Journal of European Public Policy

ISSN: (Print) (Online) Journal homepage: www.tandfonline.com/journals/rjpp20

Mapping the policy space of public consultations:

evidence from the European Union

Adriana Bunea, Reto Wüest & Sergiu Lipcean

To cite this article: Adriana Bunea, Reto Wüest & Sergiu Lipcean (01 Mar 2024): Mapping the
policy space of public consultations: evidence from the European Union, Journal of European
Public Policy, DOI: 10.1080/13501763.2024.2320836

To link to this article: https://doi.org/10.1080/13501763.2024.2320836

© 2024 The Author(s). Published by Informa

UK Limited, trading as Taylor & Francis
Group

View supplementary material

Published online: 01 Mar 2024.

Submit your article to this journal

Article views: 425

View related articles

View Crossmark data

Full Terms & Conditions of access and use can be found at

https://www.tandfonline.com/action/journalInformation?journalCode=rjpp20
JOURNAL OF EUROPEAN PUBLIC POLICY
https://doi.org/10.1080/13501763.2024.2320836

Mapping the policy space of public consultations:

evidence from the European Union
Adriana Bunea, Reto Wüest and Sergiu Lipcean
University of Bergen, Department of Comparative Politics, Bergen, Norway

ABSTRACT
Public consultations strengthen the informational advantage and policy
legitimacy of bureaucracies by allowing them to collect and aggregate
information on stakeholder preferences. How well consultations perform this
function depends on the dimensional structure and complexity of the policy
spaces describing them. Building on the research on spatial models of
politics, we derive a set of expectations about the dimensional structure and
policy content of consultation policy spaces. We assess our argument
empirically by analysing 42 consultations organised by the European
Commission via online surveys across all policy areas. Using Specific Multiple
Correspondence Analysis (SMCA) we find that more than 70% of the analysed
consultations present low-dimensional policy spaces characterised by one or
two main dimensions, although some also display a three-dimensional space.
The substantive content of policy dimensions is consultation-specific and
varies greatly across events. Most dimensions capture stakeholder alignments
with respect to policy instruments, and only a few with respect to the
orientation of the policy regime. The unveiled consultation policy spaces
reflect a regulatory model of stakeholder engagement in policymaking. Our
findings underscore the challenges and opportunities of information
provision, preference aggregation and the identification of stable majority
equilibria in the context of public consultations and bureaucratic policymaking.

ARTICLE HISTORY Received 28 February 2023; Accepted 14 February 2024

KEYWORDS European Commission; public consultations; preference aggregation; dimensionality of

policy space; regulatory governance; Specific Multiple Correspondence Analysis

Introduction
Stakeholder consultations are a rich and important source of policy and pol-
itical information that helps bureaucracies strengthen their informational

CONTACT Adriana Bunea adriana.bunea@uib.no University of Bergen, Department of Com-

parative Politics, Christies gate 15, Bergen 5020, Norway
Supplemental data for this article can be accessed online at https://doi.org/10.1080/13501763.2024.
2320836.
© 2024 The Author(s). Published by Informa UK Limited, trading as Taylor & Francis Group
This is an Open Access article distributed under the terms of the Creative Commons Attribution-NonCommercial-NoDer-
ivatives License (http://creativecommons.org/licenses/by-nc-nd/4.0/), which permits non-commercial re-use, distri-
bution, and reproduction in any medium, provided the original work is properly cited, and is not altered,
transformed, or built upon in any way. The terms on which this article has been published allow the posting of the
Accepted Manuscript in a repository by the author(s) or with their consent.
2 A. BUNEA ET AL.

advantage, while enhancing their public reputation and legitimacy (Gailmard

& Patty, 2013). This informational advantage lies at the core of bureaucratic
power and discretion in the use of delegated prerogatives (Yackee, 2019).
The introduction of online tools to engage stakeholders in public policymak-
ing enables bureaucracies to get policy input from numerous and diverse sta-
keholders on a high number of different policy issues (OECD, 2022). For non-
elected institutions such as bureaucracies, this shift towards e-governance
and online stakeholder involvement offers a valuable opportunity to learn
about the preferences and policy demands of different constituencies and
the public support for policy measures (Meier & O’Toole, 2006). While
policy expertise may also be elicited from other sources in the system (i.e.,
expert groups or specialised committees, cf. Moffitt, 2014), the information
about the aggregate distribution of stakeholders’ preferences across issues
and levels of stakeholder support for different policy options is uniquely con-
tained in the public consultations organised in relation to specific policy pro-
posals and initiatives.
The quality of public consultations as sources of political information that
facilitate legitimate and responsive policymaking depends however on the
extent to which they provide policymakers with usable information and
allows them to identify policy options that have the support of most stake-
holders. A precondition for legitimate and responsive government is that
decision-makers get informed about the content of stakeholders’ preferences
and the systematic patterns of their alignments across issues and can identify
(ideally stable) majority equilibria regarding different policy issues (Patty &
Penn, 2014). Given the high number of stakeholders usually participating in
consultations, their diverse background and constituencies represented,
and the fact that consultations may ask for feedback on a high number of
complex and technical issues, the information load of consultations may
pose serious challenges to policymakers. Information overload may have
important consequences for policymakers’ ability to aggregate public prefer-
ences and understand what stakeholders want. This in turn affects their
ability to formulate public policies that are aligned with public demands
and majority preferences (West, 2005). The complexity of policy input emer-
ging from the number and diversity of stakeholders and policy issues sub-
jected to consultations can easily translate into a cacophonous policy input
with limited informational value.
An observable implication of policy input complexity is the structure of the
policy space describing the aggregate patterns of stakeholders’ preferences
expressed in consultations. The structure and complexity of the policy
space become thus key for how consultations perform their function as chan-
nels of information transmission and communication between policymakers
and policy-takers and as venues of preference aggregation. We ask therefore
two related questions that are in our view fundamental for understanding the
 JOURNAL OF EUROPEAN PUBLIC POLICY 3

role of consultations in eliciting information about stakeholders’ preferences

and opinions: what is the structure of the policy space characterising stake-
holder consultations and how complex is it?
Despite being fundamental questions in political science research that
have important implications for issues of participation and representation
in bureaucratic policymaking (Meier & O’Toole, 2006), these questions
remain currently unaddressed in both American and European research on
stakeholder consultations. We address this gap and propose an empirical
investigation of one of the most comprehensive and sophisticated system
of public consultations: the stakeholder consultations organised by the Euro-
pean Commission (EC). Our analytical focus and case selection were informed
by four considerations. First, the Commission has developed one of the most
ambitious and formalised public consultation regimes in the world (OECD,
2022). Its extensive use of online platforms to engage stakeholders from
across EU Member States (MS) and beyond constitutes a state-of-the-art con-
sultation regime. Mapping the structure of the policy space describing con-
sultations, and understanding its complexity, offers key insights about
mechanisms of stakeholder engagement in modern, multi-level systems of
governance. It also offers important lessons for how to consolidate stake-
holder participation in bureaucratic policymaking in advanced democracies
and how to design participatory mechanisms in newer democracies.
Second, EC consultations usually engage a high number of diverse stake-
holders that include citizens and various types of interest organisations
(Bunea & Lipcean, 2023). They represent different interests such as
businesses, trade unions or environmental and consumer protection
causes. This diversity usually results in a high heterogeneity of expressed pre-
ferences and constitutes an important source of input complexity character-
ising consultations that can have implications for the structure of the policy
space in which stakeholders’ preferences compete for policymakers’ atten-
tion and inclusion in policy proposals. Third, EC consultations usually invite
stakeholder feedback on many discrete policy issues. They often deal with
technically sophisticated policy matters as well as more politically charged
ones. This further contributes to increasing the complexity of policy inputs.
Fourth, ‘the dimensionality and the character of the EU policy space’ (Gabel
& Hix, 2002, p. 934) is an intensely debated topic of empirical research for
scholars of EU party politics (Benoit & Laver, 2012; Bakker et al., 2012;
Proksch & Lo, 2012) and decision-making (Thomson et al., 2004; Junge &
König, 2007; König, 2018). However, most research focused exclusively on
the dimensionality and substantive content of the EU policy space describing
party competition and intergovernmental decision-making in the Council
and the European Parliament (EP). With some notable exceptions (Bunea &
Ibenskas, 2015; Klüver et al., 2015), the literature on the EU system of govern-
ance currently lacks a systematic empirical analysis of the policy space
4 A. BUNEA ET AL.

