Double-hatted agencies on the European scene? A case study of the IMPEL network

The European Commission has over the past years intensified its efforts to develop alternative and non-legal instruments for improving implementation in the member states. One specific instrument is networked administrative structures with national regulatory agencies , aiming to harmonize and improve implementation at the national ‘street-level’. Changes in character of the member states’ public administrations serve as an important background for these developments, a distinctive feature being the decentralization of tasks to regulatory agencies placed outside the central administrative hierarchy. Due to their relative autonomy, these agencies are well placed to work ‘double –hatted’ in the sense that they interact directly with the European Commission in enforcing EU law, at the same time as they perform traditional tasks as agents of national ministries. The case which is described and analyzed in this paper is the IMPEL network , an informal network between the European Commission and national environmental authorities in the various EU countries. It is argued that a network such as IMPEL is an arrangement that on the one hand may lead to more effective and homogeneous implementation of Community law, but that may on the other hand challenge the balance between different institutions at various levels of governance in the European Union. A later version of this paper was published in 2006 as a book chapter in M. Egeberg (ed.) The Multilevel Union Administration