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West European Politics
ISSN: 0140-2382 (Print) 1743-9655 (Online) Journal homepage: http://www.tandfonline.com/loi/fwep20
Who consults? The configuration of expert groups
in the European union
Åse Gornitzka & Ulf Sverdrup
To cite this article: Åse Gornitzka & Ulf Sverdrup (2008) Who consults? The configuration
of expert groups in the European union, West European Politics, 31:4, 725-750, DOI:
10.1080/01402380801905991
To link to this article: https://doi.org/10.1080/01402380801905991
Published online: 19 Jun 2008.
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Citing articles: 64 View citing articles
Who Consults? The Configuration of
Expert Groups in the European
Union
A
˚SE GORNITZKA and ULF SVERDRUP
This article examines and explains the committee system of the EU as a crucial
property of the EU governance system using a database on the European Commission’s
experts groups. What is the extent of the expert consultative system? What is the
distribution of expert groups? Are these groups best understood as loose networks or do
they constitute a stable, well-established consultative system? We observe a
proliferation of expert groups over time and across sectors. They have become
permanent properties of the EU governance system; yet they are remarkably unevenly
distributed among different policy domains. Sectoral differentiation is accentuated by
weak horizontal coordination between the Directorates-General. We argue that this
heterogeneity is not only a result of deliberate design attempts and differences in policy
tasks, but also the result of differences in legal and administrative capabilities, as well as
the gradual development of different routines and norms among the DGs.
This article examines a crucial property of the European governance system.
The EU is frequently understood as a governance system characterised by a
strong degree of interpenetration of different levels of government and a
plethora of interactions between EU institutions, national and sub-national
administrations as well as organised non-state interests. The ubiquity of
different kinds of public policy networks or expert groups involved in
consultation, bargaining, deliberation and decision-making is believed to be
a prominent feature of the European governance system (Eising and Kohler-
Koch 1999; Kohler-Koch 1997; Kohler-Koch and Rittberger 2006).
Nowhere is this kind of multi-level governance system as evident as in the
numerous expert groups and committees of the EU. Such committees are in
some sense the epitome of the European multi-level governance system at
work. EU committees encompass an array of bodies that vary considerably
in what they do, how they are organised, what role they play in EU policy-
making and to which EU institution they are anchored. Several specific and
Correspondence Address: ase.gornitzka@arena.uio.no; ulf.sverdrup@arena.uio.no
West European Politics,
Vol. 31, No. 4, 725 – 750, July 2008
ISSN 0140-2382 Print/1743-9655 Online ª2008 Taylor & Francis
DOI: 10.1080/01402380801905991
detailed studies have provided information and insights regarding the
functions and dynamics of these public policy networks (Beyers and Trondal
2004; Christiansen and Larsson 2007; Egeberg et al. 2003; Larsson and
Murk 2007; Wessels 1997). Scholarly attention has been paid in particular to
the role of committees in overseeing the execution of EU rules by the
Commission (Dehousse 2003; Dogan 1997; Franchino 2000; Pollack 2003),
and there have been attempts to assess the extent to which committees and
consultative organs affect the democratic quality of the European Union
(Joerges and Neyer 1997; Rhinard 2002; Vos 1997).
1
The focus in this article is on the committees and groups organised by the
European Commission, i.e. its expert groups. New data are now available
that enable us to examine more critically the use of such committees in the
EU and to answer some basic questions related to this aspect of the EU
multi-level system. What is the extent of the expert consultative system?
What is the distribution of expert groups? Are expert groups distributed
equally across different policy fields, or is this form of multi-level
governance concentrated in some specific policy fields? Are these groups
best understood as loose networks in the sense that they are informal,
flexible, dynamic, temporary and ever-changing, or are they part of a more
formalised, organised, routinised and well-established consultation system?
Previous studies have not given clear answers to such questions. For
instance, Larsson and Trondal (2006) claim that not even the European
Commission itself has adequate knowledge of the scale and activities of the
expert groups.
2
In the absence of good data, scholars have been engaged in
making ‘guesstimates’, ranging from 800 to 1,300 groups (Larsson and
Trondal 2006) or vague statements such as ‘there are probably more than
1,000 committees’ (van Schendelen 1998: 5). The new quantitative data also
allow us to examine some rudimentary hypotheses that can shed light on the
pattern of distribution and the factors involved in creating, changing and
maintaining this part of the EU governance system. This article is the first
report from a larger and ongoing research project on the role of the expert
groups in the EU, in which we will also examine the participation and
sociometrics of this consultative system (Gornitzka and Sverdrup 2007).
Our approach is consistent with two recent calls in the literature on
European governance. First, Johan P. Olsen argued that better under-
standing of the levels and forms of European integration requires the
building of more detailed knowledge about institutional variations across
sectors (Olsen 2007). Second, there have been arguments for gradually
changing the research focus from explorative and descriptive case studies to
larger N studies and a stronger focus on empirical studies (Broscheid and
Coen 2007; Coen 2007; Franchino 2005). In addition to supporting such
calls, we believe that a systematic and structured cross-sector analysis of the
consultative system might help to provide meaning to the diverse and
competing statements being made about the qualities and functions of the
EU governance system.
726 A
˚. Gornitzka and U. Sverdrup
Our argument is that the expert groups play an increasingly important
role in the EU. We can observe a proliferation of this mode of governance
across sectors. We find that the use of expert groups has developed into a
routinised practice of the European Commission in order for it to connect to
its environment and bring together various state and societal actors.
Moreover, a great proportion of the expert groups have become permanent
and lasting properties of the governance system. However, our data also
show that the expert groups are remarkably unevenly distributed along
different policy domains and areas. Distinct policy segments have different
modes of connecting to their environment. While some areas are clearly
multi-level in their governance structure, others are not. The high degree of
sectoral differentiation is accentuated by the fact that we observe weak
horizontal coordinating structures between the Directorates-General (DGs)
in their use of expert groups. We argue that the heterogeneity in modes of
governance across policy fields is not only a result of deliberate design
attempts and differences in policy tasks, but also largely the result of
different institutional and organisational factors, such as legal and
administrative capabilities, as well as the gradual development of different
routines and norms for connecting to the environment.
The article is organised as follows: in the next section, we discuss two
theoretical perspectives that might explain the use of expert groups in the
EU and comment on our data and methodology. We then present an
empirical analysis of the distribution of the expert groups across time and
discuss factors that can explain the segmented pattern of consultation.
