Political Studies (1996), XLIV, 343-351

Who Learns What from Whom: a Review of the Policy Transfer Literature

DAVID DOLOWITZ AND DAVID MARSH Department of Political Science and International Studies,

University of Birmingham

As Rose argues policy transfer or lesson drawing is common:

Every country has problems, and each think that its problems are unique . . . However, problems that are unique to one country . . . are abnormal . . . confronted with a common problem.’ policy makers in cities, regional governments and nations can learn from how their counterparts elsewhere responded.’

It has always existed but there can be no doubt that the rapid growth in communications of all types since the Second World War has accelerated the process. Not surprisingly, the increase in policy transfer has led to the development of interest in the topic among students of comparative politics and public policy. This article reviews this literature which is of two types. First, there are studies which do not use the concept but which often throw consider- able light on policy transfer. Second, there is a growing body of material dealing specifically with the process. Both types of study are now common. As an example, the June 1994 edition of Political Studies included two articles dealing with the issues discussed here. Walsh’s examination of exchange rate policy in France and Germany is a good representative of the first type of study. He does not discuss transfer, but shows how international capital flows gave rise to tensions in the European Monetary System which, in turn, led to policy convergence. In contrast, Coleman’s analysis of policy convergence in banking directly addressed the question of how international economic changes affect policy goals, policy content, policy instruments and policy style. The aim of this article is to present a critical review of the literature on policy transfer in order to both introduce the topic to a wider audience and contribute to its development.

Our review is both narrower and broader than the major existing review by Bennett.* Bennett’s approach is broader in that he concentrates upon the general pattern of convergence between the policies adopted by nations. In contrast, our focus is more narrowly upon the transfer of specific policies as a result of strategic decisions taken by actors inside and outside government. At the same time however, our approach is broader, particularly because we:

’ R. Rose, ‘What is lesson drawing?’, Journal of Public Policy, 11 (1991), 3-30, p. 3. ’ C. Bennett, ‘What is policy convergence and what causes it?’, British Journal of Political Science, 21 (1991), 215-33. DPolitical Studies Association 1996. Published by Blackwell Publishers. 108 Cowley Road. Oxford OX4 IJF. U K and 238 Main Street, Cambridge, MA 02142, USA

344 Review Section

consider transfer within nations as well as between nations; acknowledge the significance of actors outside the government machine in the process; and place more emphasis upon how governments, international organizations and trans- national companies can push other governments into policy transfer. The full implication of these differences will become clear by the end of this review.

We have organized this review around a series of questions which are raised explicitly or implicitly by the literature. What is policy transfer? Who transfers policy? Why is there policy transfer? What is transferred? Are there different degrees of transfer? From where are lessons drawn? What factors constrain policy transfer? What problems are there with the literature?

What is Policy Transfer?

Policy transfer. emulation and lesson drawing all refer to a process in which knowledge about policies, administrative arrangements, institutions etc. in one time and/or place is used in the development of policies, administrative arrangements and institutions in another time and/or place. We do not think that the difference in nomenclature is overly significant. However, we do not use the terms policy transfer and lesson drawing interchangeably, unlike Rose who refers to the overall process by which policy or institutions are transferred as lesson drawing3

In our view, the term ‘lesson drawing‘ implies that political actors or decision makers in one country draw lessons from one or more other countries, which they then apply to their own political system. This focuses on ‘voluntary’ policy transfer, which occurs as a result of the free choices of political actors; yet, as we shall see later, an important category of policy transfer involves one govern- ment or supra-national institution pushing, or even forcing, another govern- ment to adopt a particular policy. Policy transfer, a term that can cover ‘voluntary’ and ‘coercive’ transfer, seems to us to be a more appropriate term. However, we use the term lesson drawing because, in many cases, lessons are drawn from other places or times which do not result in policy or institutional change. So, for example, in some cases a negative lesson may be drawn about how not to proceed.

The study of policy transfer emerged gradually as a sub-set of the compara- tive politics literature. Before 1940 most comparative studies focused on the formal institutions of government and were thus ‘state centred’ and overly descriptive. During the 1940s such approaches became less fashionable and studies began examining how civil society interacted with the state. By the 1960s a key focus was upon comparative policy analysis.

As the field of comparative policy analysis emerged, a number of authors, notably Walker. showed considerable interest in process termed policy diffusion. These initial studies were not concerned with the specific content of the policies being transferred, but rather sought explanations of diffusion based on timing, geographic propinquity and resource similarities; as such, they had a much narrower focus than later studies of policy t r a n ~ f e r . ~ As diffusion studies

’ K. Rose. Lesson-drawing in Public Polic!.: a Guide 10 Lmwning acros Time and Space (New

‘ J. Walker. The diffusion of innovations among the American states’. The American Polilical Jersey. Chatham House. 1993).

