat business, [they] are not going to go out and find the evidence to show that this is a crazy idea,” she says.

Disturbing stuff. In my role as an advisor and having taught policy development to civil servants, I have emphasised their responsibility to “speak truth to power”. If, as Glover says, this isn’t happening within the European policy-making machinery, then that may explain much policy creep at the Commission level.

Giant Squid, Glover's Harbour

The policy process: Not what Ann Glover has in mind? Source: Giant Squid, Glover's Harbour (Photo credit: Product of Newfoundland)

Her characterisation of European civil servants wind-up toys, that just run off and do what they are told suggests there could be some danger to good governance from hyperactive civil servants who unthinkingly do what they’re told with dossiers that should be binned. This suggest two things problems: the first is the quality of guidance on developing policy options itself, how to work with external advisors (carefully by the way) and the second is that the interface between the most senior level and Commissioners lacks candour and the failure of the most senior to truth to power. This is evidence of cowardice. at least, and incompetence at most.

Her remarks suggest that perhaps Glover hasn’t also been particularly effective elevating the evidence base of policy-making itself.  Her solution, though, is seriously flawed. She seems to believe that it is possible to create a definitive evidence base around which all can agree and that it is indeed possible in policy processes to factor out the political dimension. The ‘symmetry of ignorance’ [see NOTES below] explains why a room full of experts don’t usually agree and why it is relatively easy for ‘my’ experts to challenge ‘your’ experts. Policy problems are complex, sometimes called wicked, problems, and that means that one single course of action is unlikely, that interventions may create new problems, and unlike (scientific) problems, you may not know when you’ve solved the problem (called ‘the stopping’ problem).

What science dislikes is absence of agreement (e.g. science is about proof, not consensus), whereas policy is about consensus and disagreement: the result is one of the following: do nothing, act from the precautionary principle (i.e. do something just in case, but knowing there isn’t really any good evidence), guess, compromise or satisficing [see NOTES below].  Scientists often believe that evidence leads unequivocally to specific policy actions, but this is just one view of the world. While Glover has claimed to provide independent advice, she has actualy provided ‘her’ advice, reflecting how she weighs the balance of evidence against her understanding and framing of the problems and choices on offer from what she has read, and the people she has spoken to. One could legitimately ask whether her academic roots and scientific preferences as a biologist have preconditioned her towards thinking about policy problems and evidence in a particular way.That does not detract from her alarm at the policy machinery, but does inform our assessment of her proposed solution.

Hasn’t anyone read Feyerabend?

Therefore, purely technocratic policy governance, as I think Glover is advocating, is flawed and likely dangerous as it replaces the messiness of the real world of policy problems and choice-making with tidy authoritarianism.

Equally worrying is her comment on the quality of advice from paid consultants. I once put a dossier to a DG to be be an advisor, but haven’t been called (we’re up to almost 3 years, so I guess I shouldn’t expect the phone to ring!)  It is the job of advisors to advise, and that means also saying when something is not a good idea. That the European Commission has constructed a giant out-sourced advisory industry is not surprising as it is actually a tactic to cement the European project by creating an advisory system that works in harmony with the Commission’s objectives. That so many consultancies have fallen for this trick and taken the bait is disappointing but not surprising.

Many of the Commission-funded consultancy reports I have read have started and ended with the merits of the proposed Commission actions. I can’t recall a report that said something shouldn’t be done. It is also a tactic in assessing policy options (what Glover refers to as risk assessment) to write the most about the favoured option and less about the least favoured option.I blogged here on a Commission consultancy meeting, the cost of which was no doubt staggering; the Commissioner spoke on what she wanted, everyone agreed, the presentations showed how Europe would be a better place if this were done and everyone agreed with everyone, had a nice lunch and the many unpaid interns took notes for their CVs to PR firms or consultancies so they could get more work. And so the system feeds itself by indoctrinating people into the world of uncritical agreement.

Now, for disclosure, I have been ticked off by Commission civil servants for things I’ve said that were not European Commission

doctrine. Perhaps that explains why my dossier is in a box on the bottom shelf.

