PARADYS
Participation and the Dynamics of Social Positioning
Contract No. HPSE-CT2001-00050
Final Report to the European Commission
Alfons Bora and Heiko Hausendorf
Bielefeld and Bayreuth 30 July 2004
Prof. Dr. Alfons Bora Bielefeld University
Institute for Science and Technology Studies (IWT) PO Box 100131
D-33501 Bielefeld Germany
Mailto: bora@iwt.uni-bielefeld.de http://www.uni-bielefeld.de/iwt/bora http://www.uni-bielefeld.de/iwt/paradys
Prof. Dr. Heiko Hausendorf Universität Bayreuth
Lehrstuhl für Germanistische Linguistik
Sprach- und Literaturwissenschaftliche Fakultät Universitätsstraße 30
D-95440 Bayreuth Germany
Mailto: heiko.hausendorf@uni-bayreuth.de
http://www.uni-bayreuth.de/departments/gl/de/index.shtml
Content
The PARADYS Consortium ... 4
Foreword ... 5
Executive Summary ... 9
PART ONE – INTEGRATED CONSORTIUM REPORT ... 15
I Introduction ... 17
II Biotechnology Governance in the EU... 26
III Theoretical Foundations ... 42
IV Empirical Results: Social Positions, their Dynamics, and the Institutional Context.... 62
1. Methodology... 62
2. Data Description ... 70
3. Types of Social Positions – Synopsis ... 76
4. Dynamics of Social Positions ... 97
5. Social Context, Procedural Conditions, and their Relation to the Dynamics of Social Positioning ... 114
V Conclusions and Policy Recommendations ... 139
PART TWO – COUNTRY REPORTS... 155
VI Introduction ... 157
VII Italy... 160
VIII Hungary ... 246
IX Germany ... 307
X The Netherlands ... 357
XI Sweden ... 404
XII United Kingdom ... 454
XIII Ireland... 529
PART THREE – PARADYS DATA CORPUS ... 589
XIV Data Corpus, Description, Rules of Access... 590
References ... 595
The PARADYS Consortium
The following institutions and persons have been partners in the PARADYS consortium:
• Germany
Bielefeld University, Institute for Science and Technology Studies (IWT)
Co-ordinators:
Alfons Bora, Heiko Hausendorf Scientific Staff:
Gabriele Abels Ingrid Furchner Peter Münte Marc Mölders Irena Rathert Tatjana Zimenkova
• Hungary
University of Debrecen, Institute for Political Science and Sociology
Zoltán Berényi István Muranyi
University of Debrecen, Institute for German Language and Literature Studies
Zsuzsanna Ivanyi András Kertesz Kornélia Marinecz Nóra Máté
• The Netherlands
University of Twente, Centre for Studies of Science, Technology and Sciences
Femke Merkx
Barend van der Meulen Arie Rip
Wageningen University, Communication and Innovation Studies
Harrie Mazeland Hedwig Te Molder Henrike Padmos
• Ireland
University College Cork, Department of Sociology
Patrick O'Mahony Tracey Skillington Siobhan O'Sullivan
• Italy
University of Trieste, Faculty of Philosophy Elena Collavin
Marina Sbisa
Poster Srl., Vicenza;
Massimiano Bucchi Alessia Damonte Federico Neresini Giuseppe Pellegrini
• Sweden
Lund University, Department of Sociology of Law
Matthias Baier Håkan Hydén
Lund University, Department of Scandinavian Languages and the Department of the Cognitive Science
Jana Holsanova
Henrik Rahm (Responsible for the administration of the PARADYS project in Sweden since July 2002)
• United Kingdom
Lancaster University, Department of Linguistics and Modern English Language, and Institute for Environment, Philosophy and Public Policy Norman Fairclough
Sherilyn MacGregor Simon Pardoe
Bronislaw Szerszynski
Foreword
This report presents the results of the research consortium “PARADYS – Participation and the Dynamics of Social Positioning. The Case of Biotechnology. Images of Self and Others in Decision-Making Procedures”. The consortium has been working between 2001 and 2004, funded by the EU Commission under the contract no. HPSE-CT2001-00050.
The report is the outcome of an interdisciplinary co-operation between sociology and political science on the one hand, and socio-linguistics, particularly conversation analysis on the other.
The current paper displays the results of the studies that have been conducted in seven European countries, namely in Germany, Hungary, Ireland, Italy, The Netherlands, Sweden, and the United Kingdom. The report integrates these studies with the main goal of formulating policy recommendations for the European Commission.
At the centre of interest for the research project is the realisation of “citizenship” under different institutional (i.e. procedural) conditions. It is our hypothesis that the procedural conditions influence the structure and function of the notions of citizenship emerging in the communications of these procedures. The procedural conditions can be described as an aspect of governance.
The PARADYS approach is innovative, insofar as it merges socio-linguistic and sociological studies on the basis of a communication theory, which has its roots in sociological systems theory. Therefore, it represents a type of basic research, but with a distinctive problem orientation. A problem of the praxis, namely the difficulties of citizen participation, diminishing trust in expertise, and difficulties in decision-making, are treated in an inter- disciplinary research. Besides scientific results, policy recommendations are a main goal of the report.
The report has three parts:
Part One – the integrated consortium report – explains the empirical situation, discusses the theoretical and methodological foundations, gives an overview over data, displays the comparative results, and formulates policy recommendations from the perspective of the co- ordinators of the project. Part One has five chapters. A brief introduction is followed by a discussion of biotechnology governance in the EU, our practical-political starting point. The
third chapter clarifies the perspective of the integrative approach that is followed by the co- ordinators in their work. The core features of sociological systems theory, which is the background of the PARADYS concept, will be outlined here. The concept of citizenship is embedded in a sociological theory that is, in its nucleus, a communication theory of social systems. Chapter three also depicts the methodological basics, on which the consortium is based. Chapter four gives an overview of the empirical results by comparing different types of social positions being re-constructed by the research teams. It also describes different types of dynamics, which emerge in the empirical field between the positions mentioned before. These dynamics are finally being related to the political, legal, institutional, and cultural context of the respective country and to general contexts on European level. Chapter five formulates consequences and policy recommendations.
Part Two samples the country reports with paradigmatic analyses of the material, with a systematic overview over the findings in each respective country, and with policy recommendations based on the findings in each country.
Part Three describes the data corpus, which has been the result of our research, and which will be accessible for further scientific studies according to the rules formulated in the concluding section of this report.
