This forum provides commentary on five accountability articles in this issue. In response to those pieces, it advances the argument that the study of accountability through the framework proposed by Kramarz and Park (and demonstrated by the empirical articles) can uncover key political dynamics that drive the design of global environmental governance initiatives. The utility of the practical application of accountability measures to ensure good design, rather than proper implementation, is less clear. Using the framework to study accountability does, however, provide an opening for debates over initiative design that may lead to improvements in global environmental governance outcomes.
I am skeptical about accountability. This is not a unique position and, in fact, puts me in good company with the authors in this collection of articles. I began reviewing these articles unconvinced of the analytic value of accountability. The term has the feel of an empty signifier masking other, more fundamental dynamics. More importantly, I was suspicious of its utility as a governance tool. Kramarz and Park, in this issue, correctly highlight the paradox whereby accountability mechanisms are increasingly prominent while environmental conditions deteriorate. Their explanation of the paradox is also convincing—a disjuncture between pursuit of environmental goals and the ends for which accountability measures are designed.1
My initial bias was challenged in a number of ways by this excellent collection of articles although I am still worried about the ways in which accountability could be helping reproduce the same patterns of environmental degradation under a seal of legitimacy. This collection demonstrates that, for accountability mechanisms to be a force for environmental improvement, we need them to be used in service of formulating radically different goals for global environmental governance institutions and interventions. That is, we have to make people, decision-makers, and institutions responsible for very different things. Unfortunately accountability mechanisms as currently conceived and deployed may not (and perhaps cannot) help us devise or give force to those goals and may even be counterproductive in attempting to do so. However, after having reviewed this collection, I am more sanguine about the analytic and critical utility of accountability as a concept. These articles demonstrate that studying accountability systematically and with a critical eye makes it possible to uncover the goals that (sometimes implicitly) drive the design of global environmental governance (GEG) institutions and the politics those goals imply. This process, analyzing and assessing the use of accountability mechanisms, may actually push forward the goal, so well articulated by Kramarz and Park in this issue, of having a real discussion of the aims of global environmental governance much more expeditiously than enhancing accountability measures on the ground ever could or would.
I explore these thoughts more fully by first examining the Kramarz and Park framing article and why it increased my skepticism about the practical utility of accountability while making me more optimistic about the analytic utility of the concept. I then turn to the four empirically oriented papers and discuss how each is oriented to the paradox Kramarz and Park identify and the ways in which each illustrates the analytic utility and practical pitfalls of accountability.
Accountability Can’t Solve our Problems, but Accountability Analysis Can Help
Kramarz and Park (this issue, Page 1) hold out hope that accountability can be “a tool for improving environmental governance leading to better environmental benefits.” The key is to get the goals of environmental governance right, and they argue that accountability mechanisms should hold actors responsible for having goals of enhancing sustainability when they design governance initiatives as well as for the ways in which they implement those initiatives. Their framework, then, provides a means of undertaking a different kind of accountability analysis, one that reveals the politics and interests that go into the design of GEG initiatives and efforts rather than just their implementation. This, they argue, allows analysts to systematically approach crucial questions, such as:
Who gets to choose the approach for addressing an environmental problem?
What biases animate their choices?
To whom are actors accountable in prioritizing certain goals and design features?
This analytic move splits accountability analysis into two tiers—one that looks at accountability dynamics at the design stage of governance initiatives and another that examines the implementation stage. In addition, by systematically mapping categories of actors with the goals they bring to GEG and the kinds of accountability mechanisms they pursue/are subject to, the framework can be used to gain comprehensive knowledge of accountability dynamics in any GEG initiative. This is a creative turn that gets to the heart of the accountability paradox—explaining why we might see an increasing focus on accountability combined with continued environmental degradation. This framework opens up analytic space to reveal the politics and interests (goals) that drive the design and implementation of GEG initiatives: follow the accountability measures! This analytic space then has the potential to become the home for the debate over the “understanding and framing of problems” (page 19) that needs to take place in order to avoid the paradox that Kramarz and Park identify.