Scicwcc Revielt., 3 3 (1969). 880-99. ( Political Studieb Associaison. 1996

Review Section 345

advanced the weaknesses of the approach emerged; so that by the 1980s a major critical review argued: ‘(the) major problem of this research tradition is that it reveals nothing about the content of new policies. Its fascination is with process not s~bstance’ .~ It was as a result of this perceived need to answer questions ignored by diffusion studies that comparative policy analysts began discussing lesson drawing and policy transfer.

Initially transfer studies primarily focused upon voluntary transfer, seeing the process as one in which policies implemented elsewhere were examined by rational political actors for their potential utilization within another political system. More recently the literature has begun to address questions concerning coercive transfer.

Who Transfers Policy? This literature identifies six main categories of actors involved in policy transfer, although in any specific case of transfer more than one category of actor is likely to be involved: elected official$ political par tie^;^ bureaucrats/civil servants;* pressure groups;’ policy entrepreneurslexperts; and supra-national institutions. The role of the first four is well rehearsed, but the last two categories merit brief discussion.

Policy EntrepreneurslExperts As Rose points out, policy entrepreneurs are not only important to lesson drawing because of their advocacy of lessons, but also because: ‘their concern with a special subject . . . leads them to build up a nationwide or international network of contacts that are a source of ideas for new programs’.’’

The role of such policy entrepreneurs in the international spread of an idea is clearly illustrated in Rowat’s study of Ombudsmen. He argues:

There is no doubt that some of the ombudsmen themselves have been very influential in bringing about the further spread of the institution, particularly Professor Hurwitz of Denmark . . . and Sir Guy Powles of New Zealand.”

J. Clark, ‘Policy diffusion and program scope’, Publius, 15 (1985) 61-70, p. 65. See A. Heidenheimer, H. Heclo and C. Adams, Comparative Public Policy (New York, St.

Martins Press, 1990); D. Robertson and J. Waltman, ‘The politics of policy borrowing’, paper presented to the APSA Annual Meeting, Chicago, 3-6 September (1992). ’ H. Heclo, Modern Social Politics in Britain and Sweden (New Haven CT, Yale University Press, 1974).

See E. Haas, ‘Why collaborate? Issue-linkage and international regimes’, World Politics, 32 (1980). 357-405, p. 357; H. Wolman, ‘Understanding cross-national policy transfers: the case of Britain and the US’, Governance, 5 (1992) 27-45, p. 31.

See Rose, Lesson-drawing in Public Policy, p. 56. For further examples see: D. McAdam and D. Rucht, ‘Cross-national diffusion of movement ideas’, Annals of the American Academy of Polirical and Social Science, 528 (1993), 56-74, or G. Hoberg, ‘Sleeping with an elephant: the American influence on Canadian environmental regulation’, Journal of Public Policy, 11 (1991), 107-32.

‘O Rose, Lesson-drawing in Public Policy, p. 56. I I D. Rowat, The Ombudsman Plan: Essays on World-wide Spread of an Idea (London,

McClelland and Stewart, 1973), pp. 357-76, p. 119. C Political Studies Association, 1996

346 Re vie Sect ion

In this way experts from inside and outside government interact to spread ideas in what Haas terms epistemic communities.’*

Supra-national Organizations As Rose argues:

Intergovernmental and international organizations encourage exchanges of ideas between countries . . . The European Community and OECD encourage exchanges among advanced industrial nations . . . and the World Bank and the United Nations agencies focus on programs of concern to developing countries.’3

Rose goes on to emphasize that the European Community: ‘promotes com- parison . . . so that member states can become aware of what their competitors are doing and decide which elements of foreign programs they may wish to copy or adapt.14 Similarly, Bennett found that international organizations were important actors transferring data protection p01icies.I~ One problem with these studies is they pay too little attention to the fact that international organizations are also involved in coercive transfer, an issue we shall return to later.

Why Engage in Policy Transfer? Lessons can be used in a number of ways and for a variety of reasons. Both supporters and opponents of various policies use lessons selectively to gain advantage in the struggle to get their ideas accepted. As Robertson says: ‘policy lessons from abroad often are put forward as politically neutral truths. Beneath this . . . adversaries are just as often using such lessons as political weapons’.I6

In attempting to explain why transfer occurs we must return to the distinction between voluntary and coercive transfer, although it should be acknowledged that at the margin the two types merge. In addition, a further distinction needs to be made between cases of direct coercive transfer and those cases in which the push factors leading to policy transfer are more indirect.

(a) Voluntary Transfer Most authors suggest that the primary catalyst of voluntary transfer is some form of dissatisfaction or problem with the status quo. Supporters of the dissatisfaction model presume that when governmental policies are functioning properly there is no need to search for lessons; everything can operate through established routines. Only when routines stop providing ‘solutions’ is it necessary to search for lessons.”

’’ P. Haas, ‘Do regimes matter? Epistemic communities and mediterranean pollution control’,

’’ Rose, Lesson-drubring in Public Policy. p. 105. See also Robertson and Waltman, ‘The politics

l4 Rose, Lesson-druning in Public Policy. p. 105. ’’ C. Bennett, ‘Different processes, one result: the convergence of data protection policy in

l 6 Robertson. ’Political conflict and lesson drawing‘. p. 55. ” Rose, Lesson-druw’ing in Public Policj,. p. 10.

