Multiple Streams of Gasoline: Applying MSA to Iranian Economic

Sanctions
By: Michael Foster

Rhodes College
Professor Ceccoli

For most of political history, a states preferred method of getting another

state to act a certain way was through physical coercion. Recently however, the
international system has shifted away from physical force and towards economic
force. The Comprehensive Iran Sanctions, Accountability, and Divestment Act of
2010 (CISADA) is a recent example of a display of economic force and an
important one. However, a policy like CISADA does not just pop into existence. It
was proposed, edited, voted on, reedited, and voted on several more times before
coming into effect, just like all pieces of public policy. Other similar bills had been
considered before, but never quite gained traction. Several theoretical frameworks
give policy researchers a way to understand the complex policy process, and why
certain policy attempts succeed or fail. For the Comprehensive Iran Sanctions,
Accountability, and Divestment Act of 2010, no framework is more
convincing in explaining its success than the Multiple Streams Approach, a
fact which will be demonstrated after an overview of the paradigm itself.
Before examining the Multiple Streams Approach in the context of a policy
like CISADA, it is important to examine the mechanics of the approach and what its
relevant assumptions are. According to Zahariadis, the basis for the MSA lies in a
previously articulated model called the Garbage Can Model of Choice. The model,
which represents choice as a garbage can, emphasizes the transitory nature of
policy making. That is, actors are constantly joining and leaving the process, leaving
their own potential solutions or problems (often unrelated) behind within the policy
process (Zahariadis, 2007).Extrapolating from the garbage can model, the MSA also
assumes that while these actors must individually act or think in a serial manner
(one issue after another, in sequence) organizations composed of several
individuals can process issues in parallel. This allows governments to address

multiple problems at once and independently of other parts of that same

organization, which one can easily see is the case (Zahariadis, 2007).
The MSA builds upon the garbage can model in a few other ways. MSA
identifies three separate and distinct streams that flow into the policymaking
process: the problem stream, the policy stream, and the politics stream. The
problem stream is made up of the constant flow of new issues and concerns that
citizens would like policymakers to address. Zahariadis gives examples of problems
ranging from environmental disasters to inflation. An important part of the Problem
stream is the occurrence of focusing events, which force the public to pay attention
to specific elements of the issue. The policy stream is the whole wealth of ideas that
are articulated by specialists in policy communities networks that include
bureaucrats, congressional staff members, academics, and researchers in think
tanks (Zahariadis, 2007:33). These policy ideas can either be ignored or used by
policymakers, although policies that are adopted by policymakers usually at least
some amount of change. Lastly, the politics stream, composed of three elements:
the national mood: pressure-group campaigns, and administrative or legislative
turnover (Zahariadis, 2007:34). Essentially, the politics stream is the way the
political wind is blowing. Further, MSA assumes that these three streams are totally
independent of one another in a manner similar to how MSA assumes different parts
of an organization flow independent of one another.
That is not to say the three streams never interact. Indeed, one of the major
assumptions of the MSA is that when streams do align during policy windows, they
create opportunities for advocates of proposals to push their pet solutions, or to
push attention to their special problems (Zahariadis quoting Kingdon, 1995:165).
While the streams come together on their own occasionally, policy entrepreneurs

are powerful actors that attempt to force the streams together in order to push their
preferred policy outcome. This act is called coupling, which will be discussed in
more depth further in this essay.
Finally, the MSA builds upon the garbage can model by highlighting the
amount of ambiguity that is present within the policymaking process. Ambiguity is
described by the Merriam-Webster dictionary in two ways: doubtful or uncertain
especially from obscurity and capable of being understood in two or more possible
ways. The garbage can model, and therefore the MSA, use ambiguity in the latter
context as evidenced by an example from Zahariadis: more information can tell us
how AIDS is spread, but it still wont tell us whether AIDS is a health, educational,
political, or moral issue (Zahariadis, 2007:26). In other words, the ambiguity
surrounding AIDS public policy is not from a lack of information, but because the
issue is being seen from a variety of perspectives that all seem equally valid.
Replacing AIDS with Iranian economic sanctions yields similar results: is it a
security, environmental, or economic issue? Well, its ambiguous. This ambiguity is
presented in a number of different ways according to Zahariadis. First, though
already discussed, is the fact that actors in the policymaking process are constantly
falling in and out of participation. Second, in a critique of rational choice theory,
MSA assumes that many actors dont know specifically what they want.
Policymakers are often unable to consciously develop their exact policy preference
and consider all consequences. Essentially, MSA assumes that actors act within the
limits of Bounded Rationality. Finally, ambiguity presents itself in the actual
mechanism of inputs into products of policy organizations. Actors within these
policy organizations may be aware of their individual responsibilities, but they
exhibit only rudimentary knowledge of how their job fits into the overall mission of