The co-ordinators are responsible for the integrative consortium report and for the project as a whole. The responsibility for the country reports remains with the authors named at the beginning of the respective chapters.
A work, as it has been done in PARADYS, is the result of numerous individual contributions.
They altogether shape the product. While it is the reader’s task to assess the quality of this product, the coordinators nevertheless may express their conviction that all single contributions have been inestimably valuable. We have, indeed, been able to acquire innovative insight from the entirety of the PARADYS studies. Therefore, we hope that we have been able to represent this degree of innovation in our integrative report. We express our deep gratitude to the many colleagues, who have contributed to the project. It was a great pleasure to cooperate with all these research groups and to learn from them. Finally, we hope that our report authentically assembles all aspects that have been touched in the country studies.
Without being able to name every person who has cooperated, we nevertheless like to address and to highlight the coordination team. Tatjana Zimenkova as administrative coordinator and Angelika Lünstroth as financial officer at Bielefeld University have been coping with a simply tremendous workload and with nearly any kind of problem that one might imagine.
With a smile on their faces, they have managed to solve these problems in a way that most of the involved persons did not even realise the critical issue at stake. This kind of support is essential for any large research project and we sincerely thank both colleagues for their work.
We also like to thank especially the German team. Peter Münte, Ingrid Furchner, Gabriele Abels, Irena Rathert, Marc Mölders, and Astrid Epp have not only produced a wonderful country report. They also have been engaged in preparing all the PARADYS meetings and workshops, and in discussing many aspects of the project and of this final report with us.
Therefore, they have been much more than only a research team to us. They helped us in shaping and conducting the whole project.
All persons involved in PARADYS have experienced an enormous amount of work, especially in the last few months, when confronted with noticeable pressure from the coordinators. Nevertheless, an overall atmosphere of constructive cooperation characterised the relations within the consortium. This atmosphere is a necessary condition for the emergence of any scientific innovation. We do hope that the result of our work mirrors some aspects of this atmosphere.
Bielefeld and Bayreuth, 30 July 2004
Alfons Bora and Heiko Hausendorf
Executive Summary
The PARADYS report (Participation and the Dynamics of Social Positioning) presents the results of a study on citizen participation in the regulation of plant biotechnology in Europe, namely in the licensing procedure for genetically modified plants (GMOs). The research consortium has been funded by the European Commission between 2001 and 2004 (contract no. HPSE-CT2001-00050.) Focusing on citizen participation within legally framed administrative decision making procedures, the project contributes to the analysis of European governance practices. The social, political, and legal regulation of participation is a prominent issue to reflect upon concepts of governance and citizenship in the context of science and technology, which have intensely been discussed over the last decades in various political and social science studies.
It is this field of research concerned with law, legal regulations, and governance policies in the realm of administrative practise, the project brings in a socio-linguistic approach, that has been more or less neglected up to now or, at the utmost, played a minor role in recent studies on governance and citizenship. The term communicating citizenship characterises this approach. Focusing on citizen participation as communication, we suggest a concept that requires an empirical reconstruction of citizenship as a communicative achievement. With this rather analytical and non-normative approach, we try to develop a sociological completion to the more normative notions of governance and citizenship in the legal and political sciences.
The rationale of such a theoretical perspective is, in the end, to aim at a sociologically enlightened evaluation of normative expectations with regard to „adequate” and „legitimate”
forms of participatory governance.
We assume citizenship more and something different than an inevitable outcome of civil rights and entitlements the actors are supplied with. It should rather be viewed as empirically constituted within the interactions between government and citizens. Such interactions can be found in everyday contacts between the two sides, and especially in those forms, which provide for a certain amount of citizen participation. Citizenship then bears upon participation as social communication. What then comes into focus, are not only and not primarily the legal conditions and the administrative directions, but first the empirical ways by means of which these conditions and directions are manifested and communicated within the participation process itself. It is the communicative framing of procedural givens that counts: the concrete
forms in which given participation concepts are realised in communication processes, i.e. in which they are being communicated and thereby socially realised.
Citizenship is connected with the dynamics of social positioning between the participants. For the social position of a citizen is one of the participation concepts, administrative procedures provide for in order to guarantee their claim and pretension of citizen participation. The claim of citizen participation, indeed, promises a slot for participants acting as citizens to take part in the decision making process: As a social place, where citizens make their every-day experience with state organisations, administrative procedures provide an explicit frame with pre-structured – and in a strict sense: „legalised” – participation concepts for each of the participants. In case of face-to-face interaction, this pre-structuring even includes the regulation of presence that means: the definition of legitimate participants and legitimate participation concepts. Citizenship accordingly appears to be a procedural slot, which opens up the arena for the display of different participation concepts. The kind of citizenship we look for is therefore closely linked to its legal-administrative framing.
Pre-structured participation concepts trigger a social positioning process. The social positioning process is the medium by means of which “citizen participation” can be proved empirically. For citizenship appears to be one of those participation concepts. In this sense, citizenship comes into view as a sort of membership category, which is bound to the legal- administrative framing and its communicative realisation in terms of social positioning. This happens in terms of communicated images of self and others. Moreover, citizenship, i.e. what it means to be, to act, and to be treated as a citizen, must find an echo in these communicated images of self and others. Any approach towards communicated citizenship will accordingly be concerned with the dynamics of social positioning, the images of self and others and the social voices that come to be heard within these images.
Communicated images of self and others acting in the social position of participating citizens constitute citizenship as an interactive achievement, to use a term of conversation analysis, closely tied up to the various ways, participants account for themselves and others in terms of being and acting as citizens. In addition, what the few empirical studies suggest, that have already followed this direction, is that there are very different and often conflicting versions of citizenship within the social positioning process. Citizenship is accordingly a contested
concept and as such, it has to be grasped in theoretical, methodological, and empirical respects.
The communication of citizenship cannot be separated from the social arena in which it actually takes place. In a sense, the communication of citizenship already implies the communicative re-achievement of the procedural frame. And taking into account communicated citizenship as an outcome of a social positioning process accordingly means taking into account the form of decision making in terms of procedures for citizen participation. This methodological implication obviously meets an assumption that has concurrently been spelled out in many recent political and social science studies from different angles, namely that the choice of procedures for decision-making processes makes a difference, that, to cut it short, procedures matter.
