Deliberation over multifaceted governance challenges is too often reduced to arguments over ideal-type policy solutions: administrative centralization versus decentralization, government provision versus contracting out, or the pursuit of operational efficiency versus program effectiveness. Politicians and scholars alike tend to promote their preferred administrative remedy by emphasizing the faults in alternative courses of action while undervaluing the limitations of their own. The attraction of administrative panaceas is clear. Simple answers are both persuasive and comforting; they portray intractable obstacles as navigable and disguise inherent tensions as tamable (Ostrom 2007). Christopher Carrigan’s Structured to Fail? Regulatory Performance under Competing Mandates avoids the lure of overly-simple policy panaceas. Carrigan examines the argument that many regulatory failures are attributable to the fact that regulators are often saddled with multiple, often competing, objectives. For example, the assertion that the Federal Reserve’s concurrent obligations to develop monetary policy and regulate banks precipitated the 2008 global financial crisis. Consistent with the claim, he finds that “multi-purpose regulators,” or regulatory agencies charged with both regulatory and non-regulatory goals, indeed perform worse than those whose mandates are limited to regulatory functions or lack significant regulatory responsibilities altogether. Carrigan convincingly argues, however, that the finding should not be interpreted as justification for partitioning multi-purpose regulators into single-function entities. Such a reaction, he reasons, fails to recognize the ability of multi-purpose regulators to leverage intra-agency information sharing and task coordination towards the attainment of multiple desirable policy goals. Structured to Fail offers an impressive investigation into why multi-purpose regulators exist, how their performance compares to that of other administrative arrangements, and how social and political forces contribute to observed performance deficits. As with any ambitious research project, there are limitations to the analysis, particularly regarding the causal linkages between a multiple-mandate structure and performance outputs. Yet such limitations are better thought of as opportunities for future research rather than serious defects in Carrigan’s argument. The book offers a number of important insights that hold both theoretical and practical relevance, including a compelling proposition with critical salience in the contemporary political context, as addressed at the end of this review. Structured to Fail: A Synopsis The virtues of Structured to Fail extend beyond a nuanced consideration of the trade-offs made in regulatory design decisions. Carrigan leverages insights from across several literatures including regulatory design, public administration, organizational theory, policy implementation, and political control and bureaucratic autonomy. Doing so allows him to look past the question of whether multi-purpose regulators perform better or worse than their single-purpose counterparts to also consider select mechanisms through which competing mandates affect regulatory performance and the political determinants of structural choice. Furthermore, Carrigan’s analysis offers a powerful example of how a diverse methodological toolkit provides a rich empirical canvas for theoretical inquiry. Carrigan starts off the book by investigating the central question of whether multi-purpose regulators exhibit a performance deficit. Using Program Assessment Rating Tool (PART) data generated under the George W. Bush administration, quantitative analyses indicate that multi-purpose regulators indeed perform worse, on average, than single-purpose regulators and multi-purpose agencies that lack a regulatory mandate. The relationship holds up when funding is held constant as well as when potential partisan bias in PART score data is controlled for. Carrigan then extends the quantitative analysis to examine how priority goal ambiguity—the competing priorities that are introduced by multiple organizational goals—contributes to multi-purpose regulators’ comparatively low performance. Drawing on Federal Human Capital Survey data, he shows that multi-purpose regulator personnel exhibit greater ambiguity in how their work relates to their agencies’ goals and that this ambiguity explains some, but not all, of multi-purpose regulators’ relatively low performance metrics. From these statistical analyses, Carrigan moves into a historical analysis of the Minerals Management Service’s organizational and political evolution leading up to the 2010 Deepwater Horizon disaster, in which millions of barrels of oil were released into the Gulf of Mexico. He synthesizes pertinent data from a variety of sources, including congressional hearings and budget appropriations decisions, to argue that the Service’s organizational design functionally