Towards the end of the article we show how our observations are further
strengthened by analysing the degree of specialisation and the degree of
institutionalisation of the consultative system.
Theoretical Approaches and Expectations
Expert groups are one of the three main types of committees organised by
EU institutions. Together with the Council working parties and committees,
and the comitology committees, they make up the EU’s committees system
(Hayes-Renshaw and Wallace 2006). Formally, an expert group is a
consultative entity comprised of public or private sector experts, and the
Commission is in control of its composition. Expert groups are comprised of
members from national governments, academia and various interest groups.
The main task of the groups is to advise the Commission on the preparation
of legislative proposals and policy initiatives as well as on its tasks of
monitoring and coordination or cooperation with the member states. Expert
groups do not formally make political decisions, but feed the decision-
making processes by giving expert advice, providing scientific knowledge,
sharing practical experience and information, and serving as forums for
exchange of information. The groups can be either permanent or temporary.
The Commission creates its expert groups itself, which is also a
The Configuration of Expert Groups in the European Union 727
characteristic that sets them apart from both the comitology and Council
committees. A Commission expert group may be created in two different
ways, either through a Commission decision or other legal act establishing
the group or by a Commission service with the agreement of the Secretariat-
General. Officially, the expert groups’ task is to assist the Commission as a
whole, but in practice the expert groups run by the DGs are mostly involved
with the relevant field.
In sum, the Commission’s committees constitute a highly complex system
that defies any easy categorisations
3
and does not have a well-articulated set
of rules to regulate its operations. Hence, we can expect to see multiple
factors that come into play in creating, changing and maintaining this part
of the EU governance system, some of which are singled out for analysis in
this article. Here we approach the issue of expert groups in the EU from two
perspectives; one emphasising the role of choice and design and the other
emphasising the role of routines and institutional factors (March and Olsen
1998; Olsen 1997; 2001; 2002; 2007).
Design Perspectives
From a design perspective, expert groups are basically viewed as
instruments for increasing effectiveness in decision-making. The European
Commission is often faced with tasks that have considerable technical,
political or legal uncertainty, and is therefore in need of assistance. By using
expert groups, the European Commission is able to extract knowledge,
expertise and information from actors in its task environments and
potentially improve the quality of its decisions and reduce uncertainty.
The participants in these groups bring relevant topics to the discussions,
indicate potential risks, and sometimes suggest modes for easing transposi-
tion and implementation. Expert groups can be used in direct linkage to
decision-making situations or as a tool for surveying and monitoring the
environment. The setting up of expert groups can be regarded as a relatively
risk-free strategy when entering into new or difficult territory. Typically one
could expect that the more uncertainty, the more room for a problem-
solving logic based on expertise (Radaelli 1999). From this perspective, it is
assumed that the European Commission would design and shape its expert
groups so that they correspond closely with its preferences and tasks. In
addition, we expect that the expert groups are flexible and easily adaptable
to new and changing tasks and preferences. Once the ‘mission is
accomplished’ the expert groups will be dismantled.
The policy task argument. It follows from this approach that as long as we
know and are able to identify the nature of the policy problem facing the
DGs we should be able to predict the organisational solution to decision-
making and thus the presence of expert groups. Although the idea is simple,
defining and operationalising the type of policy and nature of the policy
728 A
˚. Gornitzka and U. Sverdrup
good is notoriously difficult (Lowi 1964). We take as a starting point the
distinction between regulatory versus non-regulatory policies. This has had
a recurring significance for explaining the shape of EU decision-making
arenas and the relative power of EU institutions in general (Burns 2005;
Majone 1996: 61–79). The main idea we pursue is an assumption that
distributive policies will be subjected more often to consultations than other
policy types. The following underlying mechanism creates the rationale for
such a relationship.
When the services are engaged in managing large resources, they will have
a particularly great need for information stemming from their tasks to
ensure good design of their distributive policy, sound management of the
funds, and proper implementation. These needs cannot easily be fulfilled by
internal sources of information; hence the Commission services will pursue
an extrovert information strategy. Previous studies have also shown that the
European Commission often uses financial resources for stimulating
cooperation with member state governments and for mobilising sub-
national and non-state actors in transnational networks around joint
problem-solving activities, particularly in areas such as R&D, trans-
European networks and efforts to build a ‘People’s Europe’, which are
aimed at complementing market integration (Laffan 1997). It has also been
argued that the EU distribution that takes place under the common
agricultural policy has also been particularly prone to control by member
states and affected interests (Burns 2005). In order to find the concentration
of expert groups one should therefore ‘follow the money’. In principle, we
would expect that policy areas or Commission services that are responsible for
managing large sections of the budget would generate more expert groups than
services that are in charge of managing fewer budgetary resources (Hypothesis
1). In order to test Hypothesis 1, we sorted various policies according to
their share of the EU budget in 2006. In the EU most of the redistributive
portion of the budget is devoted to three policy areas: agriculture, regional
policy and the various social cohesion programmes.
Supply-side argument. Another, but related, version of this model is to
view the expert groups not as a result of careful design by the European
Commission, but rather as an instrument resulting from specific supply-side
pressures. The more the EU gets involved in a policy area, especially in
shaping policies, the more the actors tend to react by organising in order to
promote, protest or defend their interests. And by doing so they demand the
opportunity to participate in formulating problems and solutions, and
engage themselves in the production of new rules in consultative organs such
as the expert groups. Such processes of growth in involvement contribute in
turn to the creation of new initiatives and new areas of participation, and
thus to a dynamic of steadily increasing institutionalisation (Stone Sweet
et al. 2001). From this perspective, the emergence of expert groups is seen as
resulting from distinct pressures from different interest organisations or
The Configuration of Expert Groups in the European Union 729
national interests which regard the expert groups as their instrument for
influencing and controlling EU decision-making. We would expect a close
relationship between the profile of the expert group system and the supply-
side capacities. This kind of supply-side mechanism fits well with ideas of
lobbying in the EU (Broscheid and Coen 2007; Coen 2007; Mahoney 2004)
and with the observation made by Broscheid and Coen (2007) on an
independent effect of the number of interest groups in a certain policy field
and the establishment of consultative fora in different DGs. Their
underlying argument is that the Commission creates the largest number of
expert groups in areas overloaded with interest groups. In order to manage
this overload, DGs create expert groups and extend privileges to a limited
set of actors who have access to them. Hence, we expect to find that the more
interest groups are organised in a policy area at the European level, the more
the relevant DG will tend to create expert groups (Hypothesis 2). In order to
test this claim we included data on interest groups gathered from the so-
called Connecs base
4
and compared this with the number of expert groups
per DG.
