Dear all,
during the discussions concerning a
possible statement by the IGC on the
"nature of the Internet" someone - I think
it was Milton - underlined the need to
have a clear "problem definition" and to
assess the impact of different policy
options. I also noted that others - I
think it was Mawaki - pointed out that
this is rather high bar for an "advocacy"
statement.
I take absolutely no position on the need
for analysis / assessment before the IGC
makes a statement on this, or other topics.
The decision to issue a statement as the IGC
is of course fully the responsibility of IGC
members, which I'm not.
However, this particular exchange led me to
a broader consideration. As you might know,
the European Commission (similarly to other
governments / public authorities) has a
formal obligation to conduct an "impact
assessment" before proposing new
initiatives. In reality, there are some
subtleties - not all "initiatives" require
it - but the key concept remains.
You can find further information on the
European Commission's approach to impact
assessments at
http://ec.europa.eu/governance/impact/index_en.htm.
If you are interesed and have plenty of time
at your disposal, you might also be
interested in two recent papers analysing
how well (or not :) the EC has performed in
this particular area (G. Lucchetta, "Impact
Assessment and the Policy Cycle in the EU",
2013,
http://www.ceps.eu/book/impact-assessment-and-policy-cycle-eu;
O. Fritsch, C. Radaelli, L. Schrefler, A.
Renda, "Regulatory Quality in the European
Commission and the UK: Old questions and new
findings", 2012,
http://www.ceps.eu/book/regulatory-quality-european-commission-and-uk-old-questions-and-new-findings).
When conducting impact assessments, there
are certain agreed procedures which are
rather generic or "horizontal", i.e.
applying to different policy areas; but
there are also add-on procedures and
methodologies that are used when tackling
more specific policy areas / impacts. To
continue with the example of the European
Commission Impact Assessment procedures,
which are the ones I know best, specific
guidelines / methodologies to assess the
impact on SMEs, administrative
simplification and fundamental rights have
been introduced throughout the years.
I wonder whether there is a need to introduce
specific guidelines / methodologies to assess
the impact of Internet-related policies (which
I define on the fly as "policies (including
regulation, soft law, research activities)
which either impact on, or are impacted by,
the Internet). Questions that come to my mind:
- is the Internet an important enough phenomenon
/ infrastructure to justify having specific
methodologies to assess the impact of policies
on it, and its impact on policies?