separated its regulatory and non-regulatory tasks—thereby undermining arguments that conflicting goals led to the Gulf oil spill. Instead, Carrigan highlights the political and social forces during the 1990s and 2000s that encouraged the Minerals Management Service to prioritize oil and gas development over regulation. Lax regulation by the Service was largely externally driven, Carrigan argues, rather than being the product of internal confusion or conflict. The final section of the book consists of a theoretical analysis that formally models a politician’s decision to combine regulatory and non-regulatory goals within the purview of a multi-purpose regulator, on one hand, or assign the distinct functions to separate agencies, on the other. Carrigan shows that despite their demonstrated performance deficits, the political payoffs for establishing a multi-purpose regulator are highest when the politician values the achievement of both the regulatory and non-regulatory goals in question. His analysis further suggests that multi-purpose regulators are the most appropriate structural choice when intra-organizational task implementation offers the greatest benefit—specifically, when the multiple goals to which the agency is assigned are neither tightly aligned nor in direct conflict. The resulting implication of this result reveals an inherent tension in the structure of competing mandates: the task coordination benefits of a multi-purpose agency offer the greatest promise in situations where goal ambiguity poses the highest liability to agency performance. Carrigan closes Structured to Fail by reflecting on the preceding analyses and their findings within the context of an empirical reality where regulatory failures are frequently followed by administrative restructurings. He warns that the resulting cycles of multi-purpose regulator construction and deconstruction are costly affairs, often grounded in the faulty assumption that conflicting mandates invariably lead multi-purpose regulators to lose sight of their regulatory responsibilities. As other careful considerations of regulatory design have argued (e.g., Ostrom 2007), Carrigan concludes that structural choice is a matter of trade-offs, as “[r]egardless of how the agency is designed, it may fail—just in different ways” (p. 24). Considering the Conceptual Foundations: A Critique and Opportunities The strengths of Structured to Fail far outweigh its limitations—the book offers a convincing nuanced argument on the basis of simultaneously sophisticated and diverse methods. The broad methodological and theoretical sweep of Carrigan’s approach, however, means that the analysis engages some theoretical considerations only on the margin. Combined with a devoted emphasis on higher-level structural and contextual factors, the result is an examination that at times glosses over potentially consequential conceptual underpinnings. A first limitation of the book is a sizeable conceptual and practical gap between the regulatory crises in which the structure-performance puzzle is framed and the more mundane, but perhaps more substantively consequential, construct of regulatory performance. The book begins with, and persistently returns to, some of the most notable regulatory failures in recent history—events such as the 2008 financial crisis that resulted in the Great Recession, the Deepwater Horizon incident, and the 2011 Fukushima Daiichi power plant emergency that precipitated several nuclear meltdowns. In contrast, the first third of the book defines agency performance not in connection to regulatory failures, but rather as agencies’ assigned results/performance PART scores, which reflect “program performance on goals reviewed in the strategic planning section and through other evaluations” (OMB 2003). To his credit, Carrigan recognizes the disconnect, noting that the analyses “…do not necessarily indicate whether the organizational designs of the regulators associated with the financial and environmental disasters specifically precipitated those calamities,” and contending that the link between (poor) performance and such crises is ultimately tangential to the conclusions drawn (p. 29). This unfortunately leaves it up to the reader to decide the extent to which Carrigan’s thorough study of the relationship between structure and performance extends to regulatory crises—precisely the types of regulatory failures that are most likely to capture public and political attention. A second limitation of the book is an underdeveloped conceptualization of individual decision-making and behavior, particularly as it pertains to agency personnel. As with much research that adopts a top-down perspective to examining the implementation and impacts of policy decisions, more emphasis is placed on the priorities and goals of political principals, and less attention is afforded to the bureaucrats who realize program outputs. Perhaps most notably, some public administration scholars are likely to find