Institutional Perspectives
An institutional perspective, by contrast, puts particular emphasis on the
importance of historical developments, path dependencies and routines
when explaining the patterns of distribution of the expert groups. It is
assumed that the expert system in the EU, like other institutions in political
life, depends not only on satisfying current environmental pressures and
political concerns, but it also reflects an institution’s origin, history and
internal dynamics (March and Olsen 1998). Rather than seeing expert
groups as carefully designed to meet specific tasks, the presence of expert
groups are regarded as reflecting local rationality, sectoral specialisation and
differentiated traditions and histories for relating to the environment.
Changes and developments often occur through multiple learning processes,
but not always in consistent ways (March and Olsen 1998). Rather than
expecting a smooth and well-planned distribution of expert groups, a patchy
picture is expected. This argument merges nicely with Kohler-Koch’s
observation that the EU is functionally segmented. She argues that the
governance system in the EU is largely a result of processes of incrementally
adding bits and pieces to the functional responsibilities of the Community.
The result of such processes is not close co-operation to assure coherence,
but rather patchwork policies in a highly segmented system (Kohler-Koch
1997), as well as a marked difference between DGs in their mode of policy-
making (Christiansen 1997).
From this perspective, expert groups are seen as mirroring the long-term
patterns of interactions between sectorally specialised DGs and their equally
specialised and differentiated environments, as well as reflecting internal
factors such as internal capacity, age of certain policy domains, and different
730 A
˚. Gornitzka and U. Sverdrup
norms, routines and experiences from consultation and cooperation that
have evolved across time. In addition, it follows from this perspective that
the use of expert groups over time has developed into a routinised activity
with a high degree of institutionalisation. With the present data we cannot
make a meaningful operationalisation of historical path dependency and
local administrative cultures, yet we incorporate into our analysis two
fundamental institutional conditions that determine an organisation’s
characteristics and that can be expected to account for the differences in
density of the DGs’ set of expert groups according to an institutional
perspective. First, we explore the significance of the legal competencies that
DGs operate under and then we look at the importance of their
administrative capabilities.
The legal competence argument. A common-sense interpretation we find in
some of the literature on EU governance is that the density of expert groups
is largely a function of the allocation of competence in the EU. For instance,
according to Nugent (2003: 130–131), ‘One factor making for variation is
the degree of the importance of the policy within the EU’s policy framework
– it is hardly surprising, for example that there should be many more
agricultural advisory committees than there are educational advisory
committees.’ If we define the degree of importance of a policy area as the
legal competence of the EU in the specific area, we can consider this
mechanism more in detail. In a simple version of this perspective, we can
expect this relationship to be linear: the more exclusive legal competence
allocated to the EU, the more expert groups (Hypothesis 3).
The underlying idea is that the level and intensity of activity of the
Commission are determined by the legal competence of the EU. Increased
activity in turn triggers the activation of expert bodies. When competence
is transferred from the national level to the European level, new
opportunity structures are created at the European level, and new patterns
of consultation emerge. The competence attributed to different policy areas
is the fundamental legal parameters within which the DGs operate,
independent of the budgetary means at the Commission’s disposal for
pursuing its policies. These competencies are unevenly distributed across
the DGs’ activity areas and have accrued to the European level at different
points in the history of European integration. In order to operationalise
this variable we have coded the policy fields according to treaty com-
petence, ranging from 1 to 4. The treaties differentiate between areas
of exclusive competence for the EU (coded as 1), areas of shared
competence (coded as 2), areas where the EU has coordinating compe-
tencies (coded 3), and areas of supporting and complimentary
competencies (coded 4).
5
The administrative capability argument. From an institutional perspective
we also expect that the administrative capacity of DGs will feature as a
The Configuration of Expert Groups in the European Union 731
possible explanation for the variation in the use of expert groups. The
European Commission consists of a small administration with limited staff
and administrative capabilities, particularly when compared with the size of
national governments. Still, there has been a continuous growth of new
tasks delegated to the European Commission and a de facto extension of the
basis for Community action. Expectations regarding the Commission’s
ability to manage new responsibilities and deliver results have also
increased. Balancing task expansion with limited administrative resources
has been an enduring theme in European governance. The expert groups can
be seen as a form of outsourcing and a mechanism for coping with limited
administrative capabilities. Participants in the expert groups can improve
the ability of the European Commission to develop policies and monitor
implementation by contributing their administrative resources and provid-
ing information, knowledge and expertise. Compared with establishing
permanent, specialised organisations capable of fact-finding, rule-making
and/or enforcement, such as by establishing European agencies or
Commission joint research centres, using expert groups incurs less cost for
Community budgets. Although expenses are reimbursed by the Commis-
sion, participating experts are unpaid. Consequently, the existence of expert
groups does not require long-term budgetary commitments. It follows from
such a perspective that we would expect there to be a relationship between
internal administrative resources and the use of expert groups. The smaller
the internal administrative staff that the DG has at its disposal, the more
expert groups it will create (Hypothesis 4). In order to test this hypothesis we
have gathered data on the size and distribution of the European
Commission staff.
Data and Methodology
The empirical analysis presented in this article relies on data from our
database of Commission expert groups. Our database provides information
on key properties of these groups, such as the lead services in the
Commission, the policy area and composition of the group in general terms,
as well as the group’s tasks and missions and their formal status. It classifies
the participants into broad categories (scientists, academics, practitioners,
industry, NGOs), but it does not contain any information on individual
experts, nor does it contain information on the number of meetings and
participation rates of the expert groups. When constructing the database we
used the European Commission’s register of expert groups. Information was
downloaded from the register, coded and entered into our database in
January 2007.
6
The register’s reliability as a source of information on expert groups is
underpinned by the formal rules of the register. The register is partly a result
of a commitment made by Commission President Barroso to the European
Parliament in November 2004 to increase the transparency of the
732 A
˚. Gornitzka and U. Sverdrup
Commission’s operations and give a public overview of the advisory bodies
that assist it in preparing legislative proposals and policy initiatives.
According to the ‘Framework Agreement on relations between the
European parliament and the European Commission’ (Article 16), ‘The
Commission shall inform Parliament of the list of its expert groups set up in
order to assist the Commission in the exercise of its right of initiative. That
list shall be updated on a regular basis and made public.’