the organization (Zahariadis, 2007:27). Ambiguity is an essential piece of the MSA,

and provides the mechanism through which policy entrepreneurs are to
manipulate policy.
Policy manipulation can be defined succinctly as managing ambiguity
(Zahariadis, 2007:29). Since the political system is rife with ambiguity, policy
entrepreneurs are able to frame issues by defining them in certain way and
emphasizing some dimension, overcoming ambiguity and pursuing their preferred
policy output. Policy entrepreneurs are goal-intending manipulators while many
policymakers are subject to manipulation (Zahariadis, 2007:30). By using framing
techniques, policy entrepreneurs are able to couple the problem, policy and politics
stream, creating a window of opportunity to push their solution through. Many times
a policy output is the result of an entrepreneur coupling the streams to manipulate
policymakers, creating the perfect environment for their solution.
Now that the basic principles and assumptions of the Multiple Streams
Approach have been examined, albeit briefly, the remainder of this essay will use
the MSA to explain the passage of the Comprehensive Iran Sanctions,
Accountability, and Divestment Act of 2010. After a summary of the bill, the
problem, policy and political stream will each be inspected in turn, before finally
identifying the clear presence of a relevant policy window.
Representative Howard Berman, Democrat from California, would introduce
the bill into the House of Representatives under the name Iran Refined Petroleum
Sanctions Act of 2009. The act that would eventually be passed was named after a
corresponding bill (CISADA) introduced in the Senate by Senator Chris Dodd (CRS,
2009). The bill sought to address Irans illicit nuclear efforts, unconventional and

ballistic missile development programs, and support for international terrorism by

giving the President the explicit authority to impose additional sanctions on the
government of Iran (CRS, 2009). The exact sanctions the bill refers to are from a
previous bill titled the Iran Sanctions Act of 1996. Under that previous law, sanctions
were imposed at the Presidents discretion upon any individual or corporation that
knowingly invests a large sum of money (originally $40 million total) into Iran.
Potential sanctions in the 1996 bill included the denial of export licenses, denial of
loans from the Export-Import Bank, denial of large loans from US financial
institutions, and even a denial of all or some of the companys imports (CRS, 1996).
CISADA tightens up the original regulations, limiting investment from a total of $40
million to a total of $20 million. Additionally, the new sanctions would apply to any
party that invested in Iran any amount of money for the refinement of petroleum, or
shared any technology that would assist in the refinement process (CRS, 2009).
Obviously, selling Iran already refined petroleum was off the table as well.
Now that a picture of the policy output in question has been shown, it is time
to shift attention backwards from the end of the policy process to the beginning.
Using the Multiple Streams Approach, that means focusing on the three streams
outlined above. Important to note though is that this analysis is not done with strict
chronology, as these streams are working simultaneously. Starting with the policy
stream, it is clear to see the wealth of policy relating to Iranian sanctions. Obviously,
if CISADA is amending a previous law that placed sanctions on Iran there is some
prior sanction policy in the primeval soup of the policy stream (Zahariadis,
2007:33). However CISADA was not a general economic sanction, it was specifically
a sanction on the refinement of petroleum in addition to the tightening of economic
regulations. This idea however did not come out of the blue; the idea had clearly

been considered, many times, before CISADA would actually pass. Several years
before CISADA had been introduced, the Bush administration had considered a
possible cutoff of all refined gasoline to Iran before eventually tabling the idea
(Sanger, 2009). Picking up the torch of his Republican party-mate, John McCain
brought up the idea of limiting gasoline imports as well as specific sanctions on
[regime] leaders in Iran (Carnevale, 2008). Considering McCains speech came at
the American Israeli Public Affairs Committee meeting, the quote should hold
particular weight, considering the national security interest of Israel in the policy.
Obama made it clear that it was a bipartisan policy consideration when he
announced in a debate a few months later that he believed limiting gasoline imports
to Iran would start putting the squeeze on them (Sanger, 2009). Clearly the idea
of limiting Irans ability to import the refined gasoline it needed was not a new one
when CISADA became law in late 2010. The idea had been floating in the policy
stream for several years, but hadnt been acted upon due to a lack of a clear
political window.
Finally, the political stream must be examined. Earlier this essay established
that the political stream was made up of three different parts: national mood,
interest group campaigns, and administrative turnover. If national mood is able to
be captured, the best possible way to investigate it would be opinion polls. A Gallup
national opinion poll conducted in 2008 asked how favorable the respondent viewed
Israel. The result was over 70% of respondents saying they viewed Israel as either
very favorable or mostly favorable (Gallup, 2008). Another poll conducted two
years prior had over half of respondents saying that Israels security had gotten
worse, and 70% believed that Iran was responsible for attacks on Israel that were
ongoing at the time (Gallup, 2006). The above poll numbers indicate that a majority