Carrigan’s theorizing regarding priority goal ambiguity unsatisfying, as agency personnel are characterized as largely reactive and lacking agency. To be fair, this limitation may extend from the minimal attention paid to public servants’ cognitive, emotive, and motivational processes as well as how these factors relate to organizational priorities and performance in the goal ambiguity literature more generally (e.g., Rainey and Jung 2015). Nonetheless, scholarship on stewardship and street-level leadership (Dicke 2003) as well as “guerilla” public servants (O’Leary 2006) offers a counterweight to the assumptions inherent in Carrigan’s analysis. It could be, for example, that poor performance in these agencies reflects a resistance to an agency’s goals as defined under PART measures (and their sources) in an effort to support the objectives which public servants deem best serve the public’s interest. In this case, the end result is the same from a performance-metric standpoint, but the different assumptions regarding bureaucratic motivation and behavior lead to contrary predictions when it comes to the likelihood of regulatory failures or crises. When combined, the two aforementioned limitations lead to a somewhat obscure causal story regarding how multi-purpose regulators’ competing mandates translate to performance deficits. To be clear, Carrigan identifies important external factors that increase the likelihood that a multi-purpose regulator’s regulatory function will take a back seat to its non-regulatory duties (or vice versa), including social, economic, and political forces, as well as the objectives of political principles and administrative agency heads. He also gives considerable attention to organizational design mechanisms that help mitigate the detrimental influence of multiple organizational goals. Less flushed out are the important internal causal mechanisms leading to relatively poor performance, beyond the general influence of organizational priority goal ambiguity. Carrigan correctly contends that a central strength of Structured to Fail’s analysis is that it looks across regulatory and non-regulatory agencies to “adopt a broad approach in studying regulatory agencies beset by competing goals” (p. 165), and I agree. The cost of the broader view, however, is a more comprehensive identification of the generalizable internal mechanisms whereby competing mandates manifest as declines in organizational effectiveness. Filling in these conceptual gaps will likely prove fruitful next steps for scholars pursuing the theoretical trajectory laid out in Structured to Fail. A key task in doing so will involve identifying a way to conceptualize and operationalize agency performance that splits the difference between the book’s results/performance PART measures and fine-grained historical case narrative while allowing for comparison across different empirical regulatory arenas. Future research will also benefit from leveraging regulatory literature to conceptualize, measure, and compare the activities of multi-purpose regulators. Carrigan broaches the topic when he discusses “cooperative regulation” at Minerals Management Service, but the literature offers a variety of ways to characterize regulatory behavior, from a simple deterrence-to-accommodation spectrum (e.g., Bardach and Kagan 1982) to multi-dimensional constructs (e.g., May and Burby 1998). Capitalizing on such conceptual foundations to link multi-purpose agencies’ competing goals to regulatory behaviors and these regulatory behaviors to program outcomes offers opportunities to better understand to what extent and how agency structure facilitates and impedes regulatory effectiveness. Contemporary Relevance: .The Political Perils of Multi-Purpose Regulators Because the analysis presented in Structured to Fail is appropriately nuanced, it is difficult to identify a singular lesson from the book. Indeed, such an effort is inadvisable. There are a host of important insights that the book offers, with both theoretical and practical relevance. The theoretical message that Carrigan drives home most forcefully is that focusing on structure and its relationship with agencies’ internal operations only gets one so far in understanding why multi-purpose regulators are outperformed by their single-purpose regulatory and non-regulatory multi-purpose counterparts. A wider scope is necessary, one which includes relevant social and political forces and how these forces interpret, value, and weigh the multiple mandates with which multi-purpose regulators are charged. Carrigan closes the book with a cautionary warning regarding the impulse to restructure multi-purpose regulators in response to regulatory crises. Doing so, he argues, not only imposes financial, temporal, and personnel costs but also neglects the operational advantages that a dual-mandate offers when multiple goals are desirable. Perhaps more importantly, Carrigan’s theory supports what history suggests: organizational