describing citizens’ and interest groups’ preferences expressed in consul-

tations preceding the formulation of supranational policies. This is surprising
given the widespread use of consultations in EU policymaking and the agree-
ment that the dimensionality of the policy space describing the agenda-
setting and policy formulation stages has important consequences for the
power of the agenda-setter (EC) and the outcomes of decision-making
(Junge & König, 2007, p. 472).
We conduct an analysis of the policy space that describes stakeholders’
inputs to forty-two public consultations organised through online consul-
tation surveys across twenty-one policy areas. We speak to the literature on
stakeholder engagement in executive governance and bureaucratic policy-
making (Yackee, 2019; Balla et al., 2022), on discussing the dimensionality of
the EU policy space (Gabel & Hix, 2002), on the EC’s agenda-setting and
policy formulation powers (Hartlapp et al., 2014; Reh et al., 2020) and on the
role of consultations in the EU system of governance (Bunea, 2017; Binderk-
rantz et al., 2021). We contribute in three ways. First, we build an argument
explaining the importance of the dimensional structure of the policy space
describing consultations as instruments of information transmission and pre-
ference aggregation in bureaucratic policymaking. We focus on online consul-
tation surveys, which are one of the most frequently used approaches to
conduct public consultations. We discuss the implications of the structure
and dimensionality of policy spaces for interest representation and respon-
siveness in public policymaking and in relation to the literature on spatial
models of politics and party competition. Second, with the help of Specific
Multiple Correspondence Analysis (SMCA) we examine a novel dataset that
allows us to investigate the dimensional structure of the policy space across
consultations and policy areas. To our knowledge, this constitutes one of
the first attempts to map and investigate the policy space of consultations
on a large scale and comparatively, across policy-domains. Third, we contrib-
ute to the literature on the dimensionality of the EU policymaking by focusing
on an actor and a level of analysis (i.e., the EC and stakeholders’ participation in
open public consultations) that remains unexamined in the existing research
which focused predominantly on other actors such as citizens, national and
European political parties, and social movements (Marks & Steenbergen,
2002, p. 888). Thus, we address Marks and Steenbergen’s call for analysing
the dimensionality of the EU political system across a variety of actors,
which will contribute towards discussions of and enable comparisons and
assessments of whether dimensionality is actor- and/or context-specific.
We find that most consultations display a low dimensional space, defined
by one or two main dimensions, although we also identify a handful of con-
sultations that present a relatively well-defined third dimension. Our results
reveal a unidimensional policy space for eight consultations, a two-dimen-
sional policy space for twenty-three consultations, a three-dimensional
 JOURNAL OF EUROPEAN PUBLIC POLICY 5

space for ten consultations, and a four-dimensional space for one consul-
tation. The amount of variance explained by the main dimensions varies
across consultations, from 44.6% to 93.6%. Unlike two-dimensional policy
spaces of party competition in which parties compete for citizens’ votes on
an economically left-right and a social liberal-conservative dimension
across democratic political systems (Benoit & Laver, 2006; Borang et al.,
2023), we find that the substantive content of identified dimensions for con-
sultation policy spaces varies greatly across consultations and cannot be sub-
sumed to a generalised form of space dimensionality. The most abstract
general pattern we observe is a more frequent presence of position align-
ments that refer to preferences for different policy instruments discussed in
each consultation, and a less frequent presence of dimensions structured
by position alignments referring to the regulatory regime. While the substan-
tive contents of the policy spaces are context and consultation-specific, they
tend on average to be structured by the alignments of stakeholders’ prefer-
ences for different sets of policy instruments used to achieve a regulatory
goal. As such, consultation policy spaces are regulatory policy spaces which
are more likely structured by stakeholders’ disagreements over policy instru-
ments and less over regulatory regimes.
When exploring the observed structural complexity of consultation spaces
in policy context through an additional regression analysis, we do no find sys-
tematic patterns of association between variables describing policy space
complexity and variables capturing policy input complexity (consultation-
level and stakeholder-level characteristics). The notable exception is the
number of survey items and the average number of words used per survey
question which are both negatively associated with the presence of low
dimensional spaces. This suggests that the observed dimensional structure
is to a very limited extent explained by consultation survey design, being
instead an indication of stakeholders’ disagreements on substantive policy
issues.

Consultations as instruments of information transmission and

preference aggregation
Criticised for their lack of input legitimacy and democratic credentials,
modern bureaucracies underwent in recent years a process of enhancing
and formalising their dialogue with policy stakeholders by developing institu-
tionalised forms of public policy engagement (Balla & Gormley, 2017). The
widespread use of online and offline stakeholder consultations is a conse-
quence of this process (OECD, 2022). A key implication is that bureaucracies
have direct access to a new type of information source that allows them to
tap into stakeholders’ expressed policy preferences and to learn about the
aggregate distribution of stakeholder support for different policy options.
6 A. BUNEA ET AL.

Access to this information further strengthens the informational advantage of

bureaucracies enjoy relative to their institutional counterparts (Moffitt, 2014),
while enhancing their institutional reputation and input, throughput, and
output legitimacy (Meier & O’Toole, 2006).
Identifying stakeholders’ preferences and understanding their aggregate
distribution is essential for bureaucracies to engage in responsive policymaking
and for stakeholders to shape the content of policies (Powell, 2004; Patty &
Penn, 2014). Public consultations facilitate the entry into the bureaucratic pol-
icymaking arena of a diversity of viewpoints and preferences that may other-
wise be unavailable or not easily accessible to non-elected bureaucratic
actors (West, 2005, p. 664). Their relatively low accessibility threshold, high pub-
licity and procedural predictability make public consultations easily available to
a wide range of stakeholders. For bureaucrats with limited time and infor-
mation-processing resources, the patterns of aggregate distribution of stake-
holder preferences are particularly informative. They allow policymakers to
better understand: which policy options enjoy the support of a majority of sta-
keholders; the nature and extent of conflict over policy alternatives amongst
affected interests; the extent to which compromise and conflict resolution is
possible during both policy formulation and decision-making; the risk of antag-
onising some stakeholders and of facing input and throughput legitimacy con-
testation; and the risk of stakeholder resistance to policy measures and non-
compliance during implementation and of facing output legitimacy challenges.
Consultations also help bureaucracies collect information about policy pro-
blems and practice-informed solutions. They therefore serve as both a
channel for information transmission and a tool for preference aggregation.
As for legislatures, the electoral system and political parties facilitate policy
representation by allowing parties and elected representatives to identify and
aggregate societal demands and preferences into (ideological) policy bundles
and to translate them into policy outputs via legislative decision-making
(Dalton, 2018). As for bureaucracies, consultations allow citizens and organ-
ised interests to communicate their preferences to policymakers. They
create a formal information channel through which societal preferences are
fed into elite decision-making. The responsibility of identifying, processing,
and aggregating preferences into bundles and translating them into policy
proposals belongs to bureaucratic decision-makers who enjoy the preroga-
tive of consulting stakeholders and formulating policy proposals.
The literature on social choice theory and spatial models of politics and
party competition (Hinich & Munger, 1994; Austen-Smith & Banks, 2005) high-
lights two fundamental conditions that must be met in order for parties and
political elites to ensure policy representation: the presence of clear, diver-
gent and salient (ideological) policy packages offered by parties and the pres-
ence of a well-defined and structured (ideological) policy space in which
voters can place themselves based on their policy preferences, so that they
 JOURNAL OF EUROPEAN PUBLIC POLICY 7