Internalional Orgunisarions, 143 (1989), 233-403.

of policy borrowing’, esp. p. 7.

Europe and the United States’, Governance. 1 (1988) 425-41, especially p. 431.

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A number of causes of dissatisfaction are identified in the literature, but most authors argue that dissatisfaction usually results from a perception, either by the Government or the public, of policy failure. However, there is a clear problem with this analysis because it assumes that policy failure is a non- contentious and easily measurable concept. In fact, as Anderson points out, political actors definitions of policy problems are subjective and ‘political’.I8 For example, although the dramatic increase in world wide unemployment led President Clinton to call for a ‘Job Summit’ with G-7 nations in 1993, the Thatcher Administration, in contrast, viewed inflation, not unemployment, as the key economic problem.

As Polsby argues, elections may also force candidates to search for lessons because:

A central part of the regular quadrennial public competition for the presidential office is that candidates . . . must find programs to which they can attach their names. (As such) Presidents who wish to differentiate themselves from their predecessors and . . . make an individual mark on history . . . provide a steady market of policy innovation.”

Certainly, Heclo amply illustrates the role party competition played in the development of social policies in Britain and Sweden.20

As Bennett argues: ‘evidence is used in the policy process in highly selective ways to legitimate decisions already taken. Thus, information about the effects of a program elsewhere enters debate to justify prior positions’.*’ This process is clear in a study by Henig, Hamnett, and Feigenbaum of the international spread of privatization. In this field, government’s, committed to ‘New Right’ free market economic policies, used lessons drawn from countries which had already privatized to legitimate their decisions to implement particular forms of privatization.22

Uncertainty about the cause of problems, the effects of previous decisions or the future causes actors to search for policies they can borrow. As Haas argues: ‘the hallmark of complex interdependence is uncertainty . . . International collaboration . . . is an attempt to reduce uncertainty’ 23 Indeed, he demon- strates how uncertainty led policy makers to turn to international experts in their attempts to regulate pollution in the Mediterranean.

(b) Direct Coercive Transfer The most direct method of coercive policy transfer is when one government forces another to adopt a policy. Majone provides an excellent example in his analysis of the reasons countries pursue regulatory policies. In particular, he

C. W. Anderson ’The logic of public problems’ in D. Ashford (ed.), Comparing Public Policies (Beverly Hills, Sage, 1978). pp. 19-38.

l9 N. Polsby, Political Innovations in America, p. 161. 2o Heclo, Modern Social Politics. *’ C . Bennett, ‘How states utilize foreign evidence’, Journal of Public Policy, 11 (1991), 31-54,

22 Henig et al., ‘The politics of privatization: a comparative perspective’. 23 Haas, ’Do regimes matter?’, pp. 377-403.

p. 38.

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demonstrates how American regulators forced European states to adopt American anti-cartel laws:

It is well known that the anti-cartel clauses of the ECSC treaty . . . were significantly influenced by the American model . . . Washington, repre- sented by John McCloy . , . insisted more than once on a particular wording of individual article^.'^

The direct imposition of policy transfer on one country by another is rare. However, supra-national institutions often play a key role in coercive policy transfer. For example, supra-national institutions have played a crucial role in the spread of Western monetary policies to Third World countries. Inter- national Monetary Fund or World Bank loans are much cheaper for these countries, but in return the IMF will stipulate certain economic policies that have to be implemented if the loan is to be granted.25 The European Union (EU) and the European Court of Justice are other supra-national institutions forcing policy transfer upon member nations. Indeed, Shapiro shows how the EU has functioned as a policy-pusher, using its power to issue directives and regulations, while the European Court of Justice has forced Governments to adopt policy directives the EU has issued.'6 Trans-national corporations (TNCs) can also force governments into policy transfer because they hold a trump card. They can threaten to take their businesses elsewhere. This potential mobility can force governments to adopt policies capable of attracting industries. Certainly, Heidenheimer et al. suggest that such threats have constrained some Governments in relation to environmental regula- tion.?'

(c) Indirect Coercive Transfer Hoberg emphasizes the potential role of externalities, or functional inter- dependence, in indirect coercive transfer. His analysis shows that the Canadians looked to America for lessons which could be used in drafting their environ- mental regulation, largely as a result of the indirect effect US pollutants, and regulations, had on the Canadian side of the border.28

There is little doubt that externalities. which result from interdependence, push government to work together to solve common problems. In this way, Haas demonstrates how such interdependence was responsible for policy transfer and the development of common environmental policies in the M e d i t e r r a n e a ~ ~ ~ Similarly, Majone discovered that externalities stimulated the development of European chemical regulations; in response to American

