Kees Huizinga, Human Environment and Transport Inspectorate in the Netherlands.
Sometimes apparently simple matters turn out to be more complicated at a closer look. In my PhD research I set out to answer the following question: are regulatory enforcement agencies generally working well aligned with their official goals? That question may at first sight seem superfluous as the goals of these agencies are generally considered to be relatively straightforward, that is, accomplishing compliance with regulations by the regulated organizations concerned. It should therefore not surprise that not much has been written in the literature about enforcement goals as such, or about goal alignment of enforcement agencies. But are these really non-issues? It is well known that these agencies may be heavily criticized after calamities for not having done the right things to prevent them. In contrast, in relatively quiet periods, they may be criticized for inspecting too frequent and too intense, thereby hindering private enterprises.
I decided to explore my research question by using the concept of goal displacement. This concept was introduced more than a century ago within the field of sociology and specifically in the study of political parties. Despite its respectable age and its observation in all kinds of organizational settings, theory building has remained relatively limited. In fact, goal displacement has become something of a general covering term for any movement away from an articulated goal under any circumstances, a catch-all term. As such it appeared too vague to use as a meaningful concept in my research. Why not use other lines of research and concepts, such as organization theory or the concept of decoupling? A main reason pleading for goal displacement is that it directly relates to the very reason of being of organizations, which is to achieve specified goals. Displacements from these goals will generally seriously impair effectiveness. For regulatory enforcement agencies this may have grave consequences such as explosions or a collapse of quality of services.
So, while the concept as such seemed relevant for my research, some sort of revitalization and refining of the concept was clearly needed. Devising a general framework of goal-displacement types turned out to be very helpful. This framework specifies on the one hand how goals can be displaced, the so-called displacement forms. On the other hand, it specifies what goal-component or aspect is actually displaced, referred to as displacement modalities. Although the latter were identified for regulatory enforcement in the first place, they, like the displacement forms, seem to be highly generalizable. As such, this framework may perhaps prove useful for studying goal displacement in other organizations.
In my article Indications of goal displacement induced by budget cuts and output management: a case study of a regulatory enforcement agency in the Netherlands, published in the Journal of Law and Society (Vol 50, Issue 2, 2023), I described a case study of goal displacement at a regulatory enforcement agency in the Netherlands enforcing waste water emission limits. A clear profile of three distinct goal-displacement types affecting this agency was observed. These have very likely contributed to the observed trend in the past 5-10 years of a deterioration of the quality of large surface waters such as big rivers in the Netherlands and, consequently, increasing problems for drinking water companies to prepare good drinking water.
While quite a number of direct and indirect contributing factors could be identified, the main determinants of the goal-displacement types observed appear to be relatively simple: incisive budget cuts over multiple decades and a strong culture of output management, both well-known attributes of New Public Management. This case study is probably one of the first to provide multiple indications that this management style may structurally hamper agencies in aligning with their original goals. As it has been widely applied to government agencies in the Netherlands and numerous other Western countries, similar findings might emerge from other case studies.
It is interesting to note that while professional enforcers and the middle managers very well realized that budget cuts and output management had impaired goal alignment, they were highly skeptical that higher management would be susceptible to their potential downsides in terms of effectiveness. Actually, professional enforcers at the agency worked hard to maintain goal alignment despite the factors seriously threatening it. During the interviews, they spontaneously forwarded all kinds of solutions that can be considered as goal displacement containment or goal realignment (not included in the paper). For example, based on risk analyses, the agency allocates substantial capacities to a limited number of large chemical facilities discharging waste water into the sea. Consequently, inspections at other types of regulated organizations such as beach pavilions, and storage and transshipment facilities had become rare. As the enforcers realized they had lost sight of these organizations, they decided to dedicate capacity, each consecutive year, to one or two of such ‘low-risk’ sectors in a multi-year cycle covering all sectors that tend to be lost out of sight. These inspections enabled them to remain in control, and, if necessary, to regain control.
This case study and the other studies carried out in my PhD research on this subject, strongly suggest that goal alignment in these agencies is not so self-evident as often suspected. An important underlying factor seems to be the often intangible character of regulatory enforcement goals. This characteristic enhances the risk of goal displacement to originate in the first place but also prevents it from being readily observed and acted upon. Consequently, tendencies to goal displacement such as those caused by budget cuts and output management may have free rein and thereby seriously impair organizational effectiveness.
The vulnerability to goal displacement may be especially high when effects evaluations are time-consuming and costly, and therefore relatively rare, as is the case for regulatory enforcement. Under these circumstances, it may be rewarding for these agencies to investigate the possible presence of situations of goal displacement, as was done in this case study. It enables the agencies to obtain, in a relatively short period and with relatively limited means, indications of potential breakdowns of organizational effectiveness. As such it may offer a preliminary step to or even an alternative to effects evaluations.
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