7
As illustrated by
its codification in the framework agreement, the importance attached to the
registry for ensuring a constructive dialogue and flow of information
between the European Commission and the European Parliament increases
the reliability of the data. The Commission is formally obliged to enter
reliable information and update the register, functions which are performed
by permanent staff in the Secretariat General. The unit responsible
for the register of expert groups was consulted in the creation of our
database.
Distribution of Expert Groups
The Growth of Expert Groups
Our analysis shows that there were 1,237 expert groups organised by the
European Commission in January 2007. This is a large number, and it is
clearly in the upper range of previous estimates. The expert group system is
without doubt a considerable supplementary administrative resource of the
European Commission. In fact, there is about one expert group per eight
persons working as an official in the European Commission.
8
By
comparison there are 250 comitology committees and 162 Council
committees/working parties;
9
hence Commission expert groups far out-
number the other parts the EU committee system.
There has been a significant increase in the number of expert groups over
time. In 1975 it was reported that there were 537 groups, in 1990 the number
had increased to 602 (Wessels 1998), and by 2000 the number had reached
851 (Larsson 2003). These measures indicate gradual and steady growth
during the 25-year period, as new competencies and tasks have been added
to the European Commission and the European Union. It is noteworthy
that this gradual growth has been replaced by a more rapid and radical
increase since 2000. In this period the number of expert groups has increased
by more than 40 per cent.
10
The large number and the strong growth of the
use of expert groups in the European Commission contribute to making this
mode of interaction a significant element of the European governance
structure, and a routinised and rather standardised mode of consultation.
The extensive consultative structure also contributes to the impression of the
European Commission as an open, extrovert and accessible administrative
body, which is engaged in numerous consultations with a huge number of
actors from multiple levels of governance.
The Configuration of Expert Groups in the European Union 733
Uneven Distribution across Policy Domains and Commission Services
Although the presence of expert groups is widespread throughout the
European Commission, there are significant differences in the extent of
consultation in different policy areas. In our data, we find three clear
patterns regarding the distribution of the expert groups.
First, the expert groups operate primarily in the EU public policy
domains (Table 1). There are hardly any expert groups in the field of
internal administrative services, and there are few expert groups engaged
with the general services. Hence, the DGs related to administrative affairs,
budget and financial control, and the General Services such as the Legal
Service, General Secretariat and Press and Communication, which are
typically regarded as horizontally coordinating Directorates-General and
services in the EU (Stevens and Stevens 2001), score low on coordination
and cooperation with external experts. We also observe that very few (under
5 per cent) of the total number of expert groups are related to external
relations policies.
Secondly, the distribution of expert groups is biased and unevenly
distributed across the different DGs (Figure 1). More than 75 per cent of all
the expert groups in the Commission are related to ten DGs. The data fall
into three broad categories: DGs that organise many expert groups (more
than 70), DGs in the mid-range (between 70 and 20), and DGs with just a
few expert groups (fewer than 20). Within the first group we find three ‘super
users’, consisting of DG Research, DG Environment and DG Enterprise, all
having 120 or more expert groups. Taken together, these three DGs organise
approximately 30 per cent of all expert groups. In addition, DG Taxation
and Customs, DG Energy and Transport, DG Health and Consumer
Protection, Eurostat and DG Education and Culture all have more than 70
expert groups each. In the second category we find the DGs that are
responsible for what we might label ‘classic’ European affairs, such as
economic and social policy, agriculture policy, internal market, fishery
and regional policy. This biased distribution of expert groups clearly
indicates strong sectoral differentiation between different DGs in their
mode of governance. While extensive use of consultation with expert groups
is a prominent characteristic of some policy areas, such as research,
TABLE 1
COMMISSION EXPERT GROUPS ACCORDING TO POLICY DOMAIN. N¼1237
Count Valid percentage Cumulative percentage
Valid Policies 1,076 87.0 87.0
General services 99 8.0 95.0
External relations 54 4.4 99.4
Internal services 8 0.6 100.0
Total 1,237 100.0
734 A
˚. Gornitzka and U. Sverdrup
environment, energy and transport, this mode of governance is found much
more seldom in other areas, such as trade, competition, economic and
financial affairs.
A third striking feature regarding the distribution of the expert groups is
the changes in the number of expert groups across time.
11
As illustrated by
Figure 1, the overall trend is that there are more expert groups attached to
most of the various DGs now than seven years ago. Very few DGs deviate
from this pattern. In 2007, the median value was 27 expert groups per
service compared to 19 in 2000. During a seven-year period the number of
DGs with more than 80 expert groups has increased by more than 100 per
cent, and four of the DGs have more than doubled their number of expert
groups. The DGs that had the highest number in 2000 remain at the top in
2007, and we still observe considerable variation between the various DGs.
However, there is also a clear move towards less differentiated distribution,
indicating that this method of consultation and interaction between the
Commission and its environment is becoming more widespread and
standardised.
Explaining Uneven Distribution
What we have seen here is a strong sectoral differentiation in the DGs use of
expert groups. Why are there more expert groups in some policy domains?
What are the relevant dimensions of the policy sectors and political
FIGURE 1
COMMISSION EXPERT GROUPS ACROSS SERVICE AND TIME
Source: Own data from 2007, data on 2000 based on Larsson (2003). Some services with fewer than five
expert groups are excluded.
The Configuration of Expert Groups in the European Union 735
organisation that make such a difference for the way in which the
Commission relates to external expertise? Let us now assess how and to
what extent the four hypotheses can help to explain this pattern.
Task Matching – Policy Type Argument
Our data show that the DGs engaged in distribution do not have a large
number of expert groups. As we can see from Figure 2, the DGs that are most
involved in such polices, DG Agriculture, DG Regional Policy, DG
Employment and Social Affairs, and DG Research, which together account
for more than 85 per cent of the total EU budget, have only about 25 per cent
of the total number of expert groups, and DG Research accounts for half of
these. We can therefore conclude that our Hypothesis 1 is not supported.
However, the lack of support for our hypothesis could in fact be a
misspecification of the nature of the policy task. When we fail to see the
effect of distributive policy, it should not lead us to dismiss the idea that the
nature of the policy domain significantly affects the pattern of expert group
distribution.
