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policy is integrated in the double sense that it is sensitive to the ecological linkages that exist in the natural environment and reflects the complex linkages that exist between environmental management and other areas of public policy.8 It is procedurally complex, using environmental assessment, freedom of information, and public participation to establish priorities and to ensure implementation of measures that have been decided. It seeks an equitable distribution of costs associated with environmental management by ensuring as far as possible the internalization of related environmental costs in all economic activities. Indeed, this process of internalization has increasingly been recognized as creating desirable economic incentives to find the most cost-effective means of environmental management; this in turn leads to the development of new tools of environmental policy such as pollution charges, resource taxes, or tradable permits.

There are now two principal reasons to investigate the hypothesis that the outcomes of environmental management are broadly comparable in developed countries, even though the process by which these results are achieved may differ significantly:

  • The increasingly significant international dimension of environmental management implies that countries will need to know what other countries are doing to protect the environment, beginning with their neighbors, if they are to achieve their own policy goals.

  • As environmental management becomes more complex, more comprehensive and more effective, significant differences in levels of environmental control or degrees of internalization of environmental costs can cause noticeable economic distortions that impact the relative competitive position of the countries concerned both positively and negatively.

The literature comparing environmental management is sparse and largely limited to Western Europe and North America. It remains unclear just what must be compared to adequately assess environmental management in different countries. At least five dimensions need to be kept in mind.

Comparing Legislation

Comparative studies are a well-established field of legal scholarship. Consequently several authors initially thought that a comparison of legal requirements in developed countries would provide important insight into the state of environmental policy in those countries. The results have generally been unsatisfactory, mainly for two reasons. Environmental regulations are but part of an extended process, which begins well before the adoption of legislation and continues long beyond it. The legislative stage is certainly a key way station since it codifies agreements reached up to that point and defines the framework within which the process is to continue. Focusing on existing law often fails to capture this dynamic. While this is a problem with most comparative legal studies, it is particularly



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