The case of modern plant biotechnology has been chosen to substantiate the outlined analytical concerns. The legal regulation of biotechnological applications is a crucial test for both the chances and the boundaries of communicating citizenship. Methods and products of plant biotechnology have become a highly contested issue in the last decade and the recent history of European biotechnology regimes and policies gives much evidence that the regulation of citizen participation in administrative decision-making procedures constitutes an increasing European challenge concerning the improvement and standardisation of the different national practices. Accordingly, this empirical field appears to be a well-suited case to illustrate the communication of citizenship under the constraints of different procedural framings. This approach locates our research in the context of governance and citizenship.
The empirical studies in PARADYS resulted in mainly seven different types of social positions, which have been identified in most of the studies. For the purpose of quick identification they have been named as “The Administrator”, “The Local ‘We’”, “The Concerned or Critical Citizen”, “The Organised Protestor”, The “Scientist”, “The Politician”, and “The Industrial Actor”. These positions have been re-constructed in their structural dimensions, which are their communicated images of self and others with respect to relevant actors, valid forms of communication, problem focus, and main system reference. In these respects, the ideal types can be described as being clearly distinct against each other on an analytical level. In a second step, the dynamics between these positions have been reconstructed. In our empirical field, four forms of dynamic could be found, along the two
dimensions of 1. direct or indirect relation with procedure, and 2. multi- or single-speaker.
Two types of social dynamics have occurred between social positions, one of them offering the option for mutual inclusion of the positions (inclusive dynamics), the other being exclusive in this respect (exclusive dynamics). The dominant type is closely linked with the procedural framing. This dynamic can be described as producing conflicts in the field, insofar as it fosters the exclusion of most of the citizen positions (exclusive dynamics). A similar result could be found on the second dimension for the multi-speaker dynamics. In both cases, close relation with procedure and multi-speaker dynamics, the relation of the inclusion or exclusion of particular positions can be connected with communicative slots, which are opened by the structures of the procedural framework. It is the close link with legal- administrative rationality that promotes a certain kind of dynamics. According to this legal- procedural framework, a certain type of communication (the one of the “Scientist” and the
“Administrator” position, to some extent also the “Industrial Actor” and in some cases the
“Organised Protestor”) is selected against all other forms. What from the legal-procedural perspective (and therefore also in the communicative structure of the “Administrator”
position) will necessarily be interpreted as rational and inevitable, namely the exclusion of all structurally “mismatching” communications, will be interpreted as the execution of illegitimate or poorly justified political power.
Under these conditions, citizenship as it was found as empirically communicated in our data has to be described as an essentially contested concept. With this term we describe the fact that there are no “connecting” or “translating” links between structurally divergent concepts in different social positions. The empirical data in particular show a structural tension between institutionally, i.e. legally framed and procedurally communicated forms of citizenship. No inclusive dynamics could be reconstructed within the procedure between those positions, which entail the mutually contested concepts of citizenship. Exclusive relations are caused by the competing rationalities of some positions on the one hand and of the legal- procedural framework on the other. Inclusive dynamics might be possible under the condition of another participatory arrangement, especially one with loose or only indirect coupling with the legal-procedural framework.
The fundamental problem of legal-procedural decision-making is that the interpretative conflict between contested concepts cannot be treated sufficiently within the procedure, due to the legal-procedural framework. Dynamics are an effect of the procedural framework. This
framework provides clear slots for administrator, scientist, and – depending on the case – for industrial actor positions. On this background, the administrator position usually defines further slots for the inclusion of other positions. These slots are in many cases very broad and vague. The effect is that a variety of positions from the citizen side arise within the procedure.
These positions have been “invited” by the administrator, but with respect to their communicative structure they do not fit into the legal-procedural framework. In other words, there is a constitutive tension on the level of legal communication between the framing of an administrator position on the one hand and a very limited concept of valid contribution from the citizen positions on the other. This narrow concept is rather convincing with respect to the legal rationality of decision-making. It is not very convincing with respect to the political rationality of a political public on the other, given that this public does not want to leave critical decisions to the elected institutions alone.
Another main problem of the current procedure is the lack of relevant information. Relevant means information, which would be given in the language of the respective positions. In order to raise resonance between the positions, it would for instance be necessary to provide information about the procedure in the language of the local ‘We’. It would be necessary to show, in how far the relevant topics of this position could at all be treated in the procedure.
The impossibility of a local decision in the context of the given procedure would have to be demonstrated clearly, for instance.
Differences between countries in the PARADYS study indicate that it might be advisable to think about early information and a radical change in publicity concepts in most countries.
Further hints may be taken from the differences in the political-institutional context. In some countries, we observe a tendency to include concerned and organised citizen positions in dynamics that evolve in a more indirect relation to the procedure. Besides these differences, the situation in all countries is coined by a political-institutional context, which locates citizen participation regularly in the frame of a formal procedure. At the same time, the public debate is vivid and controversial. It is aiming at political decision-making and at more general issues of collective interest. Therefore, all over the data we find evidence for the suggestion that in situations, where the chains of the legal communication are looser, where the culture is more inclined to public debate, we will find more signs of inclusive dynamics than in the current
“standard” situation. Public debates are closer to legislation and to the parliamentary process
than administrative decision-making. It might therefore be advisable to think about chances of transferring participatory elements from the executive (administration) to the legislation.
Our study has lead to a certain hesitation about the precise function of citizen participation in administrative procedure. The national as well as the international policy documents remain very open in this respect. When it comes to their application, some of the general political reasons for participation partially lose their validity with respect to the particular context of administration. The exclusive dynamics between administrator and most of the citizen positions clearly show that a certain kind of political/democratic discourse does not find any resonance in the legal-procedural context. On the other hand, the administrator position opens slots for very formal and legal communications from the citizens’ side. It thereby manifests the fact that not every justification for citizen participation is applicable to the procedural context. Democratic legitimation remains external to the procedure. What is possible within this context is a form of justification with reference to rights and duties. Our empirical study gives reason to adjust normative legitimations to the empirical reality.
PART ONE – INTEGRATED CONSORTIUM REPORT
I Introduction
The following remarks are intended to introduce to our field of research, the conceptual framework, and some central assumptions. They shall set the frame for the subsequent chapters II and III, in which the political context and the theoretical foundations are discussed in detail.1
Communicating citizenship in administrative decision making procedures – the basic idea
This report presents the results of a study on citizen participation in the regulation of plant biotechnology in Europe, namely in the licensing procedure for genetically modified plants (GMOs). It assembles the work of a research consortium (PARADYS – Participation and the Dynamics of Social Positioning), which has been funded by the European Commission between 2001 and 2004. Focusing on citizen participation within legally framed administrative decision making procedures, the project wants to contribute to the analysis of European governance practices. The social, political, and legal regulation of participation is considered a prominent issue to reflect upon concepts of governance and citizenship in the context of science and technology, which have intensely been discussed over the last decades in various political and social science studies.