In particular, one could argue that the Commission’s choice for
establishing a group is conditioned by the technical versus the political
nature of the task rather than whether or not the DGs are tackling
distributional or regulatory problems. One could also argue that the varying
intensity of political conflict in policy-specific interest constellations impinges
on the ability of the Commission to act (Scharpf 1999) and that international
FIGURE 2
RELATIONSHIP BETWEEN EU BUDGET PER SERVICE AND NUMBER OF EXPERT
GROUPS PER SERVICE
736 A
˚. Gornitzka and U. Sverdrup
cooperation and integration are easier to achieve in fields seen as being
technical with low intensity of political conflict. Technical issues typically
require expertise, and expertise tends to subordinate national boundaries
to shared professional concerns and epistemic communities (Haas 1992;
March and Olsen 1998). The literature on international coordination has
shown the crucial role of experts in political integration and transnational
governance in general and in the EU in particular. It can be argued that
regulatory policy rather than distributive policy is based on knowledge as
a resource and aims at efficiency rather than fair distribution. Conse-
quently, regulatory policy areas fit better in the realm of technocracy and
the world of expert groups, which is relatively insulated from political
conflict (Radaelli 1999).
12
Although we recognise the significance of this distinction for explaining
the variation in forms of consultation, we find it hard to operationalise and
use policy type as an independent variable. First, coding the policy types
according to their degree of technical specialisation requires detailed
knowledge of the activities of each expert group, which is unavailable in
our database. Using DG types as a proxy for ‘type of task’ is inadequate in
this respect. Secondly, additional substantive challenges are posed by the
fact that what is regarded as technical versus political issues changes over
time. Politically salient issues can be decentralised into technical arenas in
order to avoid politically sensitive conflicts. Sometimes policy labels shift as
a result of deliberate choice, for instance when an issue is being
‘decentralised’ to a technical level in order to avoid political conflicts (Olsen
1983: 208–209), or the other way around, when a rather technical issue
becomes highly politicised, for instance regarding stem cell research in the
EU 7th Framework Program or statistical measures in the case of EMU. In
other instances, the label attached to a policy can change rapidly as a result
of external events or sudden crisis, such as in the case of BSE and
Creutzfeld-Jacob disease. Studies of EU committee governance, in
particular working groups under the Council (Fouilleux et al. 2005), also
report that this distinction is continuously blurred and putative technical
working groups are heavily involved in dynamic processes of politicisation
and depoliticisation of public policy issues. If this is indeed the case, the
distinction between technical versus political policy domains cannot be used
as an independent variable for explaining the variation in the presence of
expert groups.
Supply-Side Argument
As we see from Figure 3, the strong correlation between the number of
interest groups and density of expert groups gives support to supply-side
explanations. Nevertheless, we are uncertain how plausible it is to make
conclusions about the causal mechanism of interest group overload based
on this significant correlation.
The Configuration of Expert Groups in the European Union 737
An alternative argument would be to say that it is the general level of
activity within the EU that generates both the presence of interest groups
and expert group density in different policy domains. It should also be noted
that a large share of Commission expert groups do not include interest group
participation (Gornitzka and Sverdrup 2007), and therefore their creation
can hardly be seen as the Commission’s means of managing interest group
overload. Rather it might be the case that the creation of expert groups
causes participatory overload as it opens up a ‘can of worms’ of potential
participants that are deemed relevant and legitimate, from 27 member states
and their respective national administrations, regional authorities, candidate
countries, EEA members, interest groups and academics. Furthermore,
there are some important DGs that deviate from the overall pattern. For
DG Research, DG Taxation and Customs and Eurostat and DG Regional
Policy, this correlation is not present. Rather than seeing the proliferation of
interest group organisations as the main trigger for the establishment of
expert groups, we would argue that the number of interest groups at the
European level reflects more general sectoral differences in political
organisation in Europe, as well as the fact that some policy areas are
considered more receptive to influence and input than others.
Legal Competence Argument
In Figure 4 we present a scatter plot of the distribution of competencies and
the number of expert groups. As we can see, our data do not support the
FIGURE 3
RELATIONSHIP BETWEEN NUMBER OF INTEREST GROUPS AND EXPERT
GROUPS IN DIFFERENT POLICY FIELDS
738 A
˚. Gornitzka and U. Sverdrup
argument of a linear relationship, in which increased EU competence in a
policy field would lead to increased involvement of expert groups. In fact, we
observe that most of the expert groups are operating in policy areas where
competences are shared. The number of expert groups is rather low in policy
areas of exclusive EU competence, such as agriculture and fishery policy. We
also find relatively few expert groups in DGs in which primacy is given to
market building and legal aspects, trade, competition and internal market
issues (see also Table 4). This supports the argument that consultations have
not developed in traditional areas of EU integration where the DGs can
operate with high European legal capacity for action and correspondingly
low national capacity (Scharpf 1999). These are all areas where the
Commission DGs act in a management role with the day-to-day operation
of policy areas where the European level has replaced the nation-state level
(Shore 2000). The uneven integration (Olsen 2007) is reflected in an uneven
distribution of consultations across levels of governance.
It follows from this discussion that there is no simple linear relationship
between the quality of EU legal competence and the number of expert
groups. If there is a relationship between legal competence and the density
of expert groups in policy fields, it seems to bear more of a resemblance to a
hump-shaped curve. This observation is consistent with a view of the
Commission as the defender of the treaty and an organisation that seeks to
maximise its autonomy within the conditions set by the treaty. In areas of
exclusive competences the DGs can function as relatively independent actors
FIGURE 4
RELATIONSHIP BETWEEN LEGAL COMPETENCE AND THE NUMBER OF EXPERT
GROUPS
Note:1¼exclusive, 2 ¼shared, 3¼coordinating, 4¼supporting/complementary .
The Configuration of Expert Groups in the European Union 739
in their day-to-day operations, but areas of mixed competences are the
realm of multi-level policy-making and implementation where the Commis-
sion practices would involve the joint exercise of coordination and
authority. These areas have developed issue-specific constituencies across
multiple levels, involving multiple types of actors (Eising and Kohler-Koch
1999). At the other end of the scale, i.e. areas where there is very limited or
no treaty basis for Commission action, there is no room for a structured
interaction between levels of governance organised by the Commission.
The Administrative Capability Argument
In Figure 5 we present a scatter plot of the relationship between the
administrative resources of a DG, defined as the size of the administrative
staff, and the number of expert groups at its disposal. As we can see from the
plot, we observe a relationship, but its direction is opposite to what we
expected. The more internal administrative capacities a DG has at its
disposal, the more expert groups it will create. Rather than being a
substitute for its own administrative resources, the DG uses expert groups as
a supplement to its own capacities. This is not consistent with the view that
DGs will systematically pursue a ‘self-reliance’ strategy and only organise a
multi-level administrative structure to compensate for a lack of in-house
administrative capacity. Rather it seems that internal administrative
capacity is a prerequisite for organising a large number of expert groups.