can identify parties and their policy programmes and vote ideologically (Best
& McDonald, 2011). This perspective on political and policy representation
emphasises first the importance of a ‘differentiation between political
parties on a single policy and ideological continuum’ (Dalton, 2008, p. 902).
Second, it highlights the importance of a clearly structured space, whose
dimensionality plays a key role in party competition and parties’ ability to
identify and respond to citizens’ demands and ensure policy representation
in environments with more than one dimension (Benoit & Laver, 2012).
For scholars of political parties and electoral competition, uncovering par-
simonious models of political spaces in which parties compete for votes
across a high number of specific policy issues is a central concern and
topic of debate. Existing research indicates that while parties compete on
specific issue dimensions (i.e., redistribution, regulation, minority rights, Euro-
pean integration, etc.), which vary in salience across parties and political
systems, these dimensions usually ‘correlate with the same underlying axis
of competition’ (Benoit & Laver, 2006). The implication is that party compe-
tition across different issue dimensions can usually be collapsed in and cap-
tured by a low-dimensional structure of policy spaces for party competition:
parties’ positions across specific issue dimensions usually correspond to and
load on one or two latent dimensions underlining their electoral competition.
As such, the literature speaks of party competition taking place in uni-dimen-
sional spaces defined by a general left-right dimension of broad ideology,
also referred to in the literature as the ‘super dimension’ (Rohrschneider &
Whitefield, 2012; Däubler & Benoit, 2022); or about two-dimensional spaces
in which competition takes place on an economic left-right dimension and
a socio-cultural (libertarian-authoritarian) dimension (Bakker et al., 2015); or
about a general left-right dimension seconded by a dimension specific to
the institutional or political context in which competition is studied (e.g.,
the power and scope of EU institutions in the EP cf. McElroy & Benoit, 2007).
This literature offers several key insights for our study: first, in real-world
politics, the presence of a multitude of discrete issue dimensions on which
political parties (and stakeholders) take positions create (infinitely) high-
dimensional policy spaces in which parties and other political actors
compete on a multitude of issue dimensions. Second, the empirical models
of these high-dimensional real-world issue spaces correspond to low-dimen-
sional empirical policy spaces of party competition. Third, the substantive
policy content of low-dimensional policy spaces is usually identified induc-
tively and not defined a priori since this content is context-dependent and
the literature still debates what is the substantive content of even well-estab-
lished representations of spatial politics and party competition such as the
‘super’ ideological left-right dimension (Benoit & Laver, 2006, p. 203;
Däubler & Benoit, 2022).
8 A. BUNEA ET AL.

Building on these observations, we contend that the value of consultations

as instruments of information gathering and preference aggregation in
bureaucratic policymaking depends largely on the dimensional structure
characterising their policy space. In other words, the usefulness of consul-
tations as information source depends on how clearly structured the policy
space describing individual consultations is regarding the number of policy
dimensions, their substantive content, and the location of different actors
in this space (Gabel & Hix, 2002, p. 934). Clearly structured, low-dimensional
spaces are more helpful in supporting policymakers to identify levels of
aggregate support for policy options as well as policy friends and foes.
Low-dimensional spaces are by implication less complex and therefore
more straightforward to use in understanding how different stakeholder
demands compete for decision-makers’ attention. Conversely, high-dimen-
sional spaces are a more complex representation of aggregate patterns of sta-
keholder preferences. They are also informationally more demanding and
strategically more difficult to manage by policymakers, and therefore they
may be less informative for policy formulation activities. Policymakers’ task
to identify majority support for policy options and reconcile substantive
differences in stakeholders’ preferences in a multidimensional space is signifi-
cantly more demanding than in a unidimensional one, requiring more time,
skills, and resources (Iversen & Goplerud, 2018). Majority equilibria are also
more difficult to identify, and they are less stable in a multidimensional
space (Humphreys & Laver, 2010). The creation of policy coalitions and policy-
maker-stakeholder policy alliances may also be more difficult to pursue in
multidimensional spaces (Thomson et al., 2004). High-dimensional spaces
increase the ambiguity about the feasibility and acceptability of policy sol-
utions among different constituencies of stakeholders and may add further
challenges to consensus-building and identifying compromise solutions
across dimensions. In short, clearly structured, low-dimensional policy
spaces help policymakers harness more the policy inputs and information
received as part of public consultations when these are used as
information gathering and preference aggregation instruments of demo-
cratic governance.
We note that this view on the informational value of consultations for
bureaucracies is underpinned by the assumption that policymakers are gen-
uinely interested in using consultations to identify stakeholder preferences
and to design policies that align with their preferences. We are however
aware that bureaucracies may also benefit greatly from high-dimensional,
unstructured, and therefore more ‘noisy’ consultation policy spaces when
their commitment to listen to stakeholder policy input is less genuine and
bureaucracies use consultations as window-dressing exercises. In this scen-
ario, high-dimensional and more complex consultation policy spaces favour
bureaucratic actors as agenda-setters: they can more easily impose their
 JOURNAL OF EUROPEAN PUBLIC POLICY 9

most preferred policy solutions in the absence of clear or stable majority equi-
libria over policy options and outcomes.
We consider our assumption that policymakers are genuinely interested in
consultations and stakeholders’ preferences to be a reasonable one based on
several grounds. First, from a democratic legitimacy and accountability per-
spective, the reputational costs of ignoring the information gathered via
public consultations that are transparent and visible to external audiences
(i.e., stakeholders and institutional counterparts) is high for non-elected
bureaucratic policymakers (Balla & Gormley, 2017; Rose-Ackerman, 2021).
Conversely, the reputational benefit of being seen as responsive to and
inclusive of stakeholders’ policy inputs and preferences consolidates input
and throughput legitimacy (Bunea & Nørbech, 2023). This is especially rel-
evant in the context of EU policymaking, our empirical testing ground,
where bureaucratic decision-makers have been often criticised for being
remote from and not engaged with the policy preferences of the European
public broadly defined. For them, organising consultations and having the
opportunity to report on their results when introducing new policy initiatives
or reviewing existing legislation represents a valuable opportunity to legiti-
mise their policies and decision-making. Second, the idea of systematic infor-
mation gathering, and preference aggregation lies at the core of evidence-
based policymaking which traditionally underpins bureaucratic decision-
making (Bunea & Chrisp, 2023). Furthermore, from a cost–benefit analysis per-
spective, given the non-negligeable administrative and human resources
invested in organising consultations and processing the policy inputs
received, it is reasonable to argue that bureaucracies have strong incentives
to pay attention to and consider the information received in consultations.
Fourth, implementing policies that were not discussed with and informed
by affected parties during the policy formulation stage through stakeholder
consultations might prove difficult and challenging as affected parties may
consider that these policies lack input and throughput legitimacy and there-
fore refuse to comply (Thomson et al., 2020). Therefore, bureaucratic policy-
makers have strong incentives to genuinely listen to stakeholders’ inputs
during the policy formulation stage to ensure a smooth policy
implementation.

The policy space of EU public consultations: dimensions,

content, and structure
The principles governing the EU stakeholder consultation regime are
outlined in the EC’s Better Regulation guidelines. These guidelines indicate
that policymakers use consultations to ‘gather inputs from a broad range
of stakeholders through different instruments’ while emphasising that
consultations constitute a relevant source of factual data for ‘understanding
10 A. BUNEA ET AL.

views and opinions’ (EC, 2017, p. 396). This attests the quality of EU consul-
tations as channels of information transmission. The guidelines also refer to
consultations as a tool for aggregating stakeholders’ preferences. They
require supranational policymakers to ‘aggregate at an appropriate level sta-
keholders’ answers and contributions to public consultations’ and to ‘cluster
[the] information’ received as input. The practice of aggregating stakeholders’
preferences through consultations is further attested by the explanatory
memoranda accompanying the Commission’s draft policy proposals sent to
its legislative counterparts, the Council, and the European Parliament: they
explicitly mention the aggregate levels of support different policy options
received on behalf of stakeholders participating in consultations preceding
the proposal. This supports our description of EU consultations as tools of
information transmission and preference aggregation.
Despite the prevalence of consultations in EU policymaking and the wide-
spread recognition that they are key venues for lobbying and interest groups’
competition for decision-makers’ attention, a systematic investigation of the
structure of the policy space(s) describing stakeholders’ inputs to consul-
tations across policy areas is currently missing. The handful of studies addres-
sing this topic discussed the dimensionality of the consultation policy space
and its implications for the methodology of research on EU interest groups
employing automated text analysis techniques. These contributions are
single-case studies that used stakeholders’ policy position documents as
data source to identify issues and stakeholder preferences. Using qualitative
or quantitative text analysis, they found that the analysed consultations dis-
played a two-dimensional policy space and the substantive content of dimen-
sions varied across consultations. For example, Bunea and Ibenskas (2015:, p.
44) showed that in the 2007 EC consultation on the reduction of CO2 emis-
sions from passenger cars, stakeholders’ preferences expressed in relation
to ten discrete policy issues resulted in a two-dimensional space. The first
dimension captured ‘the stringency of the regulatory regime aimed at redu-
cing emissions with the help of ‘fuel efficiency measures’’ (supply-side regu-
latory measures). The second dimension captured the fiscal and marketing-
oriented measures aimed at shaping consumers’ behaviour when purchasing
fuel-efficient cars (demand-side regulatory measures). Klüver and Mahoney
(2015) analysed the same consultation from the perspective of stakeholders’
frames, using a different methodological approach (text analysis using clus-
tering and correspondence analysis). Their study confirmed the presence of
a two-dimensional space defined by stakeholders’ positions on environ-
mental regulation (dimension 1) and advertising regulation (dimension 2).
Both studies used an inductive approach to extract the latent dimensions
of the policy space.
Adopting a different approach that combined an inductive and a deduc-
tive strategy to identify the structure of stakeholders’ preferences in the
 JOURNAL OF EUROPEAN PUBLIC POLICY 11

