Participation in Governance from a Comparative Perspective : Citizen Involvement in Telecommunications and Electricity in the UK, France and Sweden

This paper draws on empirical research to compare modes of citizen participation in administrative actions between the United States and three European countries: England, France and Sweden. It addresses the methods not adopted by Europeans - ex parte and open meetings rules; those adopted that have U.S. parallels, including consultation procedures similar to notice and comments, working groups and consumer panels, and shows the differences between the way these methods were implemented in Europe and the U.S.; and areas where the Europeans went beyond what is used in the U.S., using municipal advisers in Sweden and interactive internet tools in France. The examples are drawn from the newly liberalized telecommunications and electricity sectors in the three countries