reforms in which multi-purpose regulators are disaggregated into single-purpose entities stand a good chance of being reversed at a later date, when the effects of a crisis have faded and the desire for parallel goal achievement once again takes political and social priority. To avoid the resulting cycles of reforms and restructuring, a fuller appreciation is needed of the limitations, strengths, and underlying rationales of multiple-mandate regulatory agencies. While both of these messages are essential lessons that position Structured to Fail as an important contribution to our understanding of regulation and public administration more broadly, contemporary events highlight another critical insight raised in the conceptual analysis that comprises the book’s final analytical treatment. Carrigan points out that the competing mandates that distinguish multi-purpose regulators may make them more susceptible to political manipulation, as: …the mere presence of multiple missions introduces a lever for principals to use in shaping administrative activities which, by definition, does not exist with regulatory agencies that do not balance other missions…As a result, it might seem that agencies which combine multiple goals would be more amenable to political efforts to influence their activities (p. 246). As this review is written, a heated debate is playing out among scholars and political observers regarding the success of the Donald J. Trump administration in dismantling much of the social, environmental, and economic regulatory infrastructure that predated it. Many loudly proclaim that a wholesale repeal of crucial regulations threatens the safety and wellbeing of American citizens (e.g., Timmons 2017). Others, including respected regulatory scholars (e.g., Coglianese 2018), counter that such claims are exaggerated, in-part by citing the sheer preponderance of federal regulations against the minimal formal rule retractions that have been executed. Regardless of whether the administration’s formal efforts to deregulate constitute a significant change to US regulation, Carrigan’s proposition points to a more obscure—yet potentially no less impactful—manner in which an administration hostile to regulatory governance (for either ideological or instrumental reasons) may undermine the implementation of regulatory oversight. By leaning on a multi-purpose regulator to shift its attention and resources from its regulatory to its non-regulatory functions, political appointees may intentionally and effectively curtail the agency’s regulatory activity without necessitating formal rule changes. Carrigan has, therefore, offered a hypothesis ready for empirical inquiry, and one that regulatory scholars are well advised to take up. The contemporary political context suggests that such research stands to make theoretically meaningful and substantively crucial contributions. References Bardach , Eugene , and Robert A. Kagan . 1982 . Going by the book: The problem of regulatory unreasonableness . London : Transaction Publishers . Coglianese , Cary . 2018 . Let’s be real about Trump’s first year in regulation . Oxford Business Law Blog . https://www.law.ox.ac.uk/business-law-blog/blog/2018/02/lets-be-real-about-trumps-first-year-regulation. (accessed April 12, 2018 ). Dicke , Lisa A . 2003 . Street-level leadership in the public sector: A case study of the challenges . International Journal of Organization Theory & Behavior , 7 ( 2 ): 231 – 51 . Google Scholar CrossRef Search ADS May , Peter J. , and Raymond Burby . 1998 . Making sense of regulatory enforcement . Law & Policy , 20 : 157 – 82 . Google Scholar CrossRef Search ADS Office of Management and Budget (OMB) . 2003 . Performance and management assessments: Budget of the United States government, fiscal year 2004 . Washington, DC : Executive Office of the President . O’Leary , Rosemary . 2006 . The ethics of dissent: Managing guerrilla government . Washington, DC : CQ Press . Ostrom , Elinor . 2007 . A diagnostic approach for going beyond panaceas . Proceedings of the national Academy of sciences 104 ( 39 ): 15181 – 7 . Google Scholar CrossRef Search ADS Rainey , Hal G. , and Chan Su Jung . 2014 . A conceptual framework for analysis of goal ambiguity in public organizations. Journal of Public Administration Research and Theory, 25 (1), 71–99. Timmons , Heather . 2017 . Trump is dismantling rules and laws protecting millions of Americans. Here are the most important . Quartz [online publication]. https://qz.com/1072054/dismantling-the-rules-that-protect-americans-a-guide-to-th-trump-administrations-destruction-from-within/ (accessed April 12, 2018 ). Published by Oxford University Press on behalf of the Public Management Research Association 2018. This work is written by (a) US Government employee(s) and is in the public domain in the US.
Journal of Public Administration Research and Theory – Oxford University Press
Published: May 2, 2018
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