consultation on the reform of the EU Better Regulation policy, Bunea and

Ibenskas (2017) showed that stakeholders’ preferences were structured
around three dimensions corresponding to stakeholders’ positions towards
deregulation, technocratic and participatory policymaking. Finally, adopting
a deductive approach, Bunea (2018) showed that stakeholders’ preferences
expressed in the consultation on the introduction of a mandatory Transpar-
ency Register for EU interest groups were structured around a two-dimen-
sional space: one dimension captured stakeholders’ evaluation of the
effectiveness of the proposed lobbying regulation regime and the other
dimension their assessment regarding its sustainability.
Building on the literature on spatial models of party politics and electoral
competition and EU lobbying and stakeholder participation in policymaking,
we derive the following set of expectations about the dimensional structure
of public consultation policy spaces. First, we expect to observe a low-dimen-
sional structure of the policy space for most consultations, with one or two
dimensions capturing the main alignments of stakeholders’ positions across con-
sultation issues (expectation 1).
In line with Laver and Benoit (2006), we note that high-dimensional spaces
are a frequent possibility in real-world policy events such as those described
by our stakeholder consultations. We argue therefore that the extent to
which the revealed consultation spaces fit the structure of a low-dimensional
or a high-dimensional space provides important insights about how complex
the revealed consultation policy spaces are. As such, we argue that policy
spaces with one or two well-defined dimensions that explain a high level
of variance in observed data present a significantly less complex structure
than policy spaces where more than two dimensions are identified as rel-
evant for describing the observed patterns of preference alignments in the
data.
Second, in line with the emerging literature on EU public consultations, we
expect for the substantive content of dimensions describing these low-dimen-
sional spaces to vary across consultation events and be context-specific (expec-
tation 2).
We note, however, that the existing literature examining the dimensional-
ity of the EU political space from the perspective of conflict in EU politics
identifies different models describing the substantive dimensions of
conflict. Summarising this literature, Marks and Steenbergen (2002) identify
four models. First, the ‘international relations (IR) model’ conceives contesta-
tion over EU issues on a single dimension capturing demand for more or less
European integration. In the liberal intergovernmentalist version of the IR
model, more integration is favoured by export-competing industrial sectors
while less integration is favoured by import-competing sectors (Moravcsik,
1998). Second, the ‘Hix-Lord model’ describes EU political contestation as
taking place along two independent dimensions: a left-right dimension
12 A. BUNEA ET AL.

summarising conflict over economic and socio-political issues and a pro-vs-

anti European integration dimension summarising conflict over national
sovereignty (Hix & Lord, 1997). Third, the ‘regulation model’ conceives of a
single dimension of contestation over EU issues, which is characterised by
left-wing support for more European regulation at one end of the dimension
and right-wing support for less European regulation at the other end of the
dimension (Tsebelis & Garrett, 2000). Finally, the ‘Hooghe-Marks model’ ident-
ifies two dimensions of contestation in EU politics, a left-right dimension, and
a pro-vs-anti European integration dimension, which are, however, neither
independent nor fused but rather related to each other (Hooghe & Marks,
1999). This literature indicates that policy spaces with related dimensions
are arguably less complex than policy spaces with independent dimensions
since, in the former, the positions of actors on one dimension will contain
information about their position on the other dimension. Figure 1 shows
the four models ordered by the complexity of the respective EU policy
space they conceptualise.
Based on this scholarship, we note that while we expect that the substan-
tive content of identified dimensions is context- and consultation-specific,
given that we analyse consultations organised by the EC as part of its (predo-
minantly regulatory) policy formulation processes, there is a reasonable
possibility that this context-specific substantive content speaks to a more
general, abstract and over-arching dimensionality theme that travels across
consultations and could be subsumed to the regulation model that broadly dis-
cerns between preferences for more vs. less regulation adopted at EU level
(expectation 3).

Figure 1. Models of contestation in EU politics.

 JOURNAL OF EUROPEAN PUBLIC POLICY 13

Research design
Case selection
We examine 42 EC public consultations organised between 2013 and 2018,
across all EU policy areas.1 We analyse stakeholders’ expressed preferences
in consultation surveys, which are directly available online to stakeholders
on the EC website. Table A1 in Appendix 1 provides an overview of the con-
sultation surveys in our sample, mentioning the consultation name, policy
area, number of participating stakeholders, number of survey questions,
number of policy-relevant survey items, and other pertinent information dis-
cussed below. Our sample includes consultations that: preceded important
policy initiatives; solicited stakeholders’ input on both technical and political
issues; were attended by relatively many stakeholders (although there is vari-
ation across consultations); included both interest groups and citizens; asked
for input on new initiatives or the review or evaluation of existing legislation.
We examine consultations whose number of participating stakeholders
ranges from as few as 34 stakeholders to as many as 66,579. This is consistent
with previous research that identified high variation in stakeholders’ partici-
pation across consultations and policy areas (Bunea & Thomson, 2015). Simi-
larly, our sample includes consultations asking for inputs on a varying
number of issues: the number of issues included ranges from 9 to as many
as 143. Thus, our sample captures well key features of EC consultations,
namely high variation in terms of participating stakeholders and number
and type of survey items.
The standard format of EC public consultation surveys includes questions
asking stakeholders about background characteristics such as their country of
residence for individuals or country of establishment for companies and
organisations, questions concerning their level of familiarity with different
policy issues as well as a set of questions asking about their policy prefer-
ences. Whereas the first category usually consists of closed-ended items,
the latter two categories entail predominantly closed-ended items but
often also a few open-ended ones. Open-ended items allow stakeholders
to add written comments substantiating their answers to previous closed-
ended items. We exclude from our analysis open-ended questions and
those about stakeholders’ background and level of familiarity with policy
issues because the former are difficult to analyse with our research design,
while the latter are less informative for our research goal. We analyse only
closed-ended items that asked stakeholders to express their preferences
regarding substantive policy issues. This strategy allows us to examine
empirically those survey items that are informative for our research questions
and comparable in substantive content. We consider each survey item to be a
discrete policy issue in relation to which the EC asks for stakeholders’ input, in
14 A. BUNEA ET AL.

line with existing research (Bunea, 2018). The closed-ended items can be
binary, nominal, and ordinal. Our consultations vary considerably regarding
the prevalence of these item types.
We further excluded those survey items that allowed stakeholders to
choose multiple response categories for two reasons. First, multiple-choice
items are rare in the selected surveys. Second, the recoding of multiple-
choice items into dummy variables would introduce a grouping structure
which cannot be straightforwardly accommodated by our method of analysis.
We also excluded from analysis the response categories indicating a ‘don’t
know’ or ‘no opinion’ since they do not provide relevant information for the
structuring of the policy space based on stakeholders’ substantive answers.
Furthermore, we excluded infrequent response-categories: all item-response
categories that were chosen by less than 5% of the stakeholders participating
in the consultation. We applied the so-called ‘5% rule’ for rare item-response
categories (modalities) which is suggested in the literature on MCA (Le Roux
& Rouanet, 2004, p. 216). Infrequent modalities can heavily influence the
determination of dimensions and therefore skew our results.