None (with one exception) of the DGs with a dense set of expert groups (i.e.,
with more than 70 groups) has fewer than 500 officials. This observation
suggests that expert groups are perhaps best seen as a tool for extending the
DGs’ capacity for action rather than limiting the DGs’ autonomy vis-a
`-vis
member states and interest groups.
However, we also see different types of relationships between internal
administrative staff and the use of external expert groups. In the lower
right-hand section with a low degree of internal resources but a high
degree of expert groups, we find DG Environment and DG Taxation and
Customs. In these policy areas the outsourcing hypotheses seem to fit the
data very well. In the upper right-hand section we find the policy areas
that mobilise many internal resources and many external resources. Not
surprisingly, we find policy areas that have increased in importance during
the last few years and areas that are of crucial importance to the current
EU agenda, such as DG Research, DG Energy and Transport. In the
upper left-hand section we find the DGs with a relatively high level of
internal resources and relatively few expert groups, such as DG
Agriculture, DG Information Society and DG External Relations. In the
lower left-hand quadrant, we find policy areas that have relatively few
internal resources and that make use of few external resources, including
DG Justice and Home Affairs, DG Development and DG Fish and
Maritime. In the centre and almost on the trend line we find DGs related
740 A
˚. Gornitzka and U. Sverdrup
to traditional EU activities such as regional policy and employment, as
well as health and consumer affairs.
Strong Sectoral Specialisation and Weak Horizontal Coordination
So far our analysis has clearly documented the heterogeneity and functional
specialisation of the expert group system and how this system has developed
according to the logic of sectoral specialisation. We have identified
dimensions of the policy types and institutional characteristics that can
account for some of this heterogeneity. We argue from this that we have
pinpointed a part of the EU governance system in which centrifugal forces
are at work. The sectoral differentiation we have observed speaks directly to
an enduring tension in the organisation of governments between specialisa-
tion and horizontal coordination (Gulick 1937). In a purely functionally
differentiated decision-making structure, the internal specialisation is
matched by highly specialised external contacts, and there are few
horizontally integrating forces and structures that ensure cross-sectoral
coordination. Our findings fit well with the EU administrative history, in
which the organisation has been based primarily upon the sectoral and
functional principle, that is, on the purpose and nature of the subject area
(Egeberg 2006). We observe this strong sectoral and functional differentia-
tion throughout the whole EU governance system, in the Commission
services, in the Council secretariat, in the various Council configurations, as
FIGURE 5
RELATIONSHIP BETWEEN ADMINISTRATIVE CAPABILITIES IN THE
COMMISSION DGS AND THE NUMBER OF EXPERT GROUPS (N¼1233)
Note: DG for Translation and the joint research centres are excluded.
The Configuration of Expert Groups in the European Union 741
well in the European Parliament, with its functionally differentiated
standing committees. In this respect our findings confirm that expert groups
contribute to this sectoral and functional specialisation.
However, to take our analysis a step further we also want to examine the
degree of horizontal coordination and the degree of institutionalisation. One
indicator of cross-sectoral coordination in relation to the expert groups is if
we find that the various expert groups are associated with other DGs apart
from its host DG. If this is the case, expertise provided by a group in one
field is more likely to be used to influence policy-making processes in other
fields and DGs as well, and possibly also contribute to increasing the
likelihood of developing cross-sectoral politics in the Commission. The
extent to which expert groups are set up in collaboration with other DGs
and report back to different DGs is therefore also a measure of the
(horizontal) permeability of organisational boundaries between the various
Commission services.
We observe (Table 2) that only a small fraction of the expert groups are
formally linked to DGs other than their host service. Four out of five of the
expert groups have a single DG ownership and do not have any other
associated DG. Moreover, in cases in which there is coordination across
DGs, the number of DGs that are associated is very limited. Of the expert
groups that are associated with other DGs in addition to their host DG, a
majority is linked to one or two DGs, bringing the total number of more
broadly, cross-sectorally anchored expert groups to only 85. We can
therefore conclude that the Commission expert groups are not a key part of
the horizontal coordinating mechanisms of the Commission. The sectoral
and functional differentiation, which is a hallmark of the administrative
history of the Commission (Cram 1994, 1997; Egeberg 2006; Stevens and
Stevens 2001), seems to be further accentuated by the practice of interacting
with extramural expertise structures through expert groups.
A High Degree of Stability and Institutionalisation
Growth and distribution across policy domains and DGs bear witness to
how widespread this consultative system has become. However, this does
not necessarily imply that these are stable and predictable structures which
are unsusceptible to short-term fluctuations and shifts in attention and
TABLE 2
CROSS-SECTORAL COORDINATION OF EXPERT GROUPS. NUMBER OF
COMMISSION EXPERT GROUPS ASSOCIATED WITH OTHER DGS IN ADDITION
TO THEIR HOST DG
No Yes . . . of which 1 DG . . . of which 2 DGs . . . of which 3 or more DGs
Valid N 1,006 231 96 54 85
%8119 8 4 7
742 A
˚. Gornitzka and U. Sverdrup
legitimacy or governance fads. What is this system’s degree of institutio-
nalisation?
Our data allow us to measure the degree of institutionalisation in two
ways. First, we make a distinction between formal and informal expert
groups. Formal expert groups are established by a Commission decision or
other legal acts, while informal groups are established by the DGs
themselves in agreement with the Secretariat General and without reference
to such a formal legal act. In principle, formal groups may be regarded as
more institutionalised than informal groups. Secondly, we make a
distinction between temporary and permanent groups. Expert groups that
are either explicitly defined as permanent or that have been in operation for
more than five years are coded as permanent groups. The rest of the groups
are coded as temporary.
Our analysis shows that (Table 3) three-quarters of the Commission’s
expert groups are informal and half are temporary. In some senses we can
view the expert group system as a rather flexible part of the administrative
space in which groups can be established and dismantled without going
through elaborate formal decision-making procedures, and therefore
contribute to creating a dynamic, flexible and adaptive administrative
system. However, our findings also show that a considerable part of this
system has become institutionalised and is an important element of a
routinised and rather stable administrative structure. The close to 400 expert
groups that have become a permanent fixture of the EU without having
been created by a formal legal act, along with the numerous formal expert
groups, indicate a rather high degree of institutionalisation of the expert
group system.