NOTE:

Symmetry of Ignorance: The expertise and ignorance is distributed over all participants in a wicked problem. There is a symmetry of ignorance among those who participate because nobody knows better by virtue of his degrees or his status. There are no experts (which is irritating for experts), and if experts there are, they are only experts in guiding the process of dealing with a wicked problem, but not for the subject matter of the problem. Source: Horst Rittel, 1972 “On the planning crisis”.

Satisficing is a decision-making strategy that attempts to meet criteria for adequacy, rather than to identify an optimal solution.

Freedom going up in digital flames

Freedom going up in digital flames

What if WikiLeaks were a book? Would governments be sending in their bully-boys to trash the bookstore? Would they try to put the publisher out of business?

And what sort of democratic government would idly stand by while others did such things? Indeed, wouldn’t such a government act to protect the bookstore, protect the publisher — something to do with freedom of speech I think.  I would have thought so until I see the difficulty WikiLeaks is having.

The persecution of WikiLeaks is tantamount to book-burning, and instead of bully-boys, we have hackers. What is worse is the complicity in what appears to be at least state-sanctioned actions by firms like Amazon (aren’t they in the freedom to read anything business?), PayPal (so much for open borders and free movement of money). Who is protecting hosting sites from cyber-attacks? I thought governments were worried about cyber-terrorism — I guess not when it is in their interests.

While we may have a variety of views on what the substance of the WikiLeaks stash of diplomatic cables (nice industrial era word), there are fundamental freedoms at work here. Yes governments need their secrets, but secrets and lies are one thing, believing we live in an open society (as Popper wrote about) brings with its risks. I had thought that democracies felt that it were better to risk the transparency of a democracy than the tyranny of a closed society. But of course, when you are subject to your own rules, that is when you discover how committed you are their protection. And therein lies the rub. Our democratic governments want openness and transparency for others, but when they are tested against these standards they are often found to be failing.

WikiLeaks is a phenomenon that will in time pass. But the evolution of open societies has been given a boost in the internet age, by enabling greater citizen empowerment, access to information, and what we are finding in many cases is the emperor has no clothes.

Enter the information-age book burners, whose intolerance is clear and their clandestine ability to subvert freedom of information has little restraint.

In the end, I worry more about how reactions against WikiLeaks will undermine the freedoms the internet brings than the embarrassing revelations of some civil servants sending messages home.

Want to know more?

Wikipedia has a good summary of book burnings over the years here.

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The stop sign design currently used in English...

Something NICE needs to do

NEWS FLASH: Setting a minimum price for a unit of alcohol would help tackle Britain’s drink problem, health advisers are expected to recommend. The National Institute for Health and Clinical Excellence (Nice) will include the advice in its guidance on how to crack down on problem drinking. (1 June 2010)

This commentary is not on whether to set a minimum price for alcohol. This is a comment about expansion of the scope of NICE’s mandate.

What is NICE for and why are they now becoming involved in more fundamental health policy matters? Under the rubric of health excellence, one assumes they are pushing this as far as they can possibly go.

NICE is really a disguised authoritarian advisory body because of their lack of proper public accountability coupled with their privileged access to ministers in government.

NICE are not ‘health advisors’; they are a fourth hurdle advisory body with a focus on what works in healthcare service delivery, such as medicines and device technologies. By moving outside this, they are creating the impression that any area of health interest can be subjected to their methodologies. Indeed, that all matters of policy can be reduced to a QALY analysis and some economic modelling. No doubt at some point, they will pass judgement on the health impact of the national speed limit,  the salt content of food, the pub opening hours, as long as there is some way to tie the analysis to a health outcome. Invoking their brand of technocratic thinking to replace the fine art of public consultation is hardly the way ahead — that there is some evidence for the benefits or costs, does not lead inexorably to the conclusion that health policy should change.  Running health policy by the numbers in this way guts the democratic process for deciding social priorities.

This all-purpose extension of the mandate of NICE is not a good thing, for democracy or for health policy in the UK.

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