'4 G . Majone, 'Cross-national sources of regulatory policy making in Europe and the United Styes', Journal of Public Policx. 11 (1991), 79 106, pp. 85-6. -' For recent examples see: J . Lloyd. ' IMF gives go-ahead for $1.5bn loan to Russia', The Financial Times. 23 March (1993) or 'Algeria devalues in deal with IMF' , The Financial Times, 1 1 April (1994). '' M. Shapiro. 'The European Court of Justice'. Euro-polirics (Washington DC, Brookings Institute, 1992). '' Heidenheimer et al.. Comparative Public Polio', p. 3 1 1. '' Hoberg. 'Sleeping with an elephant'. '' Haas. 'Why collaborate? Issue-linkage and international regimes'. 1 Polilioal Studies Association. 1996

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legislation controlling imports of toxic substances, European countries turned to the EC to develop common r e g ~ l a t i o n s . ~ ~

Technology can also push governments into policy transfer because of the speed with which it forces change. Governments, not knowing how to deal with the issues technological advances create, turn to each other for precedents and ideas.31

The world economy constrains individual governments and economic pressures can lead to transfer. In this vein, M ~ r a n ~ ~ and Coleman33 show how global economic integration led to convergence in the institutional structures and trading practices in the securities market and the banking sector respectively. When one country depends upon another as its primary market it may also be pushed into adopting similar policies. Hoberg argues: ‘historically, much of Canadian economic policy has been focused on resisting the natural north-south pull of economic activity in N~r th-Amer ica’ .~~

A country can also be indirectly pushed towards policy transfer if political actors perceive their country as falling behind its neighbours or competitors. As Bennett puts it: ‘fears of being left behind on an important public issue can trigger attention. The cumulative effect of action elsewhere may translate into a feeling of insecurity about being the ~ d d - m a n - o u t ’ . ~ ~ Certainly, Hoberg argues that national embarrassment, caused by the perception that Canada was falling behind the United States in environmental regulation, pushed policy makers to emulate American auto-emission standards during the 1 9 8 0 ~ ~ ~

The emergence of an international consensus may also act as a push factor. When the international community defines a problem in a particular way, and even more when a common solution to that problem has been introduced in a number of nations, then nations not adopting this definition or solution will face increasing pressure to join the international ‘community’ by implementing similar programmes or policies. In this way Bennett explains Canada’s intro- duction of data protection legislation as a response to the pressures associated with the international consensus emerging around the importance of data protection during the 1 9 8 0 ~ . ~ ~

What is Transferred? As is clear from this review to date, it is wrong to think of policy transfer merely in terms of the successful transfer of policy. Bennett’s review focuses largely upon the transfer of policy goals, content and instrument^.^^ In our view this focus is still too narrow. In fact, we identify seven objects of transfer: policy

30 Majone, ‘Cross-national sources of regulatory policy making’, p. 98. See also C. Bennett, ‘The formation of a Canadian privacy policy: the art and craft of lesson-drawing’, Canadian Public Administration, 33 (1990), 551-70, p. 563.

3’ C. Bennett, Regulating Privacy (Ithaca NY, Cornell University Press, 1993), p. 118-23, 150-1. 32 M. Moran, The Politics of the Financial Services Revolution: the USA, UK and Japan (Basing-

33 W. Coleman, ‘Policy convergence in banking: a comparative study’, Political Srudies, XLII

34 Hoberg, ‘Sleeping with an elephant’, p. 109. 35 Bennett, ‘How states utilize foreign evidence’, p. 43. 36 Hoberg, ‘Sleeping with an elephant’, p. 114. 3’ Bennett, Regulating Privacy. 38 Bennett, ‘How states utilize foreign evidence’.

stoke, Macmillan, 1991).

(1994), 274-92.

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3 50 Reviebt. Section

goals, structure and content; policy instruments or administrative techniques; institutions; ideology; ideas, attitudes and concepts; and negative lessons.

In several studies Wolman traces the transfer of urban development policies between the United States and Britain and argues that: ‘what potential borrowers appear to be most concerned with is program structure rather than effect‘.39 Wolman demonstrates how the transfer of the US UDAG programme to Britain involved the borrowing of the entire programme structure. However, he also points out that both general policy ideas and specific policy instruments can be transferred, but that the borrower may pick and choose what to borrow: ‘in many cases a specific policy idea . . . may be borrowed, but the specific design or structure through which this occurs in the original country may not be’.40

Robertson and Waltman show how various leaders and administrators used policy instruments or administrative techniques, for example ‘experience rating’ and productivity measures, borrowed from other countries. Indeed, they argue: ’most public policy borrowing appears to involve administrative techniques . . . rather than a change of policy dire~t ion’ .~’ However, this is contentious, for Majone concludes that, while there is considerable policy transfer between nations, few cases involve policy in~truments.~?

