Identifying stakeholders in Brussels

In other words, stakeholders in EU policy are very important, for assisting with throughput legitimacy and for helping policy-makers understand the complexities of a union with over 500 million people. Identifying key stakeholders interested in health in the European Union is not as easy as it may sound. Researchers have used a variety of techniques, but each has drawbacks born of a simple

51 Jarman H (2017). Trade policy governance: What health policymakers and advocates need to know.

Health Policy, 121(11):1105–12.

problem: the EU makes it easy to engage at a very superficial level, but there are major time and resource constraints that mean the actual number of reliably engaged stakeholders who are seen as serious is much smaller. Time and resource constraints also mean that money is empowered, for it can buy staff time and capacity. In the particular context of the EU, throughput legitimacy also means that poorly resourced interests are often better positioned and supported to act in policy than their equivalents in Member States which are less concerned about throughput legitimacy.

One alternative option is to consult the various lists of organizations that respond to consultations, join consultative forums, appear in lobbying directories sold around Brussels, and send representatives to public meetings. This produces a long list of organizations. The EU Health Policy Forum has around 5 000 registered organizations and it is not easy to find out what they are (EU stakeholder transparency initiatives have a strange way of making such information less accessible and transparent with each initiative). We can take it as a given that they are not all equally influential in policy debates. Statistical research, albeit rather old, has indeed found that most of the organizations that appear as interested in EU health policy are not really very interested and are not very influential.⁵² In many cases, especially with local and regional governments and Member State level associations, the main function of the office in Brussels is to watch for funding opportunities and take note of consequential policies rather than lobby. In particular, the EU has an institutional bias towards interacting with

“Eurogroups”, EU-level associations, rather than organizations set up at Member State level. The reliance on Eurogroups can appear to freeze out national expertise, but it has two compelling advantages: it obliges Eurogroups, rather than the Commission, to aggregate diverse preferences, and it obliges stakeholders to formulate broad appeals rather than speak in the particularistic languages of national politics and special interests.

The main alternative is to ask practitioners which the key organizations are. This method has several drawbacks. One is that it risks mapping networks rather than the whole field: if you start by asking public health advocates, you will end with a better map of public health advocates than of, for example, anti-deregulation advocates employed by industry. The second is that the field of health policy is essentially contested – are manufacturers of sugary industrial sweets part of the health policy world, in their own eyes or in the eyes of others? They are certainly to be found in the Health Policy Forum and other consultative bodies. The third is that Brussels, like any heavily lobbied political system, has lobbying firms with the capacity to rapidly expand their operations at every level, from junior to senior,

52 Greer SL, Massard da Fonseca E, Adolph C (2008). Mobilizing Bias in Europe: Lobbies, Democracy and EU Health Policy-Making. European Union Politics, 9(3):403–33.

when an industry with money finds that an issue is on the agenda and wants to influence it. Temporary lobbying operations of great size can be set up almost overnight if there is enough money. Fourth and finally, lobbying can be murky.

Not all organizations like to represent themselves publicly as such. Industries with serious opposition in the health world, notably the tobacco industry, frequently have incentives to work through other organizations, funding and supporting groups whose link to the underlying industry support is not made clear.

There are some clear repeat players in EU health policy with credibility and a health agenda, such as the European Public Health Alliance (EPHA) made up of public health NGOs, the more academic European Public Health Association (EUPHA), the European Trades Union Institute, the European Consumer Organization (BEUC), the European Patients Forum, the European Heart Network, the Association International de la Mutualité (AIM) and European Social Insurance Platform, representing social insurance organizations and associations for various health professions, to name just a few. Many ‘non health’

NGOs now occupy key positions in health-related discussions such as transport (TE – Transport Environment), housing/homeless (FEANTSA – European Federation of National Organisations Working with the Homeless)⁵³ and environment (HEAL – European Health and Environment Alliance) to name but a few. There are also Member State level organizations that have credibility even if they must often formally act through Eurogroups.⁵⁴

In most cases, the size of these organizations’ staff is very small and the number of their senior or long-term staff smaller still. This means that their credibility and profile in Brussels can rise and fall quickly with internal politics and the career choices of individuals – while it is easy to staff these organizations at the junior level, thanks to the large Brussels labour market in public affairs staff, it is relatively hard to find or train people who will develop technical and political

53 Homelessness, particularly chronic homelessness, often reflects health problems, and being homeless is extremely bad for one’s health. Willison C (2017). Shelter from the Storm: Roles, responsibilities, and challenges in United States housing policy governance. Health Policy, 121(11):1113–23. For European data, and EU policy options, see FEANTSA and the Fondation Abbé Pierre (2019). Fourth Overview of Housing Exclusion in Europe 2019. Available at: https://www.feantsa.org/en/report/2019/04/01/

the-fourth-overview-of-housing-exclusion-in-europe-2019?bcParent=27. Brussels: FEANTSA; Clair A, Stuckler D (2016). Structured Review of the Evidence on the Intersection of Housing and Health Policy in the WHO European Region. Public Health Panorama, 2(2):160–83.

54 For more information and research about EU stakeholder engagement, there are a number of useful texts:

Woll C (2008). Firm Interests: How Governments Shape Business Lobbying on Global Trade. Ithaca: Cornell University Press; Greer SL (2009). “The Changing World of European Health Lobbies”, in Coen C &

Richardson JJ (eds.). Lobbying in the European Union. Oxford: Oxford University Press; Coen D (ed.) (2007). EU Lobbying: Empirical and Theoretical Studies. Abingdon: Routledge; Greer SL, Massard da Fonseca E, Adolph C (2008). Mobilizing Bias in Europe: Lobbies, Democracy and EU Health Policy-Making. European Union Politics, 9(3):403–33; van Schendelen MP, Van Schendelen R (2010). More Machiavelli in Brussels: The art of lobbying the EU. Amsterdam University Press. Some of these titles may seem old, but, while specific information about EU politics and people changes daily, the basics of EU stakeholder engagement and the world of interest representation change much more slowly.

credibility over years. Many of the most effective organizations are precisely the ones which have been able to retain staff for years, keep in touch with “alumni”

who have moved on, and develop strong cadres of junior and mid-level staff.

Succession and workforce planning are therefore crucial in these organizations, and for outside observers it is important to pay attention to individual people’s careers as well as their organizations.