It is this field of research concerned with law, legal regulations, and governance policies in the realm of administrative practise, the project brings in a socio-linguistic approach, that has been more or less neglected up to now or, at the utmost, played a minor role in recent studies on governance and citizenship. The notion of communicating citizenship shall stand for this approach. Focusing on citizen participation as communication, we are proposing a concept that allows for and at the same time requires an empirical reconstruction of citizenship understood as a communicative achievement. With this rather analytical and non-normative approach, we try to develop a sociological completion to the more normative notions of governance and citizenship in the legal and political sciences. The rationale of such a theoretical perspective is, in the end, to aim at a sociologically enlightened evaluation of
1 The introduction also has the function of guiding the way through the text. The reader might, due to his or her priorities, after the introductory remarks go directly to the more political-practical (chapt. II) aspects or to the more theoretical parts (chapt. III), and after that to the empirical findings (IV) or directly to policy recommendations (V.)
normative expectations with regard to „adequate” and „legitimate” forms of participatory governance.
We, therefore, assume citizenship more and something different than an inevitable outcome of civil rights and entitlements the actors are supplied with. It should rather be viewed as empirically constituted within the interactions between government and citizens. Such interactions can be found in everyday contacts between the two sides, and especially in those forms, which provide for a certain amount of citizen participation. Citizenship then bears upon participation as social communication. What then comes into focus, are not only and not primarily the legal conditions and the administrative directions, but first the empirical ways by means of which these conditions and directions are manifested and communicated within the participation process itself. It is the communicative framing of procedural givens that counts: the concrete forms in which given participation concepts are realised in communication processes, i.e. in which they are being indicated, presented, filled out, negotiated, changed, or in one word: communicated and thereby socially realised. This is what the notion of “communicating citizenship” stands for.
The idea of communicated citizenship drives us to shift from a normative into an analytical concept of citizenship, which is open to empirical validation. As long as citizenship will be discussed as a primarily normative idea depending on concepts of „good” governance, it remains an inanimate husk external to what is perceived as an important social position by the actors themselves, whereas the latter promptly appears when we focus on the participation process. Citizenship then is connected with the dynamics of social positioning between the participants. For the social position of a citizen is one of the participation concepts, administrative procedures provide for in order to guarantee their claim and pretension of citizen participation. The claim of citizen participation, indeed, promises a slot for participants acting as citizens to take part in the decision making process: As a social place, where citizens make their every-day experience with state organisations, administrative procedures provide an explicit frame with pre-structured – and in a strict sense: „legalised” – participation concepts for each of the participants. One might even argue that it is the very sense of such procedures to define exactly the different participation concepts for those who will be engaged. In case of face-to-face interaction, this pre-structuring even includes the regulation of presence that means: the definition of legitimate participants, so to speak, and legitimate participation concepts. Citizenship accordingly appears to be a procedural slot, which opens
up the arena for the display of different participation concepts. The kind of citizenship we look for is therefore closely linked to its legal-administrative framing.
Due to the procedural framing, the starting communication process appears to be an attempt to establish and to keep alive different and even conflicting participation concepts.
Communication during the participation process, to put the same point differently, busies itself with the realisation, re-creation, modification of pre-structured participation concepts and with the very struggle for these concepts in terms of different social discourses, or – as we like to put it in our context – of different social positions. In this sense, pre-structured participation concepts indeed trigger a social positioning process. Accordingly, the social positioning process within administrative procedures is highly expectable and is directly rooted in the research subject itself. It is not an invention of interested sociologist or linguists but a very important feature of the social encounters themselves.
This is why the social positioning process makes the empirical core of participatory discourse.
It is the medium by means of which “citizen participation” can be proved empirically. For citizenship appears to be one of those participation concepts. In this sense, citizenship comes into view as a sort of membership category, which is bound to the legal-administrative framing and its communicative realisation in terms of social positioning.
Following this direction, we are led to the many ways in which the participants make clear their understanding of the procedure and their own contribution and those of the others. This happens in terms of communicated images of self and others. Moreover, citizenship, i.e. what it means to be, to act, and to be treated as a citizen, must find an echo in these communicated images of self and others - unless it remains an unanimated formal husk. Any approach towards communicated citizenship will accordingly be concerned with the dynamics of social positioning, the images of self and others and the social voices that come to be heard within these images.
Communicated images of self and others acting in the social position of participating citizens constitute citizenship as an interactive achievement, to use a term of conversation analysis, closely tied up to the various ways, participants account for themselves and others in terms of being and acting as citizens. In addition, what the few empirical studies suggest, that have already followed this direction, is that there are very different and often conflicting versions
of citizenship within the social positioning process.2 Citizenship is accordingly a contested concept and as such, it has to be grasped in theoretical, methodological, and empirical respects.
Tracing back citizenship to its communicative roots, so to speak, the procedural shaping of the decision making process becomes an important issue. Because the communication of citizenship cannot be separated from the social arena in which it actually takes place. In a sense, the communication of citizenship already implies the communicative re-achievement of the procedural frame. And taking into account communicated citizenship as an outcome of a social positioning process accordingly means taking into account the form of decision making in terms of procedures for citizen participation. This methodological implication obviously meets an assumption that has concurrently been spelled out in many recent political and social science studies from different angles, namely that the choice of procedures for decision- making processes makes a difference, that, to cut it short, procedures matter.
The case of modern plant biotechnology has been chosen to substantiate the outlined analytical concerns. The legal regulation of biotechnological applications is indeed a crucial test for both the chances and the boundaries of communicating citizenship. Methods and products of plant biotechnology have become a highly contested issue in the last decade and the recent history of European biotechnology regimes and policies gives much evidence that the regulation of citizen participation in administrative decision-making procedures constitutes an increasing European challenge concerning the improvement and standardisation of the different national practices. Accordingly, this empirical field appears to be a markedly well-suited case to illustrate the communication of citizenship under the constraints of different procedural framings. This approach locates our research in the context of governance and citizenship.