Analysing the dimensional structure and substantive content of the

consultation policy spaces
To examine the dimensionality and substantive content of the consultation
policy spaces, we follow Benoit and Laver (2006:, pp. 88–116) and utilise a
dimension reduction technique that is appropriate for the structure of our
data: Specific Multiple Correspondence Analysis (SMCA). This approach
allows us to systematically examine consultation surveys that present
several particularities: all surveys combine dichotomous, ordinal, and
nominal questions that we treat as nominal data; there are also some
missing values since stakeholders may choose not to engage with some ques-
tions; some response categories display low frequencies (Greenacre, 2007, p.
61). The decision to treat all survey items on a nominal scale implies infor-
mation loss for ordinal items but allows us to include different questions in
one analysis.
We use screeplots to identify the main dimensions describing a low-
dimensional space for each consultation. We employ the well-established
‘elbow’ rule (retain as relevant dimensions those that occur before the
elbow in the screeplot) (Greenacre, 2007) to decide how many SMCA-
extracted dimensions are necessary to define the low-dimensional space of
a consultation. All screeplots are presented in Appendix 2A. To examine
the substantive content of the retained dimensions, we adopt an inductive
approach (Benoit & Laver, 2006). We employ standard rules for selecting mod-
alities (response categories) that contribute towards defining the retained
SMCA dimensions: their contribution to variance, quality of representation
 JOURNAL OF EUROPEAN PUBLIC POLICY 15

and coordinate value (Le Roux & Rouanet, 2004). The inspection of biplots
and relevant modalities allows us to examine and identify the number of rel-
evant dimensions and their substantive content. Appendix 2B presents all
biplots.

Analyses
The dimensional structure of consultations policy spaces
Based on our SMCA analysis, we report the number of dimensions retained
for each consultation after applying the screeplot rule indicating how many
relevant dimensions fit our data pattern best. We report the number of
dimensions, the proportion of variance explained by each retained dimension
and their cumulative proportion of explained variance in the last two columns
of Table A1 in Appendix 1.
Consistent with our first expectation, the SMCA results show that 31 of the
42 consultations (73.8% of cases) display a low-dimensional policy space
defined by either one or two main dimensions (Figure 2).
Eight consultations display a policy space structured around one main
dimension that accounts for a significant percentage of the explained var-
iance in stakeholders’ responses, ranging between 66% and 93.6%. The
average value of explained variance across uni-dimensional consultations is

Figure 2. Number of main dimensions across consultations and the amount of variance
explained by each dimension.
16 A. BUNEA ET AL.

84.6%, capturing more than four-fifths of the variation in the patterns of

responses.
Figure 3 illustrates the case of a uni-dimensional policy space for the con-
sultation on rules of the imported cultural goods (consultation 39). The main
dimension accounts for 66% of the explained variance in responses and is
defined by preferences expressed against the adoption of new customs
rules that would regulate the imports of illicit goods (defining the positive
pole) and preferences supporting the introduction of such custom rules
(defining the negative pole).
Twenty-three consultations present a policy space structured around two
main dimensions. Their cumulative explained variance ranges from 44.6% to
96.8%. Fourteen of these two-dimensional spaces display a prominent first
dimension that explains more than 50% of variance, ranging between
53.6% and 79.2%. The second dimension is less prominent, explaining
between 11.3% and 36.6% of variance.
For nine of the two-dimensional consultations, the first dimension explains
less variance, ranging between 30.6% and 48%. Within this subset, three con-
sultations display a policy space in which the first and second dimensions
explain an almost equal amount of variance and are equally relevant in

Figure 3. Biplot of a uni-dimensional space for the consultation on rules on the import
of cultural goods (consultation 39).
 JOURNAL OF EUROPEAN PUBLIC POLICY 17

defining the structuring of the policy space. This is the case of the consul-
tations on the initiative to limit industrial trans fats intakes in the EU (21),
on EU citizenship (26) and on the revision of the EU regulation on explosives
precursors (30). For the remaining six consultations in this sub-group, the
differences in the amount of variance explained by the first and second
dimensions are somewhat more pronounced but less so relative to the four-
teen two-dimensional consultations with a prominent first dimension. These
differences underscore that the structuring of two-dimensional spaces takes
different forms, and those with a prominent first dimension may resemble
more the structuring of uni-dimensional spaces.
Figure 4 illustrates the two-dimensional policy space for the consultation
on fake news and online misinformation (consultation 6). The policy space
is defined by a prominent first dimension accounting for 75.6% of explained
variance and a second-dimension accounting for 12% of variance. Dimension
1 discerns between preferences against the harmonisation of current prac-
tices at EU-level regarding the fight against fake news and online misinforma-
tion (positive pole) vs. preferences supporting the introduction of more EU-
level regulatory and actively punitive measures to reduce misinformation
(negative pole). Dimension 2 discerns between stakeholders concerned

Figure 4. Biplot of a two-dimensional policy space for the consultation on fake news
and online misinformation (consultation 6).
18 A. BUNEA ET AL.

about the impact of fake news on economic and technological aspects (posi-
tive pole) vs. stakeholders concerned about the impact of fake news on the
political aspects (negative pole).
Ten consultations present policy spaces defined by three main dimen-
sions according to our SMCA analysis, while one consultation displays a
policy space structured around four dimensions. While the total cumulative
variance explained by these dimensions ranges from 49.3% to 95.1%, the
individual contribution of each dimension to the overall percentage of
explained variance is rather low, indicative of a more fragmented and
complex policy space. Take for example the most extreme case: the consul-
tation on the EU ecolabel for fishery and aquaculture with four main
dimensions. Dimension 1 accounts for 32.8%, dimension 2 for 21.4%,
dimension 3 for 13.8%, and dimension 4 for 12.1% of explained variance.
Together, they account for 80.1% of explained variance, which is an
accepted threshold to fit well the data in the methodological research
on SMCA (Le Roux & Rouanet, 2004, p. 51). Appendix 3 presents the sub-
stantive interpretation of these dimensions. It indicates that dimension 1
was defined by stakeholders’ support vs. opposition towards the idea
that ecolabels were useful for fishery products. Dimension 2 discerned
between stakeholders appreciating the positive impact of ecolabelling of
fishery products on sustainability and consumer confidence vs. stake-
holders supporting ecolabels but indicating that consumers may not
know what ecolabels mean. Dimension 3 was defined by positions for
vs. against the idea of EU-level regulated standards for the ecolabelling
of fisheries and aquaculture products. Dimension 4 was defined by stake-
holders supporting ecolabelling and believing they improve animal welfare
standards vs. stakeholders highlighting that consumers may struggle to
choose an ecolabel but agreeing that there are a set of market-related
advantages of using it.
Overall, the predominance of low-dimensional policy spaces structured
around one or two main dimensions speaks of consultations that remind
the reader about the uni- or two-dimensional policy spaces describing the
classic models of party competition. Two-dimensional spaces are more fre-
quent in our analysis. This finding is consistent with previous case-study
research analyzing EC consultations (Bunea & Ibenskas, 2015; Klüver &
Mahoney, 2015) and contributes to previous debates about the uni- or
two-dimensional nature of the consultation policy spaces in which interest
groups compete for influence over the formulation of EU legislative propo-
sals. In terms of their structure, consultation policy spaces display a level of
complexity similar to those described by party competition. However, a rel-
evant aspect in assessing policy space complexity is the substantive
content of identified dimensions, to which we turn next.
 JOURNAL OF EUROPEAN PUBLIC POLICY 19