However, while I am enthusiastic about the potential for studying accountability systematically and critically, I remain skeptical that pursuing accountability mechanisms at Kramarz and Park’s tier one provides a path towards enhanced sustainability. There is a significant difference between holding an actor accountable for damage2 (i.e., corporations polluting the environment) or for not carrying out governance well (i.e., not transparent, corrupt) versus holding an actor accountable for not having the right goals (valuing efficiency over sustainability in the design of GEG initiatives) or not being the appropriate actor to design a GEG initiative. The mechanisms for the former two situations are well developed. However, simply put, we do not currently have well-developed conceptual or institutional apparatus for the latter two. Kramarz and Park are to be lauded for laying bare this lacuna, but I am not convinced that “accountability” is necessarily the right frame for the kind of tier one discussion and debate that we need.
The problem, it seems to me, is that accountability mechanisms work best (and are most important) when an authoritative actor is implementing an initiative, because then the performance that actor is responsible for and the community to which it is responsible are (more or less) clear. At tier one, there are either actors competing to be authoritative or debate over authoritative actors’ goals (rather than what they do). It is difficult to see how accountability mechanisms could be devised in the former case because it is uncertain to whom actors are responsible. It is also difficult to see how the latter case really constitutes accountability. Debates over goals are bigger than accountability; they are politics over values and interests.
The great potential of Kramarz and Park’s framework is that doing accountability analysis with their framework can be a means to effect the kinds of changes at tier one that they call for. They provide scholars and practitioners the means to undertake accountability analysis as:
a forensic account for explaining who got to choose the “right” approach for addressing environmental problems, while revealing the biases that animated those choices and determining whether (and to whom) they were accountable for prioritizing certain goals. (page 12)
As is clear when reviewing the empirical articles in this collection, the accountability analysis inspired by Kramarz and Park’s framework is useful for identifying the kind of changes GEG requires.
Contesting Accountability and Legitimacy
The clearest demonstration of the paradox that Kramarz and Park identify is found in the Gulbrandsen and Auld article on the conflict over evolving accountability mechanisms designed by the Marine Stewardship Council (MSC). Fish stocks around the world are plummeting (Barkin and DeSombre 2013), and pitched battles are being fought over the accountability of private mechanisms for improving the sustainability of fisheries. This is not to trivialize governance through certification; the failure of governmental and multilateral efforts to preserve fish stocks has, in part, generated the move towards private and transnational governance, and the literature has shown that these mechanisms have potential (e.g., Cashore et al. 2007; Auld 2014). Yet, it is unclear if accountability politics can or will translate into positive sustainability outcomes.
This article reveals that conflicts over accountability mechanisms are a proxy fight for larger values—over who gets to decide what sustainable fisheries look like and how they are managed and monitored. These are the very kind of big-picture goals that Kramarz and Park argue need to be the true focus of debate and discussion. However, in line with their fears, the accountability focus ultimately subordinates these debates to more proximate conflicts that may do little to enhance sustainability. Gulbrandsen and Auld’s article ultimately demonstrates that analyzing the conflict over accountability measures can uncover crucial political dynamics and goal misalignments, while doggedly pursuing accountability measures might be counterproductive environmentally unless the goals that an initiative is being held to account for are environmentally sound. Accountability measures only matter once the goals are right (environmentally), and accountability measures (at least the ones we currently have and employ) do not currently ensure that the goals will be right.
As Gulbrandsen and Auld point out, actors with very different goals come together in the MSC efforts to enhance fishery sustainability:
Environmental groups with sustainability goals
Fishing industry actors seeking market access
Fish retailers seeking consumers
In the development of MSC’s standards and accountability measures, the MSC itself is seeking legitimacy to function as an effective standard setter—one whose standards are followed and whose label is recognized and valued.
The article shows the fascinating way in which conflict over accountability measures reveals the politics of whose and what goals are embedded in those measures. The MSC is navigating a conflict over whose goals should be represented in the accountability mechanisms that, in part, define the MSC—internal stakeholders in the fishing industry, retailers, or the environmental groups that provide the public awareness/pressure that makes governance through certification/labeling plausible. By analyzing accountability mechanisms and conflict over them, Gulbrandsen and Auld show how the fight over who gets to have a say on what the certification standards are and whether they are being met “affects the normative principles against which a certification standard will be measured. Narrowly focusing on interests within the fisheries supply chain, for instance, may neglect global commons concerns arising about ocean systems” (page 46).