The institutions used to implement policy can also be transferred. Haas demonstrates that the establishment of many environmental Ministries to protect the Mediterranean involved substantial borrowing of ideas and

Similarly. Training and Enterprise Councils (TECs) in England and Wales and Local Enterprise Companies (LECs) in Scotland were based upon American Private Industry Councils ( P I C S ) . ~ ~

Robertson and W a l t m a r ~ ~ ~ demonstrate that President Reagan and Prime Minister Thatcher adopted each other’s ideological rhetoric to justify and spread political programmes based upon ‘New Right’ principles. More specifi- cally, the analysis by Henig ef al. of the development of privatization politics and policies in Britain, France and the United States indicates that other governments sent delegations to Britain to learn about both the details of the privatization programme and the ideology underpinning it.46

Political actors can also transfer ideas, attitudes and concepts; although this category overlaps the last one. During the 1980s the rhetoric adopted to justify changes in the British welfare system was drawn directly from American writings which emphasized dependency, reciprocal obligations and using welfare to help recipients help them~elves.~’

Similarly, in his analysis of the development of data protection legislation, Bennett shows that transfer led to policy convergence around the principle of

39 Wolman, ‘Understanding cross-national policy transfers’, p. 35. 4o Wolman, ‘Understanding cross-national policy transfers’. p. 41. See also: Bennett, ‘Different

4’ Robertson and Waltman. ’The politics of policy borrowing’. p. 9. 42 Majone. ‘Cross-national sources of regulatory policy making’, p. 83. 43 Haas, ‘Do regimes matter’. 4.1 R. Bennett. P. Wicks and A. McCoshan. Local Empowerment and Business Services (London.

processes one result’, p. 418.

UCL Press, 1994) and C. Stratton. TECs and PICs: the key issues which lie ahead, Regional Studies, 24 (1989). 71 -4.

45 Robertson and Waltman. ’The politics of policy borrowing’. 4h Henig el a / . , ‘The politics of privatization’, p. 458. 47 A. Digby. British Wi,(fare Pofirj.: Workhouse ro WorkJare (London, Faber and Faber, 1989),

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‘fair in f~rmat ion’ .~~ Interestingly, while the countries adopted a shared comprehensive set of data protection principles and legislated to protect citizens against abuses, none designed the same policy instruments to enforce these principles.

Lessons can be negative as well as positive. As an example, after examining 1970s American auto-emission standards, Canadian legislators made an explicit decision not to emulate American standards, believin them to be unnecessarily

the development of American data protection legislation, legislators and bureaucrats specifically rejected the Hessian statute as inappropriate as it protected the interests of the state over those of the people.50

restrictive, given Canada’s environmental s i t~a t ion .~ !? In the same way, during

Are there Different Degrees of Transfer? When engaged in policy transfer actors have a range of options on how to incorporate lessons into their political system, Rose identifies five: copying; emulation; hybridization; synthesis; and in~piration.~’ We prefer to combine the two related categories of hybridization and synthesis.

Copying occurs when a country adopts a programme in use elsewhere without any changes. The easiest way to prove that copying has occurred is to examine the wording of the legislative bill authorizing a p r ~ g r a m m e . ~ ~ Emulation happens when a country: ‘reject(s) copying in every detail, [but] accepts that a particular program elsewhere provides the best standard for designing legislation at home’.53 Hybridization and synthesis involve combin- ing elements of programmes found in two or more countries to develop a policy best-suited to the emulator. Finally, studying familiar problems in an unfamiliar setting can expand ideas and inspire fresh thinking about what is possible at home.s4

From where are Lessons Drawn? When policy makers begin searching for lessons, their own country’s past is the logical place to begin.55 By searching the past, agents learn not only what has worked but can learn what not to repeat. So, Rose claims: ‘the defence policies of Germany and Japan today represent lessons learned about what not to d ~ ’ . ~ ~ Similarly, in examining the rise of Keynesianism during the Depression, Weir

48 Bennett, Regulating Privacy. 49 Hoberg, ‘Sleeping with an elephant’, p. 1 12. Similarly, Canadian legislators explicitly rejected

the American Freedom of Information Act as a model because it was: ‘incoherent, confusing and injurious to legitimate privacy interests’, Bennett, ‘The formation of Canadian privacy policy’, p. 564.

50 Bennett, Regulating Privacy, p. 124. s‘ Rose, Lesson-drawing in Public Policy, p. 132-4. 52 J. Waltman, Copying other Nations Policies: Two American Case Studies (Cambridge MA,

53 Rose, ‘What is lesson drawing’, p. 21. 54 Rose, ‘What is lesson drawing’, p. 22. 55 This does not take into consideration that the environment surrounding the policy may have

56 Rose, Lesson-drawing in Public Policy, p. 88.

Schenkam, 1980), p. 5.

changed to the point that the same solution no longer works.