of the United States at that time liked Israel, but were worried that its security had
gotten worse. Additionally, a supermajority of Americans believed that Iran was at
least moderately responsible. Were there a barometer on the nation in 2008-2010, it
would read pro-sanction on Iran.
The other two pieces of the political stream, administrative turnover and
pressure group campaigns, will be studied presently. The obvious administrative
turnover preceding the passage of CISADA was the election of Barack Obama to
President. While the Bush administration had tabled the idea of refined petroleum
sanctions, Obamas quote during the October debate shows he would at least
consider it. More importantly, House Rep. Berman would become the chairman of
the House Foreign Affair Committee, only months before he would introduce the bill
that would become CISADA. The final part of the politics stream, the pressure group
campaign piece, is best exemplified by the public spending of AIPAC, or the
American Israeli Public Affairs Committee. The committee, a pro-Israel advocacy
and lobbying group, spent almost $88 million dollars in 2008 according to Pew
Research. AIPAC accounted for almost a quarter of total spending among all
advocacy groups. This incredible public spending by AIPAC, along with the ascension
of Rep. Berman to chair of the Foreign Affairs Committee and the Gallup poll
indicators show the politics stream was flowing clearly in a pro-Israel direction.
The political and policy stream were clearly joined by the time CISADA was
introduced to the floor of the House. But it could have gone the way of previous
attempts at restricting Iranian importation of gasoline were it not for the problem
stream also aligning. However, the revelation that Iran had a secret uranium
refinement plant near the capital of Tehran at Qom acted as a major focusing event
(Traynor and Borger, 2009). CISADA was a bill trying to curb Iranian nuclear

development, and here was evidence that their nuclear program was further along
than anyone knew. It threw a certain sense of urgency over the pending CISADA
vote, which was undergoing the amending process at the time.
The revelation of the uranium refinement facility at Qom might have been
enough to push CISADA through, but it is the work of policy entrepreneurs to couple
the various streams and guarantee they pass. Representative Berman, the man who
first introduced CISADA to the House of Representatives, is clearly one such policy
entrepreneur. Entrepreneurs have their own preferences on policy, and Berman is
no exception. In an interview with the Forward, Berman said even before I was a
democrat I was a Zionist (Guttman 2008). In the same article, a board member of
AIPAC is quoted saying that Rep. Berman is not only a leader on [Jewish] issues, but
he is a friend to many in the pro-Israel community. This considered, it is no stretch
to imagine that Rep. Bermans preferred policy is pro-Israel and anti-Iran.
Immediately following the news of the secret refinement reactor, Rep.
Berman published an editorial in the Washington Post that is a clear example of
political manipulating. In the opening sentence, Berman says that Tehran could
soon have humankinds most frightening weapon (Berman 2009). This is a clear
attempt at framing the issue as one of national security. This frame is reinforced a
paragraph later when Berman says that Iran has at least enough enriched uranium
for one bomb, adding some sense of urgency. As an overture to the national security
issue, Berman builds on the idea that Iranian officials are untrustworthy, saying
there is more than ample reason to remain skeptical about continuing diplomatic
talks with the Iranian government. Opposition to the bill could have framed it as a
sovereignty or free trade issue, but this framing event gave Berman too much
ammunition. By highlighting these issues, Representative Berman is able to deftly

ensure that the three streams are coupled and the preferred solution, his own bill
CISADA, would have a better chance at passing.
The Multiple Streams Approach is not without its detractors. One of the major
critiques focuses on policy entrepreneurs, and the utility of stressing entrepreneurs
as individuals (Zahariadis 2007:44). Some call for a developed theory of
institutional entrepreneurship. In the context of the MSA as a whole further,
development of the concept of entrepreneurship might be necessary; but in the
context of CISADA specifically, the role of individual policy entrepreneur Rep.
Howard Berman cannot be understated. This is most shown by the quick (politically
speaking) turn around in the American political approach to Iranian nuclear policy.
CISADA passed the senate on March 11th, 2010 and became public law the following
July 1st. But Berman would be voted out of office in the 2012 election, and sanctions
on Iran over nuclear development would erode after his departure from office
despite AIPACs continued public pressure. The effort of Rep. Berman, both in the
introduction of his own policy and editorial work, was a major factor in the passage
of CISADA and his role as an individual entrepreneur is notable. Developing the idea
of institutional entrepreneurship will help scholars understand other policies, but in
the context of CISADA the individual entrepreneur plays a bigger role. The passing
of CISADA as a whole shows the incredible strength of the Multiple Streams
Approach. The politics stream was pro-Israel at the time, and sanctions on refined
petroleum had been floating in the policy stream for some time. Rep. Berman takes
advantage of the discovery of the refinement plant near Qom and focuses on the
Israeli national defense dimension of the issue, effectively coupling the three
streams and creating the perfect window to push his preferred policy, CISADA, into
law.

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