The policy content of dimensions

To identify the substantive policy content of dimensions structuring the con-
sultation policy spaces we adopt an inductive approach by identifying the
response categories that contribute towards defining the positive and nega-
tive poles of the retained SMCA dimensions for each consultation and by con-
sidering their contribution to variance, the quality of representation and their
coordinate value (Le Roux & Rouanet, 2004). Section 2 of Appendix 3 details
the top three response categories contributing towards the definition of the
positive and the negative poles defining the main dimensions and a detailed
substantive interpretation of the dimension. Table A1 in Appendix 3 presents
a concise summary of this interpretation.
We observe several relevant patterns. First, the specific substantive
content of each dimension varies, and it is consultation-specific. This is con-
sistent with our second expectation and the findings of previous case study
research on EU public consultations (Bunea & Ibenskas, 2015). It highlights
the significance of policy context in understanding stakeholder participation
in policymaking (Klüver et al., 2015), and provides additional empirical
insights about the dimensionality of the EU policy space (Marks & Steenber-
gen, 2002). Indeed, for the EC’s policy formulation and consultation processes
(a previously under-researched institutional actor in this literature), this
dimensionality is very much context-specific.
Second, when applying a classic distinction made in the literature on
regulatory governance between regulatory regime orientation (overall
goals and policy objectives) and regulatory regime organisation (measures
and policy instruments used to achieve the regulatory goals) (Levi-Faur,
2011, p. 13) to interpret the substantive meaning of identified dimensions,
we notice that most dimensions are defined by position alignments
expressed towards policy instruments (63 of the 88 dimensions), while
only few concern the regulatory regime (20 dimensions). An illustration
for the first category is the consultation on non-financial reporting guide-
lines (consultation 20). Here, dimension 1 is defined by position alignments
distinguishing between preferences for a minimalist and narrower in scope
specification of policy guidelines vs. preferences for a more detailed and
comprehensive in scope specification of guidelines. An example for the
second category is dimension 1 of the consultation on the retail energy
market (consultation 13), defined by preferences supporting the regulatory
status quo (positive pole) vs. preferences demanding new regulatory
measures and criticising the competitiveness of the energy retail market
(negative pole). The predominance of dimensions defined by position align-
ments related to policy instruments is not surprising given that public con-
sultations are usually organised as part of the policy-shaping phase of the
20 A. BUNEA ET AL.

EU policy formulation process when ‘alternative policy instruments’ are con-

sidered to ‘tackle a given policy issue’ (Lelieveldt & Princen, 2023, p. 226).
This finding is consistent with our third expectation positing that although
consultation-specific, the substantive content of identified dimensions
describing the policy spaces speaks to a more general, over-arching theme
corresponding to a regulatory model of EU politics and policymaking. While
most spaces are structured by different preferences for regulatory/policy
instruments, oftentimes the choice between different policy instruments is
informed by the extent to which an actor prefers different forms and levels
of regulation. As such, we argue that implicitly or explicitly most unveiled con-
sultation policy spaces are fundamentally regulatory policy spaces.
This implies that the observed consultation policy spaces are closer to the
‘regulation model’ of contestation in the EU which was reviewed in our theor-
etical section (Tsebelis & Garrett, 2000). Some important qualifications are
however necessary. First, the left-right ideological underpinning that accom-
panies the Tsebelis and Garrett ‘regulation model’ is largely absent or at least
not obvious in consultations because these are organised in the bureaucratic/
executive arena, involve policy (stakeholders) and not political actors (politi-
cal parties), and include numerous technical issues on which stakeholders’
positions are more likely to be informed by policy experience and expertise
rather than ideology. Second, only some dimensions explicitly relate to pre-
ferences for more vs. less EU-level regulation, a scenario that taps directly into
the classic ‘regulation model’ of EU contestation that equates more regu-
lation with further EU integration. Most dimensions capture instead stake-
holder disagreements over how to achieve regulation once the EC decided
to introduce a legislative initiative and established the regulatory goals.
This is consistent with previous case-study research examining the structure
and dimensionality of policy debates describing EC stakeholder consultations
(Bunea & Ibenskas, 2015; Klüver & Mahoney, 2015) and reflects the fact that
online public consultations are more frequently used as policy formulation
and less as agenda-setting tools in the EU system of regulatory governance.
Third, we observe that while on most dimensions the position alignments
describe opposing preferences, for others they are defined by preference
intensity and not their substance. For example, dimension 2 of the consul-
tation on EU marketing standards for fishery and aquaculture products (con-
sultation 28) is defined by positions expressing moderate support for the
extension of common marketing standards vs. positions expressing strong
support for this extension. This highlights a specificity of the consultation
policy spaces: sometimes they are defined by preference intensity, not prefer-
ence opposition. This shows the value of consultations as channels of
information gathering and preference aggregation that allow policymakers
to get access to nuanced and detailed information about the degrees of sta-
keholder support for different policy instruments. This enhances their ability
 JOURNAL OF EUROPEAN PUBLIC POLICY 21

to identify in a more fine-grained manner solutions that constitute more

stable or more desirable policy equilibria. In this respect, public consultations
offer policymakers access to unique information about how to fine tune their
policy proposals and identify optimal policy solutions that may otherwise be
unavailable to them or in short supply.
Concerning the substantive content of policy dimensions, our findings
reveal that significant complexity characterises consultation policy spaces.
The importance of consultation-specific contents of dimensions indicates
that stakeholders’ demands compete for policymakers’ attention on a case-
by-case basis and on specific, well-defined, and usually policy instruments-
related issues. While this should not negatively impact policymakers’ task
of information gathering and preference aggregation on a consultation-
by-consultation event basis, it does raise the challenge of doing this at
policy area level or understanding the broader patterns of stakeholders’ com-
peting demands across consultations, initiatives, and policy areas. Therefore,
we underline that the substantive content of policy dimensions is an impor-
tant source of complexity for consultation policy spaces even when these are
low-dimensional.

Additional analyses: contextualising the dimensional structure of

consultations’ policy spaces
To deepen our understanding of the dimensional structure of consultation
policy spaces, we explore whether there is a systematic pattern of association
between indicators of space dimensionality (low vs. high-dimensional spaces
and the amount of variance explained by the first two dimensions) and key fea-
tures of consultation survey and stakeholder participation. This builds on the
intuition that consultation design and stakeholder participation may shape
the dimensional structure. Appendix 2C presents the operationalisation of
these variables. Logistic models examine the probability of observing low vs.
high-dimensional spaces (more than two dimensions), and Beta regressions
examine the amount of variance explained by the first two dimensions.
Given the small sample size, we examine survey indicators and stakeholder
characteristics separately, including consultation type as a control.
Figure 5 presents the results as standardised estimates (Odds Ratios). In
the logistic models (1.1 and 1.2), no explanatory variable is systematically
associated with the probability of observing a low or a high-dimensional
space, although the number of survey items almost reaches statistical signifi-
cance at 10% level. The Beta models indicate that the number of survey ques-
tions is negatively associated with the amount of variance explained by the
first two dimensions (model 2.1), while the number of respondents is posi-
tively associated with it (model 2.2). These are statistically significant at 5%
and 10% levels.
22 A. BUNEA ET AL.

Figure 5. Co-variation between space dimensionality, survey design and stakeholder

participation. Note: coefficients represent odds ratios.

Figure 6 shows predicted values of low-dimensional policy space con-

ditional on each covariate across models. In model 1.1, as the number of
survey questions increases, the probability that a consultation shifts from
low- to high-dimensional space also increases. Conversely, in model 2.1,
the downward predicted slope indicates that as the number of questions
increases, the amount of explained variance by the first two dimensions
decreases. This relationship is intuitive and theoretically plausible: more ques-
tions are more likely to cover a broader range of policy aspects, thus increas-
ing complexity. The same logic applies to the average number of words per
survey item, the second statistically significant variable in model 2.1. As the
length of a survey question increases, the probability of observing a high-
dimensionality consultation space also increases.
Among stakeholder characteristics, only the number of stakeholders is sys-
tematically associated with the observed dimensionality (Beta models).
Higher participation does not increase the dimensionality of the space but
instead helps structuring it around one- or two-dimensions accounting for
a high amount of variance. Given the huge variation in the stakeholder
number (minimum 34; maximum 66,579), the substantive interpretation of
the log scale is not straightforward. When predicted values are transformed
back, the effect of additional stakeholders on the explained variance
 JOURNAL OF EUROPEAN PUBLIC POLICY 23

Figure 6. Predicted values of low dimensionality conditional on survey design and sta-
keholder participation.

decreases after a certain threshold. In model 2.2, the steepest increase is

observed up to about 500 stakeholders. Above this, the marginal contribution
of additional stakeholders diminishes considerably.
The observed dimensional structure correlates only to a limited extent to
consultation design characteristics, indicative that this structure reflects
instead stakeholders’ disagreements over substantive issues.
Interest diversity, polarisation between business and non-business interests,
and consultation type do not explain the dimensional structure. Nevertheless,
despite the lack of statistical significance, consultations on new initiatives
increase the probability of observing a high-dimensional space relative to
consultations on evaluations and reviews (logistic models) and, conversely,
a lower probability of observing a space where one or two dimensions
explain high levels of variance.