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and Skocpol found social democratic policy ideas were re-articulated from past attempts to implement Keynesian type programme^.^^

Searching for lessons within a political system‘s past has the advantage of saving time and resources. However, searching the past involves subjective evaluation; while history is constant it is open to many interpretations and current situation’s may not be truly analogous to past ones. Indeed, when drawing lessons actors might not truly understand the past or its relation to the present. At the same time, given that most policy develops over time, deciding from which period to draw lessons can critically affect the lesson drawn. Finally, as Rose points out, time is not a constant when actors are engaging in policy transfer: ‘obstacles to lesson-drawing are not permanent; in the course of time many obstacles become variable^'.^^

When searching within a nation, actors may start with their own organization because different branches and divisions provide opportunities for transferring administrative techniques and procedures. As Rose emphasizes: ‘the first lace

Actors can also draw lessons from other political systems within their own country if its constitutional structures create a series of similar sub-national units of government within a relatively harmonious political culture. As an example, the United States 1988 Family Support Act, was developed based upon the experiences of state welfare programmes during the 1980~.~’

Although constraints exist, it is common for governments and agents to transfer policies from one nation to another. So, for example, in the welfare area international policy transfer has played a crucial role in the spread of poor laws and unemployment legislation since the nineteenth century. Not only were British poor houses adopted in the United States during the nineteenth century, but, as Heclo shows: ‘experience in Denmark and New Zealand were important in Britain . . . however, it was experience in Germany that stirred greatest international interest’.6’

Some countries and regional governments commonly export policies to other nations and regions. While examining policy transfer between the United States and Canada, Robertson and Waltman found that particular American States and Canadian Provinces acted as policy leaders: ‘(their) innovations are disproportionately copied by neighbouring jurisdictions’.62 Heclo shows that Germany played a similar role in the transfer of unemployment insurance to Sweden and Britain during the early twentieth century.63 Similarly, Bennett found that the 1973 Swedish Data Act acted as an exemplar to other nations instituting data protection laws.64

for an organisation to look is to its own standard operating procedure 7 . 5 r

’’ M. Weir and T. Skocpol, ‘State structures and the possibilities for “Keynesian” responses to the Great Depression in Sweden, Britain, and the United States’ in P. Evans, D. Ruescheneyer and T. Skocpol (eds), Bringing the Stares Back In (Cambridge, Cambridge University Press, 1985), pp. 107-63.

58 Rose, Lesson-drawing in Public Policy, p. 18. s9 Rose, ‘What is lesson drawing?, p. 13. 6o For more information on this case contact David Dolowitz. 6’ Heclo, Modern Sociul Politics, p. 310.

63 Heclo, Modern Social Po/itics.

and regions, are used as exemplars.

Robertson and Waltman, ‘The politics of policy borrowing’, p. 8.

Bennett, Regulating Privacy. This case also demonstrates that some policies, as well as nations

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The basic assumption involved in drawing lessons from other nations is that: ‘similarities are greater within a given program across national boundaries than among different programs within a ~ountry’ .~’ When drawing lessons across nations, geographic propinquity does not equate with policy transfer because ideological and resource similarities are necessary preconditions to adapt lessons from one country to another and neighbouring countries do not always meet these preconditions. We return to this question below.

What Factors Constrain Policy Transfer? The complexity of a programme affects its transferability; the more complex a policy or programme is the harder it will be to transfer. Although the effect of complexity on transferability is an understudied area, Rose suggests six hypotheses:

1 programmes with single goals are more transferable than programmes with multiple goals;

2 the simpler the problem the more likely transfer will occur; 3 the more direct the relationship between the problem and the ‘solution’ is

perceived to be the more likely it is to be transferred: 4 the fewer the perceived side-effects of a policy the greater the possibility of

transfer; 5 the more information agents have about how a programme operates in

another location the easier it is to transfer; 6 the more easily outcomes can be predicted the simpler a programme is to

transfer.66

These hypotheses offer a basis for future research but attention also needs to be paid to the way complexity interacts with the other factors discussed here to help shape what is transferred and in what form.

Rose makes a key point which students of policy neglect at their peril:

Policy makers are inheritors before they are choosers; as a condition of taking office they swear to uphold the laws and programs that predecessors have set . . . new programs cannot be constructed on green field sites . . . they must be introduced into a policy environment dense with past commit- m e n t ~ . ~ ’

Past policies constrain agents as to both what can be transferred and what agents look for when engaging in policy transfer. In this way, Heclo demon- strates how past policy constraints influenced the approaches Britain and Sweden adopted when developing social policies during the twentieth century.68 Similarly, Robertson and Waltman show how existing policy commitments constrained transfer between the Reagan and Thatcher Administrations, despite the fact they shared ideological goals.69

65 R. Rose, ‘Comparative policy analysis: the program approach‘ in M. Dogan (ed.), Comparing

66 Rose, Lesson-drawing in Public Policy, pp. 132-4. 67 Rose, Lesson-drawing in Public Policy, p. 78.

69 Robertson and Waltman ‘The politics of policy borrowing’.

Pluralisz Democracies (Boulder CO, Westview, 1988), pp. 219-41, pp. 227-8.

Heclo, Modern Social Politics.