Governance and Citizenship: The role of participation at scientific and technological crossroads
The concept of governance, originally deriving from economic analysis, namely the control over corporations, but in the meantime re-defined through a longer debate in political science,
2 See, for instance, the different participatory discourses empirically observed in Bora 1999a.
is frequently associated with questions of different international regimes and of global order (cf. for example Held 1995, Kohler-Koch/Eising 1998, Zürn 1998).3 It is usually understood as a means of political, legal, and social regulation beyond markets and hierarchies (Amin (ed.) 1997). Since the late 1990ies, the World Bank has made use of the concept, commonly describing governance as the exercise of political power to manage a nation’s affairs. For our purpose, mainly the aspect of public governance is relevant. It means the coordination of new forms of social cooperation, i.e. more horizontal activities between state institutions, non- governmental organisations, private enterprises, and individual actors. In this perspective, public governance covers aspects of the state, the market, and the civil society. In contrast to previous lines of regulatory theory (government theory), the use of the term governance indicates that new forms of – non-hierarchical, de-central, co-operative, “enabling” – regulation replace older models of central regulation. We will reflect upon this point in our theoretical considerations, taking up the systems theoretical model of a multi-referential and a-centric society.
The governance concept, as Christian Joerges writes with respect to the EU white paper on governance, “refers to both activities and actor configurations. ‘ Governance’ is to be equated neither with the actions of governments and administrations, nor with law-making activities, nor the law implementing activities of authorities and courts. It is all this, ‘too’. But it is a specific feature of modern regulatory policy that it builds, to a large degree, on knowledge available not within the administrative machinery but in society, which it is likewise dependent upon the management capacities of enterprises and non-governmental organisations. Regulatory policy can neither be reduced to the execution of the will of the sovereign by that sovereign's administrative bodies, nor can it be delegated ab ovo and in toto to non-governmental actors. The complexity of modern governance structures is a response to the problem situations of society and of the political systems … Accordingly, official and technical authorities must engage in new linkages; governance structures in which both private actors and ‘civil society’ participate in the ‘carrying out of public tasks’ have to emerge. ‘Governance’, instead of government and administration: this is the outcome - but also the problem.” (Joerges 2001) Taking this position, our question then is, how these new linkages between technical/administrative authorities and civil society work in the case of
3 The discussion about governance is characterised by a wide variety of differing, partially contradicting concepts, see for a short overview Kooiman 2002; Rosenau 1995.
biotechnology. We therefore ask for the social relations between representatives of the civil society and the administration.
In the following, we would like to make use of this concept of public governance that is closely related to the new type of regulatory regimes, which can be observed in many policy areas. Being an analytical instrument for the analysis of newer developments in international politics, public governance is closely connected with examples of environmental and risk policies. This connection also includes questions of technology, especially new and potentially hazardous technology and its regulation on local, national, and transnational levels. For questions of environment, technology, and risk in modern society are typically transboundary questions. They constitute new fields of regulation, where the classical interventionist policy instruments are merely applicable. This holds true not only for the regulation of air and water, but also for the transnational question of biological safety, for instance.
On this background and in the context of political and legal regulation we would propose to understand public governance as a co-operative social relation between governmental institutions and actors of the “civil society”. Dealing with the participatory dimension of governance, we are primarily interested in the role of the citizens in public governance. We do not want to say, that this relationship is entirely new or that sociological and political theory before the governance-debate did not reflect on these issues. Rather we would like to interpret the theoretical interest in governance as an expression of shifting focus and emphasis in theoretical and practical respect.
The political discussion during the beginning modernity was dominated by the questions, what good government is, what the fundaments of good government are, and how the state shall be governed. In these early times during the Renaissance age the answer very roughly speaking was, that good government means security for all members of the society (citizens) and that good government is based upon certain properties of the governors and the community, such as Peace, Power, Prudence, Magnanimity, Temperance, and Justice.4 Obviously, this is a more or less ontological concept of government, which tries to formulate substantial properties of „good government”. We all know that such concepts have been dissolved – or deconstructed – in the post-metaphysical discourse of the last centuries. Major
4 cf. for instance Lorenzettis famous fresco „Buon Governo” of 1338 in the Palazzo Pubblicco in Siena.
changes in the concept of government can be observed in this process of dissolution. Maybe the most important shift can be seen in the growing importance of citizenship, which has been dominating the discussion since the early 18th century. As will be pointed out more in detail in chapter III, in the beginning modernity, citizenship is mainly an expression of a certain estate – and it is closely related to the cities and their inhabitants, their position as craftsmen and members of the respective guilds, for instance. Later – after enlightenment and the great revolutions – citizenship has got more and other meanings, namely the guarantee of legal, civil, social rights and entitlements. That means that the relationship between government and citizens has been changing significantly. In many respects, these basic shifts and changes are being reflected terminologically with the notion of governance. Thus, governance and citizenship are closely linked. In modern society, citizenship mainly stands for two aspects:
Membership (sociologically speaking: inclusion) in a wider, namely in a national context:
Citizenship does not regulate inclusion into the society as a whole, but inclusion into the political system, traditionally by means of law (nationality, maleness, age, property ownership as preconditions for political voice – as, for instance, in the Athenian model), but in the meantime also by means of economy, culture, and education. These means of inclusion can be understood within the framework of a more general sociological theory, namely as different answers to a question or task: in how far do persons become relevant in communication systems? Because of this discussion, we will define Citizenship as a mode of social inclusion into the political system (see chapter III for details). It is a communicative, semantic concept, which gives a specific answer to the structural question of how persons become relevant in social systems. When inclusion is the function of citizenship, we can see that a number of different (but functionally equivalent) forms could fulfil this function. Nationality (be it in the form of ius sanguinis, be it in that of ius soli; Holz 2000) is another mode of inclusion into the political system, as well as electorate, for example.
Social position: to be a citizen means more than being a member of a nationality; it means to have rights, rights of information, rights to participation, voice, standing for example, that is rights to being treated in a certain way.5 It is this theoretical interest for a certain kind of relation between citizens and government, that is being expressed in the concept of governance and that we take as the conceptual heart of our approach.
5 This twofold notion of citizenship is theoretically connected to a gradual concept of inclusion; see Bora 2002.
With this concept of governance as relationship, we want to mark the shifting emphasis in regulatory forms of modern society, which can briefly be described as shifts (1) from a more institutional way of regulation towards a more procedural and (2) from more hierarchical forms of communicating towards more heterarchical. We will come back to these – ideal- typical – distinctions in the following chapters. For the moment, they are only meant to serve as additional indicators for what we will treat as the central aspects of governance and citizenship in our approach.