Conclusions
We asked two important yet currently neglected questions in the research on
democratic governance and stakeholder participation in policymaking: what
24 A. BUNEA ET AL.

is the dimensional structure of the policy space of stakeholder consultations

and how complex is it? Building on the scholarship on social choice and
spatial models of politics and party competition, we explained why these
questions are important for understanding the role of public consultations
as instruments of information transmission and preference aggregation in
bureaucratic policymaking. We discussed how their informational value
depends on the structure and dimensionality of their policy spaces and
how it may affect policymakers’ capacity to understand the aggregate distri-
bution of stakeholders’ preferences and identify majority support for policy
options. Building on the limited literature on EU lobbying that touches
upon the issue of consultation policy spaces and the more established litera-
ture on the dimensionality of the EU political space, we derived three theor-
etical expectations which are all supported by our findings.
We find that most consultations examined display a low-dimensional
policy space, defined by one or two dimensions, in line with our first expec-
tation. This finding is consistent with previous case-study research using a
different data source (stakeholders’ policy position documents) (Bunea &
Ibenskas, 2015; Klüver & Mahoney, 2015) and provides relevant empirical evi-
dence based on a large-N analysis to previous debates about the dimension-
ality of the consultation policy spaces in which interest groups compete for
influence over the content of EC policy proposals. Specifically, our findings
show that while consultation policy spaces are low-dimensional, they are
infrequently unidimensional. In line with our second expectation, we find
that the substantive policy content of these dimensions is consultation-
specific. However, viewed through the conceptual lenses of regulatory gov-
ernance, this substantive content speaks to a broader regulatory model of
EU politics and policymaking, in which policy conflict revolves around the
policy instruments used to achieve certain regulatory goals. Consequently,
the unveiled consultation policy spaces are fundamentally regulatory policy
spaces. This finding is consistent with our third theoretical expectation.
Several implications follow from our findings. First, the predominance of
uni- and two-dimensional spaces across consultations suggests there are
certain similarities with the dimensionality of spatial models of party compe-
tition. Most importantly, this finding indicates that there is structure in stake-
holders’ policy preferences expressed as part of public consultations. This
suggests that even when consultations tackle many and diverse policy
issues and generate the participation of numerous and diverse stakeholders,
the aggregate distribution of preferences that structures the consultation
policy spaces provides policymakers with coherent information about stake-
holders’ preferences for different policy instruments and outcomes (see also
Marks & Steenbergen, 2002, p. 889 for a similar point about preferences for
EU integration). This observed structure enhances the quality of public consul-
tations as instruments of information gathering and preference aggregation.
 JOURNAL OF EUROPEAN PUBLIC POLICY 25

Second, while low-dimensional consultation spaces predominate, high-dimen-

sional spaces are an empirical possibility that policymakers should acknowl-
edge and account for in their decision-making. Likewise, researchers should
examine empirically the presence of high-dimensional spaces and consider
them as a theoretical and empirical possibility when developing theoretical
arguments explaining lobbying and interest groups competition in the
context of consultations used as lobbying venues. Third, the context-specific
substantive content of consultation policy spaces highlights that the value
and performance of consultations as information-gathering tools depends
largely on the expertise and specific-knowledge of the policymaker tasked
to analyse the aggregate distribution of stakeholders’ inputs channelled
through these consultations. Fourth, our study shows that the policy spaces
describing stakeholders’ participation in consultations are subsumed to a
more general model of regulatory governance, in which stakeholders disagree
most often about policy instruments and sometimes about the regulatory
regime. This finding is relevant insofar it highlights that across consultations,
stakeholders participate in an abstract ‘common policy space’ (Marks & Steen-
bergen, 2002, p. 889) describing public consultations and EU policy formu-
lation processes. The fact that this common policy space is regulatory in
nature indicates that the introduction of public participation in bureaucratic
decision-making (through public consultations) did not result in a politicisa-
tion of regulatory policymaking. Policy conflict continues to be structured
around key aspects for the EU regulatory state (how to achieve more and
better regulation) rather than by political/ideological dimensions.
We identify several extensions of our study and venues for future research.
A first extension is to examine whether and to what extent the observed pos-
ition alignments defining the policy dimensions are underpinned by a sys-
tematic pattern of stakeholder alignment that pits different types of
interests against each other or represent the preferences of a diverse set of
actors. This would add further insights into the importance of policy
conflict and/or lobbying coalitions for the structuring of consultation policy
spaces. A second extension is to investigate the institutional and behavioural
sources of the dimensional structure of consultation policy spaces. This would
further develop our short exploratory analysis and would contribute to our
knowledge about how institutional factors and patterns of participation
shape the dimensional structure of consultation policy spaces. A third exten-
sion is to analyse how the structuring of the consultation policy space shapes
the Commission’s responsiveness to the information and stakeholder inputs
gathered through public consultations. A fourth extension is to look at the
extent to which the observed structuring of the consultation policy spaces
impacts the Commission’s bargaining power in inter-institutional nego-
tiations and thus assess the broader policy consequences of the structuring
of consultation policy spaces.
26 A. BUNEA ET AL.

Note
1. We analyze a number of consultations similar to that used by Golden’s (1998)
classic study analyzing 42 consultation or Yackee’s (2015) study analyzing 36
consultations in the US policymaking.

Acknowledgements
The authors are grateful to Raimondas Ibenskas for his excellent comments and sug-
gestions regarding the scholarship on party politics and policy spaces of party com-
petition, and the reviewers for their insightful comments.

Disclosure statement
No potential conflict of interest was reported by the author(s).

Funding
This article is part of a research project that has received funding from the European
Research Council (ERC) under the European Union’s Horizon 2020 research and inno-
vation programme (ERC StG 2018 CONSULTATIONEFFECTS, grant agreement no.
804288). This funding is gratefully acknowledged.

Note on contributors
Adriana Bunea is a professor at the Department of Comparative Politics, University of
Bergen, Norway.
Reto Wüest was a postdoctoral fellow at the Department of Comparative Politics, Uni-
versity of Bergen, Norway.
Sergiu Lipcean is a research fellow at the Department of Comparative Politics, Univer-
sity of Bergen, Norway.

References
Austen-Smith, D., & Banks, J. S. (2005). Positive political theory II: Strategy and structure.
University of Michigan Press.
Bakker, R., et al. (2015). Measuring party positions in Europe. Party Politics, 21(1), 143–
152. https://doi.org/10.1177/1354068812462931
Bakker, R., Jolly, S., & Polk, J. (2012). Complexity in the European party space: Exploring
dimensionality with experts. European Union Politics, 13(2), 219–245. https://doi.
org/10.1177/1465116512436995
Balla, S., et al. (2022). Lost in the flood?: Agency responsiveness to mass comment
campaigns in administrative rulemaking. Regulation & Governance, 16(1), 293–
308. https://doi.org/10.1111/rego.12318
Balla, S., & Gormley, W. T. (2017). Bureaucracy and democracy: Accountability and per-
formance (4th ed.). CQ Press.
Benoit, K., & Laver, M. (2006). Party policy in modern democracies. London: Routledge.
 JOURNAL OF EUROPEAN PUBLIC POLICY 27