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As Wolman shows, the institutional and structural constraints faced by agents transferring policies are crucial. So, Wolman demonstrates how the United States’ federal structure acted as a constraint on the transfer of policies from the unitary British system, while the British system facilitated the Govern- ment’s ability to transfer policies from the United States.70

Policy transfer is also dependent upon the transferring political system possessing the political, bureaucratic and economic resources to implement the policy. Robertson suggests that both transfer, and the success of transfer, is more likely if the policy is consistent with the dominant political ideology in the ‘host’ c o ~ n t r y . ~ ’ Certainly, ideological similarities between countries can be a key factor when actors look for lessons.’* Examining the transfer of environ- mental policies between the United States and Canada, Hoberg found that one reason for the Canadian adoption of American environmental standards was the ‘value consensus’ which existed between the two nations.73 Similarly, Kelman explained the convergence of safety and health regulations in Sweden and the United States as a product of the ideological consensus between government officials.74

Rose emphasizes that the bureaucratic size and efficiency may influence transfer.75 Similarly, even desirable programmes will not be transferred if implementation is beyond a nation’s technological abilities. For example, developed nation’s emission standards generally require the installation of high technology monitoring equipment and filters which are beyond the techno- logical and monetary resources of most Second and Third World countries. Even developed countries might decide not to transfer policies because of the technological complexities involved. On several occasions Canada explicitly rejected particular American environmental protection policies because the technology used to implement them was too expensive and re~t r ic t ive .~~

Implementation costs money so economic resources are another critical constraint for agents engaged in policy transfer. In this way, Bennett demon- strated the importance economic constraints played in the transfer of data protection principles during the 1 9 7 0 ~ ’ ~

What are the Problems with the Literature?

(i) Is it a Dependent or an Independent Variable, or Both? Some authors, like Bennett, use policy transfer as an independent variable; the process of policy transfer is used to explain why a particular policy was adopted. In contrast, other authors, for example Rose, treat it as a dependent variable; attempting to explain why transfer occurs. Obviously, both concerns are legitimate, but the second seems to us more interesting.

70 Wolman, ‘Understanding cross-national policy transfers’, p. 40. ” Robertson, ‘Political conflict and lesson drawing’. 72 Rose, Lesson-drawing in Public Policy, p. 101. 73 Hoberg, ‘Sleeping with an elephant’, p. 126. 74 S. Kelman, Regulating America, Regulating Sweden: a Comparative Study of Occupational

Safety and Health (Cambridge MA, MIT Press, 1981). 75 Rose, Lesson-drawing in Public Policy, p. 129. 76 Hoberg, ‘Sleeping with an elephant’. l7 Bennett, Regulating Privacy.

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There is plenty of evidence that policy transfer occurs and is an important cause of policy innovation. However, we need much more work on how and why it happens; perhaps organised around the series of questions identified in this review.

(ii) Beyond Pluralism Policy transfer has been strongly associated with a pluralistic perspective on power and the policy process. Most authors discussing policy transfer believe that the process brings new actors and ideas into decision making, expanding the number of actors involved in the policy process. However, at best, this is one of two competing hypotheses. The pluralist origins of much of the literature are clear from: the overemphasis upon politics and, particularly, the role of politicians/bureaucrats and upon intentional, as distinct from structural, explanation; and the assumption that political actors are rational, calculating subjects.

If policy makers are looking to draw lessons from polities which are similar in institutional, economic and cultural makeup, it might be argued that, instead of expanding the number of ideas and actors involved in the decision-making process, policy transfer enhances the power of a relatively small circle of actors who consistently draw lessons from each other. So, if policy transfer occurs within relatively closed international policy communities, instead of introducing new ideas, lesson drawing simply reinforces the existing system, for the same ideas will be circulated amongst like-minded nations, thus maintaining the status quo. Of course, to a large extent this is an empirical question; we can analyse the extent to which policy transfer limits participation and underpins the existing order. However, policy transfer is underpinned by pluralist assumptions and the key question of whose interest is served by this process goes unasked.

Obviously, policy transfer involves strategic political judgements and, as we saw, the key actors involved in the process are politicians and bureaucrats. As such, the concept fits in well with the ‘statist’ developments in both pluralism and other state the~ries.’~ However, it is not possible to explain policy transfer solely in terms of the decisions of political actors. The strategic decisions of actors are taken in a context which is mostly not of their making and which is characterized by structured inequality.

Some of these constraints are national and political, resulting from a country’s own institutional structures and processes. Rose, like most analysts of policy transfer, plays down such constraints:

Even though institutions are necessary, it does not follow that they are important . . . A new program can usually be administered in more than one way; insofar as this is the case, one institution can be substituted for another.79

This conclusion is misguided. Indeed, the general trend in the wider comparative politics literature, especially in the New Institutionalism and state-centred approaches, is towards emphasizing the importance political

’* D. Marsh, ‘The convergence between theories of the state’ in D. Marsh and G. Stoker (eds),

l9 Rose, Lesson-drawing in Public Policy, p. 123. Theories and Methods in Polirical Science (Basingstoke, Macmillan, 1995).