Governance in this sense has an aspect, which refers directly to questions of civil society and democracy (Hirst 1994, Zürn 1998, Brunkhorst/Kettner 2000, Vandenberg 2000, Edeling/Jann/Wagner 2001, Grote/Gbikpi 2001). The above mentioned new, transnational problems of environmental, risk and technology policies show that governance on this transnational level is closely connected with and depends on the building of a transnational legal culture, the emergence of a transnational rule of law, and within this framework a transnational culture of co-operative, democratic decision-making. These components could be seen as the basis of a transnational regime. That does not mean, that a uniform culture is to be expected or should be intended. It rather means, that a multilateral and mutually responsive, complementary and differentiated set of national, regional, and local forms of governance is needed in order to form a successful transnational, European governance order (Brock 1997).
Once again, the latter argument shows the connection between governance and citizenship.
This is because the achievements on the level of governance mentioned above are strongly depending on complementary achievements on the level of civil society in general and especially of citizenship. The concept of citizenship is the result of a debate reaching far back in the social sciences (cf. chapter III.) In the second half of the last decade many authors realised, that the development and shaping of new technology is in its nucleus a question of democratic policy and therefore of citizenship (Sclove 1995; Saretzki 2000). This topic has mostly been discussed under the title of „technological citizenship“. The concept has a number of theoretical roots: basing on Barber‘s “Strong Democracy” (Barber 1984) and on Marshall’s differentiation between the civil, political, and social dimensions of citizenship (Marshall 1950), the scope of dimensions was enlarged by the concept of “cultural citizenship” (Turner 1994). Various arguments are also advocated in favour of the idea of
“ecological” or “environmental” citizenship (Steenbergen 1994; Newby 1996;
Rondinelli/Berry 2000; Hawthorne/Alabaster 1999; Mehta 1998). In sociological theory a number of arguments has been exchanged with regard to this topic under the label of “social inclusion/exclusion” (Brubaker 1992; Holz 2000; Holz 2001; Bora 2002).
Although the scientific discussion of the concept of „technological citizenship“ has been provoking a number of serious critiques (see, for example, Saretzki 2000), the discussion about governance and citizenship at least brought about two points, which will guide our further analysis: 1. It shows, that in the regulation of (especially new, and perhaps risky) technology, questions of governance and citizenship are closely linked together. 2. It shows that governance will always be complementary to a certain form of citizenship, a form that includes rights to participation, information, and informed consent – with the interesting question still being open: which forms of procedure and which forms of participation will best be suited to realise this kind of citizenship? This question on a theoretical level leads to the discussion of different theories of participation. Before we turn our attention to these theories, we will in the second chapter now sketch the European debate on Biotechnology Governance in order to show, how citizenship, governance, and participation are linked together by the issue of biotechnology on the European level and what the practical-political issues are that arise from the political struggle about biotechnology governance in the EU.
II Biotechnology Governance in the EU
Biotechnology regime – History and controversy
It is no exaggeration to claim that biotechnology is the most crucial issue in the contemporary public debate on questions of risk, technology, ethics, health, and environment. The recent development in this debate has brought up a rather contra-intuitive effect, at least at the first glance. Whereas many applications in human genetics seem to be widely accepted by the consumers and the general public – even after extensive debates on stem cell research in several partner countries –, methods and products of plant biotechnology have become a highly contested issue in the last few years (Durant/Bauer/Gaskell 1998, Hampel/Renn (eds.) 1999, Urban/Pfenning 1999, Gaskell/Bauer 2001). But if one looks a bit closer at the controversy about biotechnology, this outcome corresponds very much with the development, which the overall debate has taken during the last decades.
In the seventies and early eighties – after the 1975 Asilomar conference – scientific and regulatory debates strongly concentrated on questions of containment and good industrial large-scale practice (Cantley 1995: 511.) Human genetic and plant biotechnological applications were not very sharply separated in many cases, because research activities were mainly dealing with basic problems. Beginning in the middle of the eighties – and mainly because of the growing number of applications for the new technologies – the so-called green biotechnology began its career as a branch of its own. A steadily increasing number of field experiments provoked two effects: firstly, the growing relevance of ecological aspects in the biotechnology debate, and, secondly national and international efforts to achieve regulatory solutions for the new technology. These efforts concentrated under the topic of “biosafety“. A whole series of international symposia was held under the title “The Biosafety Results of Field Tests of Genetically Modified Plants and Micro-organisms“ (see, for example, Fairbairn/Scoles/McHughen 2000) in which the scientific results were brought together in order to advise regulatory authorities. National competent authorities were involved in this widespread debate, but also the European Commission 1983 and 1984 (European Commission 1983; 1984), the OECD 1986, 1992, and 1994 (OECD 1986, 1992, 1994) and many other international organisations took part in it. On the EU level, two directives have been enacted, 90/219 EEC (Contained Use) and 90/220 EEC, now 2001/18 EC (Deliberate Release). The latter is relevant for field trials, because it gives the procedural rules for
deliberate releases of genetically modified organisms. It has to be applied according to Article 95 (Ex-Article 100a) EC-Treaty, which means, that national provisions going beyond the regulation of the directive are not in accordance with community law. Based on this directive, the member countries have regulated their permitting procedures in the different forms we mentioned above. Since 1990, there have been more than 2000 cases of deliberate release in the EU countries. Public controversies about these field trials have for a long time been concentrating on the German speaking countries. Since the last few years, they have also spread over the rest of Europe (Hampel 2000, Gaskell/Bauer 2001, Torgersen et al. 2002);
especially in the UK remarkable public protest can be observed against all kinds of agricultural applications of biotechnology. – The question is, how this controversy is influenced by the citizens‘ right to participate in administrative permitting procedures in different legal contexts. The biotechnology debate, in other words, leads directly to central issues of scientific and technological citizenship and of democratising expertise, an issue, which is in the centre of European policy making efforts (EU-Commission 2000 and 2001;
see for an extended presentation of this argument Abels 2002). Biotechnology in agriculture, a key technology for the 21st century with the potential for sustainable development – or a key problem of risk society, which tends to run out of control? These are the outstanding positions of the contemporary struggle about plant biotechnology. And they show that it will depend on the social regulation of the technique, whether or not this struggle will lead to a viable regime for biotechnology, on national as well as on European level.