Most DGs balance between temporariness and permanence in their
consultative system. Yet some DGs organise a strikingly stable set of expert
groups, which is especially the case for Eurostat, DG Agriculture and DG
Fisheries. At the other end of the scale we find DG Research, DG Taxation
and Customs and DG Information Society, whose expertise system is
predominantly temporary.
In sum, we have obtained some striking and robust findings regarding the
distribution and degree of institutionalisation of the expert groups. The
TABLE 3
COMMISSION EXPERT GROUPS BY TYPE AND STATUS (N ¼1237)
Status P/T
Temporary Permanent Total
Type Informal Count 557 389 946
F/I % 88.6 64.0 76.5
Formal Count 72 219 291
% 11.4 36.0 23.5
Total Count 629 608 1237
% 100 100 100.0
The Configuration of Expert Groups in the European Union 743
large number of expert groups clearly shows that multi-level consultation is
an important feature of the European governance system, and our data also
show that this mode is gradually becoming even more important over time.
Table 4 provides an overview of the distribution of the groups and the
degree of institutionalisation. The obvious conclusion of these findings is
that the extent and quality of the EU multi-level governance is radically
different across different functional policy areas. While multi-level
consultation is a dominant and routinised feature of some policy areas
and in some services, it is a rather rare occurrence or it is used as a much
more flexible tool in other policy areas and services.
The pattern we see in Table 4 has both unsurprising and puzzling traits.
The position of internal administrative DGs in the left-hand column does
not represent much of a theoretical puzzle. The reason that we find DG
Trade and DG Competition in this group, on the other hand, is not that self-
evident. In the middle column we find many of the main traditional areas
subject to European integration and with a relatively high level of capacity
to act at a European level, in particular agriculture, internal market and
regional policy. We also see that many of the policy areas associated with
the ‘New Europe’ or the European knowledge economy, such as research
and education, are located in the right-hand column along with high-profile
areas, such as energy and environmental policy. The degree of institutio-
nalisation, on the other hand, also pairs policy areas that usually are not
thought of as having much in common – such as taxation and research
policy. Placing the policy areas in a two-dimensional space points us in the
direction that both the nature of the policy area and institutional differences
TABLE 4
DISTRIBUTION OF EXPERT GROUPS AND THEIR INSTITUTIONALISATION
(NUMBER OF EGS PER DG IN PARENTHESIS)
Number of expert groups
Few
(fewer than 20)
Medium
(21–70)
Many
(71 or more)
Degree of institutionalisation Low
(0–33.3%)
RELEX (11)
TRADE (7)
COMP (7)
BUDG (3)
ELARG (1)
DGT (1)
INFSO (38) RTD (129)
TAXUD (95)
Medium
(33.4–66.6%)
BEPA (5)
SG (4)
EMPL (62)
REGIO (58)
JLS (33)
DEV (30)
ENV (127)
ENTR (120)
TREN (94)
EAC (71)
High
(66.7–100%)
ECFIN (10)
OLAF (5)
AIDCO (5)
JRC (3)
ADMIN (3)
COMM (1)
AGRI (64)
MARKT (51)
FISH (25)
SANCO (89)
ESTAT (85)
744 A
˚. Gornitzka and U. Sverdrup
are factors that encourage, facilitate and restrain the Commission’s use of
expert groups.
Conclusions
Our analysis substantiates the idea that the European Union should be
understood as a governance system characterised by interpenetration of
different levels of government and non-state actors. We see this in the
ubiquity of expert groups at the European level. The Commission’s 1,237
expert groups are a key element in the multi-level European adminis-
trative space, outnumbering by far other types of committees in the EU
system. Over time this particular mode of consultation has become more
widespread and institutionalised. The number of expert groups has
increased considerably, especially after 2000. Although the formal rules
system regulating the creation and operation of expert groups is weak,
the use of expert groups has become a standard way for a large
proportion of the DGs to interact with their environment. We also see
some convergence in consultative system(s) in the various DGs, as all the
DGs, with the exception of two, have increased the number of expert
groups they organise. While three-quarters of the expert groups are
informal, half of them are permanent. These findings clearly support the
claim that the EU can be understood as a relatively stable multi-level
governance system.
The density and durability of the expert groups, on the other hand, vary
considerably between different Commission services. Some DGs are clearly
engaged in governance of this kind while other DGs are not involved in this
mode of governance. As for the factors that can explain the observed
heterogeneity in the organisation of expert groups across policy fields, we
find some support for the design perspective. On the one hand, parts of the
Commission’s set of expert groups represent a deliberate attempt to match
information systems and consultation to policy tasks. This is especially the
case when we differentiate between internal/general services and sectorally
oriented DGs. Most of the expert groups are found in areas of substantive
European policy areas, especially in task areas related to research,
environment and enterprise policy. In issue areas related to internal
administration, general services, and external relations, there are few – if
any – expert groups. The distinction between regulatory versus distributive
policy can also account for some of the heterogeneity in the Commission’s
use of expert groups – contrary to our expectations, distributive policies do
not entail more use of expert groups. We also find that external pressures in
terms of the number of interest groups are significantly correlated with the
Commission’s DG propensity to establish expert groups. Moreover, much
of the variation results from different institutional and organisational
factors such as legal and administrative capabilities, as well as the gradual
development of different routines and norms for connecting to the
The Configuration of Expert Groups in the European Union 745
environment. Expert groups are typically established and drawn into
the policy process in policy areas where legal competence is shared between
the European and national level of governance, and the density of organised
expert groups is highest in the policy areas where administrative and policy-
making capacity has been amassed in the Commission.
One main pattern we observe is that expert groups contribute to the
sectoral differentiation of EU decision-making, amplifying the sectoral
organisation of the European administrative space. Cross-sectoral coordina-
tion of expert group activities is at a very low level. The world of expert
groups unveils the Commission as a multi-organisation that is part of
structured multi-level governance within sectorally defined boundaries. This
underscores the significance of the basic organisational structure of the
Commission, its institutional traditions and routines, as well as the legal
parameters and administrative capacity of the various DGs for the way in
which European multi-level governance is structured. We therefore argue
that the EU is best understood as a functionally differentiated system with
very different modus operandi. Different policy areas form issue- and policy-
specific constituencies that evolve according to different logics. We have
described the empirical variance in the Commission’s expert group system
and pointed to causal mechanisms and differentiating factors that can ac-
count for these differences. The findings emphasise the need to give due
attention to the heterogeneity of European multi-level governance in the
study of European integration and its institutions and to specify the institu-
tional conditions and constellations of actors involved in governing Europe.