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institutions play in shaping policy. Institutions structure the actions and values of actors working within them: ‘political institutions determine, order [and] modify individual motives . . . in terms of institutional interests’.*O Additionally, as March and Olsen point out: ‘expectations, preferences, experiences and interpretations of other actions are constructed within political institutions’.’’ More specifically, they also influence which actors search for lessons and where: ‘political behaviour [is] embodied in institutional structures of rules, norms, expectations, and traditions that [limit] free play of individual will and

There are other international constraints involving either international agencies or TNCs. Indeed, in some cases of coercive transfer actors have little or any autonomy of action. Certainly, a political leader in a Third World country has little alternative but to accept the policies imposed by the World Bank or the IMF, given that the consequences of refusal are deepening debt and economic and, probably, political crisis. Similarly, even in a developed country, a TNC may have sufficient economic power to influence Government policy in a way which is analogous to an international beauty contest; a TNC threatening not to invest in a given country unless policy concessions are made.’3 More generally, changes in the international economy, and in the location of a particular nation within it, constrain the autonomy of politicians and may push them towards the emulation of solutions which are favoured by international companies, financial institutions and, perhaps specifically, holders of the country’s currency or debt.

This is not to deny the role of individual actors in policy transfer; but neither should one deny the crucial role of political structures. However, pluralism tends to downplay structural and economic explanation and over-emphasize intentional and political explanation. This is a plea for a broader approach. We need to recognize that political actors operate within structural constraints. Some of the constraints derive from the political institutions within which actors operate, other are economic in origin based upon the structured inequality which characterizes societies.

Much of the literature on policy transfer also assumes that actors involved in transfer are rational and calculating. In this view, the process is driven by dissatisfaction. Policy makers act to to reduce the possibility of incurring electoral defeat. It is also assumed that decision makers evaluate the causes and the effects of problems. The key to policy transfer is thus prospective evalu- ation: ‘prospective evaluation starts by observing how a program operates in another country and develops a model of what is required to produce its effects

However, dissatisfaction is not the sole cause even of voluntary transfer. At the same time, policy making is not inevitably, or perhaps even usually, a rational process. Rather, it is often a messy process in which different policy, solution, and problem streams need to combine at the appropriate moment for

.I. March and J. P. Olsen, Rediscovering Instirurions (New York NY, Free, 1989), p. 3. March and Olsen, Rediscovering Institutions, p. 39. ’’ March and Olsen, Rediscovering Institutions, p. 5 .

83 D. Marsh, ‘The politics of private investment’ in A. Blais (ed.), Industrial Policy (Toronto,

84 Rose, Lesson-drawing in Public Poliq, p. 33. University of Toronto Press, 1985). pp. 83-1 17.

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a policy to develop.85 A few authors have begun to examine the process of policy transfer in the light of more sophisticated models of policy making.86 More work of this sort is clearly needed.

There are three macro-theoretical positions which, potentially, offer alterna- tives to pluralism, and within which it may be possible to interpret and explain policy transfer: new institutionalism; rational choice theory; and neo-Marxism. Each is dealt with in a longer version of this paper available from the authors. The key point here is that policy transfer is a meso-level concept which does not necessarily have to be integrated into a pluralist perspective.

(iii) Too Much Positivism Most policy transfer studies have an inadequate conceptualization of the role subjective perception and judgements play in the definition of problems and solution. Some authors pay lip service to the problem: ‘the definition of a satisfactory, or at least a “not unsatisfactory”, program is problematic. The aspirations against which achievements are judged are not given, but a social cons t r~c t ion’ .~~ However, few scholars look at how the definitions of problems or solutions are socially constructed. More importantly, they ignore the way that subjective definitions affects how and where searches are conducted and, also, what solutions are considered. Both Anderson88 and W01man~~ attempt to demonstrate the influence subjective perceptions have upon definitions of public problems but, again, much more work is needed.

Conclusion Policy transfer refers to the process by which actors borrow policies developed in one setting to develop programmes and policies within another. It is an important area to study because transfer is a common phenomena. We have suggested a series of questions which can be used both to organize our current knowledge of the process and to guide future work. However, it is crucial that the concept is developed beyond the pluralist perspective which has almost exclusively underpinned research in this area. We have suggested a number of alternative frameworks within which the process of policy transfer can be understood and explained. However, further consideration of these broader questions is essential if the literature is to progress beyond description.

85 See: M. Cohen, J. March and J. P. Olsen ‘A garbage can model of organizational choice’, Administrative Science Quarterly, 17 (1 972), 1-25; Kingdon, Agendas, Alternatives, and Public Policies (USA, Harper Collins, 1984).

86 See: G. Stoker and K. Mosberger, ‘The dynamics of cross-national policy borrowing’, paper presentd at the Urban Affairs Association Conference, 2-5 March (1994), New Orleans; J. L. Waltman and D. T. Studlar, Political Economy: Public Policies in The United States and Britain (Jackson MS, Jackson University Press, 1987); Robertson and Waltman, ‘The politics of policy borrowing’.

87 Rose, Lesson-drawing in Public Policy, p. 59 88 Anderson, ‘The logic of public problems’. 89 Wolrnan, ‘Cross-national comparisons of urban economic programs’.

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