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forums include the Regional Advisory Councils in the fi shing sector (see also Dreyer
et al. 2014 ).
Nonetheless, there is a striking lack of institutionalised structures for stakeholder
participation and communication, particularly at the regional level . And in general,
there is a fairly big gap between ideal scenarios and practice when it comes to broad
stakeholder participation and communication of environmental risk governance of
the Baltic Sea (including the EU level) (Dreyer et al. 2011 , 2014 ; Jönsson et al.
2016 ; Linke et al. 2016 ). From the case studies, we found scant evidence of real
refl ection on and practice of participatory and communication activities. Forms for
horizontal interaction among groups are generally lacking (exceptions are umbrella
NGOs such as Coalition Clean Baltic ). HELCOM and other governance arrangements are only beginning to foster such horizontal interaction. Available forms of
stakeholder interaction are fragmented and only allow for some restricted inclusion
of various stakeholders, as within the EU WFD. The institutional design of the
RACs presents one of the most innovative and interesting models. Yet, the RACs
only apply to the risk management phase, not earlier phases during, for example,
risk assessment and risk appraisal when the problem framing mainly occurs (see
Dreyer et al. 2014 ; Sellke et al. 2010 ). Furthermore, there is a dominant functionalist view of participation in which stakeholders are at the service of policy. By interpreting the data from the cases studies, it is clear that stakeholders are supposed to
improve implementation and provide useful knowledge to policy, but not expected
to express their values or provide criticism based on refl exive thinking (social
refl exivity in Beck’s understanding). If the risk assessment arrangement relies on a
narrow scientifi c-technical framing , which was particularly apparent in the eutrophication case, the governance framework in effect largely excludes stakeholders’
knowledge and experiences and undervalues their potential input.
However, the critical issue is not merely that of increasing inclusion. While
addressing tensions between inclusion of stakeholders and decision effi ciency, Voss
et al. ( 2006b ) make an important observation by referring to an ‘effi cacy paradox’,
between ‘opening up’ for the inclusion of more actors and ‘closing down’ for
decision- making. The more actors that become involved, the trickier the decisionmaking process is likely to be. This paradox, or tension, cannot be eliminated but
needs to be recognised and somehow organisationally balanced. Although vast networks of international substate, city networks or lobby organisations exist within
the BSR (see Fig. 3.1. in Haahti et al. 2010 : 23), their participation is to a large
extent predetermined by the character of the regulatory framework, making their
role more indirect, i.e. attending meetings and participating within, for example,
HELCOM according to their ‘observer’ status. But, due to the vastness of the NGO
networks, competition among networks, for example, for funding and hence domination, this has in some cases resulted in overlapping and confl icting agendas. A
perception that there are too many actors engaged is likely to emerge if there are a
lack of clear forms and structures for stakeholder input as well as a lack of rules and
guidelines that defi ne the roles and relationships among stakeholders. Absence of
structures for stakeholder participation and communication corresponds with a lack
of coordination among actors. Furthermore, it should be carefully noted that
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