Benoit, K., & Laver, M. (2012). The dimensionality of political space: Epistemological
and methodological considerations. European Union Politics, 13(2), 194–218.
https://doi.org/10.1177/1465116511434618
Best, R. E., & McDonald, M. D. (2011). The role of party policy positions in the operation
of democracy. In R. J. Dalton, & C. J. Anderson (Eds.), Citizens, context and choice:
How context shapes citizens’ electoral choices (pp. 79–102). Oxford University Press.
Binderkrantz, S. A., Blom-Hansen, J., & Senninger, R. (2021). Countering bias? The EU
Commission’s consultation with interest groups. Journal of European Public Policy,
28(4), 1350–1763.
Borang, F., Naurin, D., & Polk, J. (2023). Making space: Citizens, parties and interest
groups in two ideological dimensions. Journal of European Public Policy, (https://
www.tandfonline.com/doi/full/10.108013501763.2023.2182819).
Bunea, A. (2017). Designing stakeholder consultations: alleviating or reinforcing bias in
the European Union system of governance?. European Journal of Political Research,
56(1), 46–69.
Bunea, A. (2018). Legitimacy through targeted transparency? Regulatory effectiveness
and sustainability of lobbying regulation in the European Union. European Journal
of Political Research, 57(2), 378–403. https://doi.org/10.1111/1475-6765.12231
Bunea, A., & Chrisp, J. (2023). Reconciling participatory and evidence-based policymak-
ing in the EU better regulation policy: Mission (im)possible? Journal of European
Integration, 45(5), 729–750. https://doi.org/10.1080/07036337.2022.2144848
Bunea, A., & Ibenskas, R. (2015). Quantitative text analysis and the study of EU lobbying
and interest groups. European Union Politics, 16(3), 429–455. https://doi.org/10.
1177/1465116515577821
Bunea, A., & Ibenskas, R. (2017). Unveiling patterns of contestation over better regu-
lation reforms in the European Union. Public Administration, 95(3), 589–604.
https://doi.org/10.1111/padm.12335
Bunea, A., & Lipcean, S. (2023). ‘Understanding patterns of stakeholder participation in
public commenting on bureaucratic policymaking. Evidence from the European
Union. Regulation & Governance. Online First: https://onlinelibrary.wiley.com/doi/
10.1111rego.12551.
Bunea, A., & Nørbech, I. (2023). Preserving the old or building the new? Reputation-
building through strategic talk and engagement with stakeholder inputs by the
European Commission. Journal of European Public Policy, 30(9), 1762–1792.
https://doi.org/10.1080/13501763.2022.2099450
Bunea, A., & Thomson, R. (2015). Consultations with interest groups and the empow-
erment of executives: Evidence from the European Union. Governance, 28(4), 517–
531. https://doi.org/10.1111/gove.12119
Dalton, R. J. (2008). The quantity and the quality of party systems. Comparative Political
Studies, 41(7), 899–920. https://doi.org/10.1177/0010414008315860
Dalton, R. J. (2018). Political realignment. Economics, culture and electoral change.
Oxford University Press.
Däubler, T., & Benoit, K. (2022). Scaling hand-coded political texts to learn more about
left-right policy content. Party Politics, 28(5), 834–844. https://doi.org/10.1177/
13540688211026076
European Commission. (2017). “Better Regulation Tool Box” (Available at: https://ec.
europa.eu/info/law/law-making-process/planning-and-proposing-law/better-
regulation-why-and-how_en#documents) (Last Accessed: 16.09.2022).
Gabel, M., & Hix, S. (2002). Defining the EU political space. Comparative Political Studies,
35(8), 934–964. https://doi.org/10.1177/001041402236309
28 A. BUNEA ET AL.

Gailmard, S., & Patty, J. W. (2013). Learning while governing. Expertise and accountability
in the executive branch. University of Chicago Press.
Golden, M. M. (1998). Interest groups in the rule-making processes: Who participates?
Whose voices get heard? JPART, 8, 245–802.
Greenacre, M. (2007). Correspondence analysis in practice. Chapman & Hill.
Hartlapp, M., Metz, J., & Rauh, C. (2014). What policy for Europe? Power and conflict
inside the European commission. Oxford University Press.
Hinich, J. D., & Munger, M. C. (1994). Ideology and the theory of political choice.
University of Michigan Press.
Hix, S., & Lord, C. (1997). Political parties in the European Union. St. Martin’s.
Hooghe, L., & Marks, G. (1999). Making of a polity: The struggle over European inte-
gration. In H. Kitschelt, P. Lange, G. Marks, & J. Stephens (Eds.), Continuity and
change in contemporary capitalism (pp. 70–97). Cambridge University Press.
Humphreys, M., & Laver, M. (2010). Spatial models, cognitive metrics, and majority rule
equilibria. British Journal of Political Science, 40(1), 11–30. https://doi.org/10.1017/
S0007123409990263
Iversen, T., & Goplerud, M. (2018). Redistribution without a median voter: Models of
multidimensional politics. Annual Review of Political Science, 21(1), 295–317.
https://doi.org/10.1146/annurev-polisci-031016-011009
Junge, D., & König, T. (2007). What’s wrong with EU spatial analysis? Journal of
Theoretical Politics, 19(4), 465–487. https://doi.org/10.1177/0951629807080778
Klüver, H., et al. (2015). Legislative lobbying in context: Towards a conceptual frame-
work of interest group lobbying in the European Union. Journal of European Public
Policy, 22(4), 447–461. https://doi.org/10.1080/13501763.2015.1008792
Klüver, H., & Mahoney, C. (2015). Measuring interest group framing strategies in public
policy debates. Journal of Public Policy, 35(2), 223–244. https://doi.org/10.1017/
S0143814X14000294
König, T. (2018). Still the century of intergovernmentalism? Partisan ideology, two-level
bargains and technocratic governance in the post-Maastricht era. JCMS: Journal of
Common Market Studies, 56(6), 1240–1262. https://doi.org/10.1111/jcms.12738
Lelieveldt, H., & Princen, S. (2023). The politics of the European union. Cambridge
University Press.
Le Roux, B., & Rouanet, H. (2004). Geometric data analysis: From correspondence analy-
sis to structured data analysis. Kluwer.
Levi-Faur, D. (2011). Regulation and regulatory governance. In D. Levi-Faur (Ed.),
Handbook on the politics of regulation (pp. 3–24). Edward Elgar.
Marks, G., & Steenbergen, M. (2002). Understanding political contestation in the
European union. Comparative Political Studies, 35(8), 879–892. https://doi.org/10.
1177/001041402236297
McElroy, G., & Benoit, K. (2007). Party groups and policy positions in the European par-
liament. Party Politics, 13(1), 5–28. https://doi.org/10.1177/1354068806068593
Meier, K. J., & O’Toole, L. Jr. (2006). Bureaucracy in a democratic state: A governance per-
spective. Johns Hopkins University Press.
Moffitt, S. (2014). Making policy public: Participatory bureaucracy in American democ-
racy. Cambridge University Press.
Moravcsik, A. (1998). The choice for Europe: Social purpose and state power from Messina
to Maastricht. Cornell University Press.
OECD. (2022). Better Regulation Practices across the European Union 2022. https://www.
oecd.org/publications/better-regulation-practices-across-the-european-union-
2022-6e4b095d-en.htm. (Last Accessed: 02.01.2024.).
 JOURNAL OF EUROPEAN PUBLIC POLICY 29

Patty, J. W., & Penn, E. M. (2014). Social choice and legitimacy. The possibilities of
impossibility. Cambridge University Press.
Powell, B. G. (2004). The quality of democracy: The chain of responsiveness. Journal of
Democracy, 15(4), 91–105. https://doi.org/10.1353/jod.2004.0070
Proksch, S. O., & Lo, J. (2012). Reflections on the European integration dimension.
European Union Politics, 13(2), 317–333. https://doi.org/10.1177/1465116511435943
Reh, C., Bressanelli, E., & Koop, C. (2020). Responsive withdrawal? The politics of EU
agenda-setting. Journal of European Public Policy, 27(3), 419–438. https://doi.org/
10.1080/13501763.2020.1712453
Rohrschneider, R., & Whitefield, S. (2012). The strain of representation: How parties rep-
resent diverse voters in western and Eastern Europe. Oxford University Press.
Rose-Ackerman, S. (2021). Democracy and executive power. Policymaking accountability
in the US, the UK, Germany and France. Yale University Press.
Thomson, R., Boerefijn, J., & Stockman, F. (2004). Actor alignments in European Union
decision making. European Journal of Political Research, 43(2), 237–261. https://doi.
org/10.1111/j.1475-6765.2004.00153.x
Thomson, R., Torenvlied, R., & Judge, A. (2020). Incentives to comply: The impact of
national governments’ and stakeholders’ preferences on compliance with EU
laws. Journal of European Public Policy, 27(12), 1801–1818. https://doi.org/10.
1080/13501763.2019.1699593
Tsebelis, G., & Garrett, G. (2000). Legislative politics in the European Union. European
Union Politics, 1(1), 9–36. https://doi.org/10.1177/1465116500001001002
West, W. (2005). Administrative rulemaking: An old and emerging literature. Public
Administration Review, 65(6), 655–668. https://doi.org/10.1111/j.1540-6210.2005.
00495.x
Yackee, W. S. (2015). Participant voice in bureaucratic policymaking processes. JPART,
25, 427–444.
Yackee, W. S. (2019). The politics of rulemaking in the United States. Annual Review of
Political Science, 22(2), 1–2.19.