This is compelling politics, especially in the interplay of internal and external stakeholders with very different goals and leverage over the success of the MSC, but why does this article make me less sanguine about accountability mechanisms’ practical role in enhancing environmental governance? The debates about accountability are proxies for debates about larger values and goals that drive the MSC and its implementation of sustainable fishing standards. Accountability measures can only indirectly influence these debates. The MSC will have to choose which values and stakeholders it is accountable to. There is no “accountability” for this choice except in what Gulbrandsen and Auld argue is the likelihood that actors excluded “are likely to engage in rival processes to hold the program accountable and to pursue their objectives” (page 57). As argued above, this is a very different understanding of accountability and, I would argue, better understood as value politics than accountability.
When Does Accountability Matter?
Kuyper and Bäckstrand’s article in this issue takes the exploration of accountability in a slightly different direction—examining when we should expect accountability mechanisms to be put in place to hold representative actors responsible to those they represent. This is especially relevant for informal groupings of nonstate actors within formal multilateral institutions and processes like the UN Framework Convention on Climate Change (UNFCCC). The accountability in question here is not of global environmental governance initiatives themselves, but rather of collective or conglomerate nonstate actors that participate in those initiatives. In terms of Kramarz and Park’s framing paradox, this article shows how far removed accountability mechanisms and discussions can be from environmental outcomes, even when they may be crucial for enhancing the democratic and representative nature of multilateral processes.
Most importantly this article demonstrates that analyzing accountability can reveal when accountability matters and when it doesn’t, especially for constituting the political agency of representative actors. To be clear, it is not a matter of whether accountability measures enhance or erode agency (though that might be the case, as we see below in Gordon’s article); rather, accountability measures are a key marker of and may even constitute collective agency. Analyzing accountability measures may tell us which representative bodies are actually actors and where agency and authority lie.
This argument is easiest to articulate in a contrast of three types of constituent groups analyzed in the Kuyper and Bäckstrand article in this issue:
RINGO (Research and Independent NGOs)—No Accountability Measures, No Agency. RINGO is a constituency at the UNFCCC meetings that counts research organizations (mostly think tanks and university-based groups) among its members. It is not a collective that has substance (or existence really) beyond the UNFCCC meetings. It is not a surprise that RINGO entities have essentially no accountability measures because the collective has no agency. RINGO is not seeking a unified voice because its members are not attending the negotiations to pursue influence.
BINGO (Business and Industry NGOs)—No Accountability Measures, Agency Elsewhere. The members of this constituency definitively have an agenda and goals of influence at the negotiations, but Kuyper and Bäckstrand find that, like RINGO, BINGO has essentially no accountability measures. The key is again agency, but the difference is that while BINGO entities certainly do seek collective influence, collective agency lies elsewhere for business actors (e.g., the International Chamber of Commerce). Presumably accountability mechanisms there hold the collective actor responsible to its constituent members.
Environmental NGOs/Indigenous Peoples’ Organizations/Women and Gender/Youth NGOs—Substantial Accountability Measures, Collective Agency. A number of UNFCCC constituencies have both desire for collective impact and a fairly singular focus on the UNFCCC process, as it is here that disparate NGOs seek to meld their diverse voices into these collective voices. Bäckstrand and Kuyper’s account demonstrates a similar desire for collective voice and influence—agency—in a number of constituencies. Accountability measures accompany this desire for collective agency, because the constituent members have a greater need to hold their collective to account so that the unified voice is used the way that constituent members want it to be used. In these constituencies accountability politics matters.
Here again we see the analytic value of accountability analysis: it can reveal (and constitute) agency in important ways, especially among relatively informal groupings. The practical utility of these kinds of accountability measures for improving global environmental governance is, however (and again), suspect. Enhancing accountability in the RINGO constituency will not enhance climate governance outcomes. Enhancing the accountability of the Climate Action Network to its constituent NGO members, for example, could improve environmental governance, but the logical chain from accountability with the ENGO constituency and “good” outcomes from climate negotiations is long and uncertain. Further, such a positive result would depend on what policies the Climate Action Network pursues and whether it is able to do successfully—and accountability measures cannot necessarily help with that.