The General “Participatory Turn” in the EU
Biotechnology and its legal and political regulation has been a central issue to national and EU policy-making for the last decade. Public opinion has in all countries been aware of the questions connected to biotechnology, as well as to medical applications. Eurobarometer 52.1 on “The Europeans and biotechnology”, the fourth survey in a series that cover biotechnology since the 1990s, shows a high acceptance of medical biotechnology, while there is a far greater and, over time, even growing scepticism against “green” (agricultural) biotechnology in the late 1990s (cf. Durant et al., 1998; Gaskell/Bauer, 2001; for an overview and comment see Bora 2000). The member states and the EU have to consider these issues with regard to their regulatory policy.
The regulation of biotechnology has to focus on at least three dimensions, which can be described as follows (Abels 2002). In the cognitive dimension regulation has to be confronted with the fact that the lack of knowledge – rather than the mobilisation of new knowledge – is a basic component of risk policy and that this cognitive dimension requires new modes in the management of knowledge as well as a higher reflexivity of regulatory law and practices (cf.
Bora, 2002). In the interest dimension, “Policy-makers have to balance these opposing interests and have to keep the common good in mind. They must develop policies which satisfy social needs and do not lead to permanent social conflicts” (Abels 2002, 2). Finally, in the normative dimension, dissent over fundamental normative issues would regularly be brought up by social debates about GMOs and similar critical issues. Regulation is confronted with the observation, that legal instruments cannot answer cognitive questions of risks and that scientific advice cannot provide answer to the normative dimension (Abels 2002, ibid.) In this situation, as Gabriele Abels notes, a certain shift in the European biotechnology regime can be observed, starting in the area of biomedicine and stretching to other fields such as GMOs and food regulation. It may be characterised as a shift from an expertise model to a more participation-oriented model in decision-making processes. The EC is opening up for incorporating ethical concerns into its research, technology and development policy as well as its regulatory biopolicies, as Abels says.
This shift in biotechnology policies – as slight as is might be – is being framed by a general re-orientation in EU policy-making. At the end of the last decade, an extended discussion about what has since been called the “democratic deficit” of the EU has spread through scientific and political debates (Scharpf 1999). In the working document on "Science, society and the citizen in Europe" (SEC (2000) 1973; see also European Commission, 2001, Science and Society. Action Plan, COM (2001) 714 final) the Commission has clearly pointed out the relevance of participatory procedures of risk assessment and the need for new forms of dialogue between science and society. This position corresponds with the one laid down in the white paper on European governance "Enhancing democracy in the European Union" (SEC (2000) 1547/7 final and European Commission, 2001a, European Governance. A White Paper, COM (2001) 428 final), where a close connection between institutional and democratic challenges has been pointed out. It is these umbrella documents which express the notion of a democratic deficit in the EU and which show that the problem has been taken into consideration from the side of the European Commission in the meantime.
According to Abels, one of the most striking features of these policy papers is their
“participatory” speech: “They emphasise the need for input legitimacy and take this as a means for strengthening output legitimacy. They are all concerned with new institutional and procedural mechanisms for more ‘participation’ by creating a public sphere and including stakeholders, the general public and citizens in Community policy-making. Science and technology – in particular, biotechnology – assume a prominent place; it is in this context that the Commission speaks of the need for a ‘new societal contract’.” (Abels 2002, 10.) This new line in Technology Governance has been followed in all relevant papers since then.
Especially, the policy paper on science and society (European Commission, 2000) speaks about the need for a “new partnership” by promoting open dialogue between researchers, industrialists, policymakers, interest groups, and the public. Against an older, more trivial model of technological innovation from scientific invention to useful application, technological innovations are now been viewed at much more in the way of the so-called
“mode 2”-hypothesis in Science and Technology Studies, namely as outcomes of social networks that incorporate a wide range of social actors, including users. Under such presuppositions, the conclusion is obvious that citizens should be involved in decision-making processes, in order to “bring science policy closer to the citizens” (cf. Abels 2002, 12.)
This shift in European policies has been criticized by a number of scholars for being merely rhetorical, for being tokenism, or for at least covering the basic problem of public protest (Abels 2002). We do not want to challenge these critiques. However, even the EU documents show the close interrelation between risk issues, technological citizenship, and participation that is central also to our empirical argument with respect to biotechnology. We will now address the question, which theories of participation could give support to the political developments just mentioned before from a scientific point of view. Do we have arguments to suppose that “more” or “better” participation would indeed have positive effects on the problem of social integration that lies behind the formula of the “democratic deficit”? And with which theoretical concepts could we study this question empirically?
The scientific debate about the regulation of green biotechnology
The development of the public debate on green biotechnology shows not only the growing relevance of regulatory issues; it also visualises a certain shift in the contents of the debate
itself. Increasingly, the public concern is dealing with the problem, how society wants to live in the future. This is not merely a question of biosafety, risk, and environmental aspects, but rather a normative question (O’Mahony (ed.) 1999, van den Daele et al. 1996, van den Daele 1999, Levidow/Marris 2001). Very closely intertwined with the controversy about genetically modified plants and microorganisms, about the methods of agriculture and food production, about “natural“ and “artificial“ ways of living, are definitions of social and cultural identities.
The struggle about the new technology sharply demarcates competing conceptions of “good life“ (cf. Gill 2003.) And these conceptions are being expressed as images of self and others.
The way in which biotechnology is perceived, in which it is set into social and cultural contexts, in which it is framed in the debate is an expression of the way of perceiving oneself and others in the context of communication itself. These perspectives are being constructed and realised in the process of communication.
Licensing procedures on deliberate release of genetically modified organisms and their social contexts are prominent social arenas, where such processes of social positioning are to be expected. To a remarkable extent, also the general public debate – especially promoted by social movements with the support of mass media – and different intermediary arenas – such as participatory technology assessment procedures, consensus conferences and similar forms – does influence the dynamics of social positioning. Nevertheless, we would like to concentrate on the fact, that for questions of governance and citizenship first the administrative procedures and their legal framework are prominent factors. They are the most direct form, in which citizenship can be realised and can be made tangible for the participants.
They provide for direct, every-day contact between competent authorities, interested parties, and the concerned public. They are, at last, designed to be the gateways, through which the demands for rationality from the periphery of the Lebenswelt are expected to be smuggled into the centre of the legal-political system – to use Habermas‘ words.