Acknowledgements
Draft versions of this article were presented at the ARENA seminar on 8
May 2007, at the CONNEX Conference: Institutional Dynamics and the
Transformation of Executive Politics in Europe, Barcelona 7–9 June 2007,
and at the 4th ECPR general conference, Pisa, Italy, 6–8 September 2007.
We would like to thank Michael Bauer, Jeff Checkel, Thomas Christiansen,
Pieter de Wilde, Morten Egeberg, Fabio Franchino and Johan P. Olsen for
helpful comments.
Notes
1. Note that these studies focus specifically on comitology committees.
2. To our knowledge, the most comprehensive overview to date is provided by a Swedish
governmental report prepared by Torbjo
¨rn Larsson (2003).
3. See Christiansen and Larsson (2007) for a discussion of the defining characteristics of the
Commission’s expert advisory groups.
4. Consultation, the European Commission and Civil Society (Coneccs) is the Commission’s
database of civil society organisations active at the EU level. http://ec.europa.eu/
civil_society/coneccs/index.html.
5. For reasons of simplicity we use here the terms found in the unratified Draft Constitutional
Treaty.
746 A
˚. Gornitzka and U. Sverdrup
6. It does not cover all expert groups and committees that are linked to the Commission. The
following broad categories of entities are excluded from the Commission’s register and thus
also from our database: 1) independent experts charged with assisting the Commission in
the implementation of framework programmes for research and development; 2) Sectoral
and cross-industry social dialogue committees, whose work is particularly aimed at the
finalising of agreements implemented by the Council or autonomous agreements
implemented by the social partners themselves and at adopting frameworks for action.
There were about 70 such committees in 2004; 3) Comitology committees which are
established by the legislator to assist the Commission in policy areas where the Commission
is empowered to implement legislation (about 250 such committees in 2004); 4) Joint entities
arising from international agreements (a total of 170 joint entities in 2004). These entities
differ from expert groups in terms of their creation and competence: they are created in
accordance with methods laid down in international agreements, and their role is to
supervise their implementation: http://ec.europa.eu/transparency/regexpert/faq/faq.cfm?
aide¼2.
7. See full agreement at http://ec.europa.eu/dgs/secretariat_general/relations/relations_other/
docs/framework_agreement_ep-ec_en.pdf.
8. Data on the European Commission was found in the Statistical Bulletin of Commission
staff: http://ec.europa.eu/civil_service/docs/bs_dg_category_en.pdf.
9. Data for comitology committees from 2006 and for Council committees from 2005; in
addition there were 121 sub-groups under the Council working parties and committees
(Hayes-Renshaw and Wallace 2006).
10. Since there is uncertainty attached to the accuracy of the data from the years prior to the
establishment of the register, some of this increase might reflect more rigorous methods for
reporting.
11. As noted earlier, there is some uncertainty regarding the accuracy of the measure from
2000.
12. A similar argument is voiced in theory by Broscheid and Coen because they expect to see
more expert groups in regulatory policies as the nature of the policy good in these policy
areas affect limited sets of societal actors in combination with high demand for technical
information. However, they fail to find support for this hypothesis in their data on expert
fora creation; rather they find (insignificantly) more expert groups in distributive policy
domains (Broscheid and Coen 2007).
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APPENDIX
Service Service
Expert
groups (N)
Budget
2006 em Connecs Legal Staff
Personnel and Administration ADMIN 3 660 0 1 670
Agriculture and Rural
Development
AGRI 64 54,455 30 1 887
Europe Aid AIDCO 5 0.1 0 2 583
Bureau of European
Policy Advisors
BEPA 5 0.1 0 1 25
Budget BUDG 3 1,160 0 1 382
Directorate General for
Communication
COMM 1 205 0 1 492
Competition COMP 7 99 0 1 593
Directorate General for
Development
DEV 30 1,301 1 2 245
Directorate General
for Translation
DGT 1 0 0 1 2,113
Education and Culture EAC 71 1,008 12 4 482
Economic and
Financial Affairs
ECFIN 10 468 0 1 441
(continued )
The Configuration of Expert Groups in the European Union 749
APPENDIX
(Continued )
Service Service
Expert
groups (N)
Budget
2006 em Connecs Legal Staff
Enlargement ELARG 1 2,205 0 2 226
Employment, Social
Affairs and
Equal Opportunities
EMPL 62 11,934 36 3 559
Enterprise and Industry ENTR 120 400 23 4 727
Environment ENV 127 346 17 2 492
Eurostat ESTAT 85 133 0 2 578
Fisheries and
Maritime Affairs
FISH 25 1,074 1 1 250
Information Society
and Media
INFSO 38 1,425 2 3 820
Justice, Freedom
and Security
JLS 33 605 0 4 328
Joint Research Centre JRC 3 0 1,710
Internal Market
and Services
MARKT 51 75 1 1 376
European Anti-Fraud Office OLAF 5 66 0 1 290
Regional Policy REGIO 58 28,629 1 2 523
External Relations RELEX 11 3,476 1 4 651
Research RTD 129 3,526 0 2 1,150
Health and Consumer
Protection
SANCO 89 559 3 2 625
Secretariat General/
Legal Service
SG 4 0 0 1 778
Taxation and Customs
Union
TAXUD 95 130 0 3 354
Trade TRADE 7 83 1 1 398
Energy and Transport TREN 94 1,462 4 3 863
Directorate General
Informatics
DIGIT 0 0 0 1 359
Humanitarian Aid ECHO 0 515 0 2 154
European Personnel
Selection Office
EPSO 0 0 0 1 106
Internal Audit Service IAS 0 12 0 1 71
Office for Infrastructure and
Logistics in Brussels
OIB 0 0 0 1 415
Office for Infrastructure and
Logistics in Luxembourg
OIL 0 0 0 1 160
Publications Office OPOCE 0 0 0 1 595
Paymaster’s Office PMO 0 0 0 1 234
Directorate General for
Interpretation
SCIS 0 0 0 1 667
Legal Service SJ 0 215 0 1 321
Total 1,237 11,6226.2 133 21,693
750 A
˚. Gornitzka and U. Sverdrup