Accountability before Governance
Balboa’s forum article in this issue demonstrates the worth of accountability analysis, as opposed to accountability in practice, in its purest form precisely because the governance mechanism being discussed, Environmental Impact Bonds (EIBs), are still in the design phase and have yet to be implemented. By examining the possibilities for accountability measures in EIBs, Balboa uncovers, very directly, the range of goals and interests that are prioritized in this proposed public–private governance mechanism. In this way, her tier one accountability analysis provides a window on the genesis of the very paradox that Kramarz and Park identify; the paradox can be designed in from the beginning, and examining accountability measures shows how this takes place (page 38):
Public and voluntary accountability logics would push to ensure the highest standards possible in provision of this public good. However, the [EIB] contract also draws the line between investment success and failure, which may compel the parties to lower the contract standards to ensure return on investment.
If we follow Balboa’s example and analyze the accountability measures in a proposed initiative, we can uncover the goals and interests that are at the heart of the design of the initiative, just as Kramarz and Park suggest.
Further, this article also confirms my suspicion that accountability measures alone will not (or maybe even cannot) make EIBs good for the environment and could actually lead to environmental degradation. Balboa demonstrates that when financial goals drive the design of EIB accountability mechanisms, there is a significant danger that perverse incentives will be produced, for instance when EIB investors “could experience greater returns by investing in both the creation of pollution and the mitigation of it” (page 39). In this case accountability mechanisms might ensure that financial goals will be met, not in complementary pursuit of environmental goals, but at the expense of environmental goals. Accountability measures are and can be used to pursue multiple goals, but it is the goals that are doing the work at tier one, shaping what accountability mechanisms will be brought to bear and how they will be implemented. Accountability mechanisms for holding actors to account for deciding to unveil EIBs (or not) are less clear cut; for that we have political debates over values and goals.
Given fragmentation (Biermann et al. 2009), the rise of public–private partnerships (e.g., Bäckstrand 2008), and expanding experimentation (Hoffmann 2011) in global environmental governance, we should expect to see more and more innovations like EIBs that attempts to harness market dynamics in the pursuit of environmental goals (Bernstein 2001). Despite all my misgivings, I am convinced that accountability mechanisms will be important—these initiatives should be held responsible for doing what they say they’ll do and for the outcomes they generate (or do not). What the Balboa article reminds us of (reinforcing the argument that Kramarz and Park make in this issue), however, is that accountability mechanisms are not and perhaps cannot be an independent force for improving environmental outcomes. Accountability mechanisms are inextricably yoked to the goals that go into the design of governance mechanisms. Accountability analysis can be used to assess, a priori, the appropriateness of proposed governance initiatives, laying bare the goals that are driving the design.
Unless we develop ways of shifting the values debate or holding designers accountable not for the performance of mechanisms but for the substance of them, accountability measures will always have the potential to produce the paradox that Kramarz and Park warn us of. Further, assuming that accountability mechanisms do have an independent effect can lead to perverse outcomes whereby the effectiveness (or ineffectiveness) of an initiative can be entirely misjudged. In an analysis of transnational climate governance, Bulkeley et al. (2014) discuss how using the most readily available accountability measure—emissions reductions achieved—can actually miss the effectiveness of initiatives that could be transformational in different ways. Similarly, Chan et al. (2015) discuss the need for care in developing accountability measures for nonstate and substate initiatives in ongoing efforts to develop registries associated with the UN climate regime so that the dynamism of these initiatives is not stunted by inappropriately applied accountability mechanisms.
Accountability as Identity
Gordon’s article in this issue provides an in-depth look at the rise of accountability itself—why and how accountability has become central to the developing identity of the C40 Climate Leadership Group, and what C40 accountability is for. To be clear, accountability is instrumental in all of the cases discussed so far—instrumental to organizational legitimacy (Gulbrandsen and Auld), representation (Kuyper and Bäckstrand), and interests/goals (Balboa). In each case, the implicit hope is that accountability measures will also be instrumental for improving environmental outcomes. In Gordon’s case, accountability is instrumental to the identity of the governance initiative itself and in some ways has come full circle—achieving accountability is the goal driving the design C40’s activities, and those activities show that cities and the C40 network are accountable.