The regulation of biotechnology on the level of participatory procedures is a field, which has not been studied very thoroughly by social scientists until now. A number of studies have been published which focus on different aspects of the regulation of biotechnology and of risk policy (e.g. Gibbs/Cooper/Mackler 1987, Gill 1991, Wheale/MacNally 1993, Stemerding/Jelsma 1995, Dolata 1996, Martinsen (ed.) 1997, Gottweis 1998, O’Mahony (ed.) 1999, Bora 1999, Patterson 2000). Also well described is the public acceptance of genetic engineering (Levidow/Carr 2000), as well as the realm of risk sociology, technology
assessment and general questions of risk regulation (e.g. Schenek 1995, Köck 1996, Hasse 1997, Gill/Bizer/Roller 1998, Bora (ed.) 1999, Bora/Epp 2000, Kapteina 2000, Hood/Rothstein/Baldwin 2001). Contributions to biotechnology regimes on transnational and international level are mostly policy-oriented and are concentrating on negotiation processes and questions of arguing and bargaining as well as on competition between innovation systems (Heins 1996, Barben 1997 and 1998, Braun 1998, Barben/Abels (eds.) 2000, Barben/Behrens 2000, Giesecke 2000, Behrens 2001). So after all, many relevant fields of biotechnology are covered by research in the social sciences, but there is no activity at all regarding comparative research on participatory communication in legally constituted administrative procedures – in spite of a rich tradition of European research in general citizen participation (Joss/Durant 1995, Joss 1999, Abels/Bora 2004, Joss/Bütschi 2002). Our report intends to throw light on this field of communicating citizenship in the struggle about the licensing of plant GMOs.
Citizen Participation in Licensing Procedures on Genetically Modified Organisms
Licensing procedures on GMOs (genetically modified organisms) are characterised by different forms of legal framing. In the following, we will draw our attention to procedures in different European countries, their distinctive regulations and their common properties, in order to exemplify the variety of forms as well as their common structures. Taking into consideration citizen participation in administrative processes, different forms of procedure can be observed in European countries. With respect to our empirical domain, permitting procedures in the field of plant biotechnology, the following can be said:
Until about 1999, the legal situation widely varied between EU countries (cf. Jülich 1998). In some of them, an oral form of direct citizen participation (public hearing for instance) had been implemented, so in Austria, Luxembourg, Germany before 1994, and the Netherlands. In a larger group of countries, legal regulation would provide for a written participation; this held true for Germany (since 1994), the United Kingdom, France, Belgium, Spain, as well as for the applicant countries Poland and Hungary. In some countries the legal framework for permitting procedures had been constructed completely or almost completely without any direct involvement of the public in general, for instance in Italy, Ireland, or Portugal. A fourth model of regulation could be characterised by a very far reaching right of information for
everybody, underlying the whole permitting procedure, irrespective of the concrete form of the right to participate in the decision-making; this is the case especially in Sweden and Denmark. Switzerland and Norway as non-member states would show similar regulations.
Furthermore, the ten countries, e.g. Hungary, that have entered the EU in May 2004 had to transfer European law – including the deliberate release directive – into national law prior to accession.
As has been said before, this was the situation until the end nineties. Meanwhile a great part of harmonisation has taken place in Europe and the situation has more or less been developing into the direction of the mainstream model of written participation. An overview over the situation in a number of countries, which represent the above-mentioned types of regulation, shall demonstrate this fact (see also the detailed descriptions in the country sections, Part Two of this report):
In Germany, submission for deliberate release is to be published in local newspapers and in the official journal of the Ministry of Justice. Law provides for citizen participation in the form of written objections. On the web site of the competent authority deciding on the application, the Robert-Koch Institute (RKI), information is given on the procedure in general and on granted applications after the decision is made, whereas the concrete ongoing procedure is not made transparent to the public.
In the Netherlands, the general public has to be informed about the application via the internet and national and regional newspapers. Citizens can participate in the procedure by submitting written objections to the concept disposals. The decision-making is to some degree made transparent through the internet (web-sites of the relevant authorities Ministry of Housing, Spatial Planning and the Environment (Ministerie van VROM), Bureau for Genetically Modified Organisms (Bureau GGO), and Commission for Genetic Modification (COGEM)).
In the United Kingdom, the general public is informed only about the giving of consent to an application and before the planting of the crop, that is, after the procedure, via the web and through an advertisement in a local newspaper. Information is also supplied via the DEFRA (Department of the Environment, Food and Rural Affairs) web site. Citizens can then present written objections to the granting of consent; but the Competent Authority is not obliged to consider those. Transparency is provided by a public register of information at the Ministry
library (DEFRA), available over the internet. Minutes of ACRE meetings (although selective) are also available.
In Ireland, submission for deliberate release is to be made public by an advertisement in a local newspaper containing the details of the organisation applying for the trial, the location, purpose, and date of the deliberate release. Citizen participation is provided in the form of written objections (e-mails, letters, petitions.) Apart from public registers in the Environmental Protection Agency (EPA) offices, no measures to attain transparency are provided for.
In Sweden, from the moment when an application is complete, the rule is publicity. As a policy, the competent authority, the SBA (Swedish Board of Agriculture), refers the application to several institutions and organisations, e.g. the Swedish Society for Nature Conservation and The Swedish Ecological farmers. On request, everybody can get quite extensive information about a case. Furthermore, information about all cases of field trials decided is given on the SBA homepage. The SBA requires the applicant to advertise about the field trial in the local newspaper. No information is given on the precise location and timing of the field trial. No citizen participation is legally provided (by way of exception, the concerned boards can decide whether a participation is required). A high degree of transparency of procedure seems to be the dominant feature of the Swedish procedure.
In Italy, the public is not informed about an ongoing procedure. Information is given to the public on request, for what is not classified as private. Once the decision is made, the public is in principle informed; details of the experiment are published on the Health Ministry web site, the fields of the trial are flagged with banners, and some local authorities are informed (in order to provide appropriate field inspections). Despite of that, a state-of-fact lack of information for the general public has to be postulated. No citizen participation is provided for in the procedure. No provision is made for transparency.
In Hungary, submission for deliberate release is to be made public. The permit (draft and final) must be announced in the official journal of the biotechnology authority. The public can participate in the procedure by written comments on draft permits. Comments are examined by the BC (Committee for Evaluating Biotechnology Procedures), who gives advice to the Biotechnology Authority deciding on the application. The decision-making process itself is