This is not necessarily bad for the pursuit of environmental outcomes. The implicit (and sometimes explicit) syllogism at work is clear:
A: A functioning and effective C40 (and municipal action more generally) is good for the global response to climate change.
B: Accountability is good for C40.
C. Accountability must be good for a municipal approach in the global response to climate change.
What Gordon shows in great detail is that A and C are essentially assumed as actors have pursued B in the building of C40. Accountability has become “a means of governing” (page 87) in and of itself, and the crucial politics within C40 have become “politics of accountability” (page 89).
Gordon’s analysis of accountability reveals that accountability measures in C40 are designed for two connected goals—to secure recognition and authority for the initiative in the broader world of global environmental governance, and as a means to persuade (or gently coerce) member cities to take on specific activities. The same accountability measures—e.g., disclosure, transparency, “measure to manage” philosophy—are used to secure both goals. Crucially, these measures are “decidedly non-environmental and operationalized so as to respond to narrow, material interests” (page 93). Gordon argues that accountability measures have the direct goals of “securing access to financing and improving the competitive positioning of member cities in global capital markets” (page 92). Accountability analysis reveals the goals driving the politics of this governance mechanism and provides the space for scrutiny of those goals—the tier one debate that we need.
On the practice side, however, we again see the potential for paradox—C40 is designing its activities to demonstrate, and so that it can plausibly advertise, its accountable nature. This is done in the service of corralling city members, attracting investment, participating in the burgeoning green economy, and securing authority and resources from other levels of government. Because the activities used to demonstrate accountability—measuring and reporting greenhouse gas emissions and, hopefully, their declines—are related to climate action goals, there is potential for accountability mechanisms in this case (as in all the cases) to support pursuit of environmental goals. In fact, much has been made of the potential for city networks to enhance the global response to climate change (e.g., Bulkeley and Betsill 2013). However, the accountability measures are not necessarily designed for environmental goals, or they are designed for a particular vision of environmental goals. Thus the pursuit of transnational municipal sustainability is channeled in particular ways by the accountability goals. As Gordon argues, the accountability measures that C40 uses to establish its identity and authority “render certain practices or aims of governance natural” (page 95) and that concern “quantification, standardization, and aggregation” (page 94). These practices may prove to enhance the global response to climate change, but not because environmental goals are driving their development. Environmental outcomes might be coincidental to C40’s accountability goals and are certainly channeled in specific directions—directions that are not the focus of scrutiny or accountability mechanisms. Using the accountability analysis that Kramarz and Park suggest, we can bring scrutiny to these mechanisms and uncover the goals that drive them.
Accountability measures can be valuable for enhancing sustainability and the effectiveness of GEG initiatives if the goals that go into the design of the initiatives are appropriate.3 What Kramarz and Park provide is a framework for accountability analysis that can systematically and critically assess those goals. The empirical articles demonstrate the great utility of this approach to accountability analysis, demonstrating how one can demonstrate the values, interests, and conflicts shaping GEG initiatives by examining accountability measures and dynamics.
This kind of analysis opens space to have the conversations that we need about whether environmental goals are being served by the GEG initiatives that exist and that are being designed. Here, then, is the practical utility of the framework—by analyzing accountability dynamics, scholars (and others) can contribute to the tier one politics and debates that precede and should shape the development of GEG initiatives and the accountability mechanisms that go with them. I thus remain skeptical that accountability is the answer to effective GEG, but I am now convinced that examining accountability through frameworks and analyses like those provided by these articles may contribute to the path toward effective global environmental governance.
For additional critical views on the utility of accountability (and closely related questions of transparency) from a public administration perspective, see e.g., Dubnick 2005; and from a global environmental politics perspective see e.g., Mol 2010; Auld and Gulbrandsen 2010; Gupta 2010; Mason 2008; Chan and Pattberg 2008. For a more positive, though still critical, analysis see Biermann and Gupta 2011.
On the issue of accountability for environmental harm, see Mason 2008.
It is, of course, possible that GEG initiatives could fail to enhance sustainability even if their goals and implementation are appropriate because the relationship between governance dynamics and environmental outcomes is fraught, see Young 1999.
I thank Teresa Kramarz and Susan Park for the opportunity to comment on this special section, and for their and the anonymous reviewer’s feedback on an earlier version of this commentary.