5.1.1 Problem Stream

The problem of climate change first entered European policy discussions in the early 1990s. Since then, joint climate policies have, at least in principle, enjoyed relatively consistent popular and political support, albeit with significant variations across member states. European institutions have repeatedly seized on the problem of climate change to reinforce their own legitimacy, advance the development of a joint foreign policy, and accelerate supranational identity building based on the “myth of a Green Europe” (Reference Lenschow and SprungkLenschow and Sprungk 2010).

Over time, dominant problem frames in the EU have changed, gradually transforming the issue of climate change from a narrow sectoral concern “into a high-politics, core-identity issue for the EU” (Reference TorneyTorney 2015: 49). An important shift in problem framing occurred in the mid-2000s, when the European Commission pushed forward a more integrated approach to climate policy, mainstreaming it into other policy areas, notably energy (Reference SkjærsethSkjærseth 2017). More recently, problem definitions have become even more expansive, with the 2019 EGD connecting the need for climate change mitigation and adaptation with a range of other ecological and societal challenges. Climate change is no longer framed simply as a “problem” but as an “emergency,” requiring long-term transformations of key socio-technical systems rather than ad hoc emission cuts (Reference RankinRankin 2019). Yet, notwithstanding the EU’s high-level commitment to transformational change, current policies still reflect an understanding of sustainability that is steeped in techno-economic narratives of innovation and market rationalities (Reference Olsson, Öjehag-Pettersson and GranbergOlsson et al. 2021). The EU has also consistently sought to frame climate action as a means to increase competitiveness and green growth. However, in practice, internal market and economic growth imperatives have often competed with climate change and other environmental issues in the problem stream (Reference SadeleerSadeleer 2014).

A plurality of actors within the EU is actively shaping problem framing. The EU’s overall political and strategic directions are set at the high-level EU summits, when national and EU-level leaders convene as the European Council (see Figure 4). More than other EU institutions, the European Council serves primarily to reconcile national (Level II) interests. Through this venue, member states with higher bargaining power may be able to successfully push forward or resist particular problem frames. For example, the linking of the EU climate and energy agendas may not have been possible without support from the British and German leaders at the time (Reference Bocquillon and DobbelsBocquillon and Dobbels 2013). Conversely, powerful member states can also hit the brakes on more radical problem reframing, as exemplified by Germany’s long-standing resistance to narratives that threaten techno-economic legacy frames (Reference OltermannOltermann 2021). That said, the rotating Council presidency also provides opportunities for smaller member states and their leaders to throw their weight behind particular agendas (Reference TallbergTallberg 2011).

Figure 4 Decision-making in the EU

(ordinary legislative procedure)

While the European Council provides important impetus, it is the European Commission, operating at Level I, which holds a monopoly on formal agenda-setting in the policy process (see Figure 4). Key to the Commission’s ability to exercise substantial influence on problem framing is its role as a knowledge broker. As Reference DregerDreger (2014, 176) argues, gathering expert input and building epistemic consensus serves not just to make sense of the problem but can also be strategically employed to “technocratize” subsequent policy debates, “pull[ing] political actors toward those grounds where the Commission has a home field advantage.” However, the Commission is also sensitive to the preferences of diverse interest groups (Reference Coen, Katsaitis and VannoniCoen et al. 2021) and it may choose to prioritize issues that have particular salience for European citizens (Reference Koop, Reh and BressanelliKoop et al. 2021).

While the agenda-setting powers of the EU’s legislative bodies are more constrained, they too are able to wield a certain amount of influence on the problem stream. For example, the Environment Council, which brings together national environment ministers, plays a key role in preparing joint positions for UNFCCC negotiations, thus shaping the problem frames that the EU promotes at the global level. In turn, the European Parliament has increasingly explored informal avenues to raise the salience of certain issues through fostering public and/or elite support for policy action (Reference Kreppel and WebbKreppel and Webb 2019). For example, the declaration of a “climate and environment emergency” by the Parliament in 2019, while largely symbolic, raised pressure on the EU’s executive bodies to step up ambition (Reference RankinRankin 2019).

Crucially, decisions which ultimately shape problem framing are not taken in isolation from societal realities and background developments of a technical and scientific nature. All EU institutions are responsive to what Reference KingdonKingdon (1995) conceptualizes as indicators, feedback, and focusing events. Indicators refer to new data and evidence that highlight a change in scale, scope, or nature of a particular problem. For example, IPCC assessment reports have regularly provided impetus for EU climate policy development. Feedback takes place when the evaluation of existing policies reveals implementation gaps, insufficiencies, or novel unexpected problems. This information may be gathered by policymakers and street-level bureaucrats, but also comes in the form of feedback from stakeholders and citizens and highlights important linkages between the problem and the politics stream. The recent youth climate strikes are arguably a particularly powerful form of feedback, since young people will be most affected by future climate change policies yet are not franchised across democratic political systems. Finally, focusing events refer to crises and emergencies that provide an extra push for problems to climb up the policy agenda (Reference KingdonKingdon 1995), such as heat waves or spikes in oil and gas prices.

Importantly, in MLG settings such as the EU, indicators, feedback, and focusing events play out at several levels, with EU policymakers responding to pressure from above as well as below. Having invested significant political capital into building a reputation as an international climate leader at Level I, the EU faces particular pressure to deliver on global climate treaties. At the same time, national (Level II) policy priorities, public opinion, and problem framing activities within member states, leveraged by interest groups with access to EU forums, influence which issues gain most salience in Brussels. At several points in recent years, this combination of top-down and bottom-up pressure has brought the problem of climate change to the fore and spurred the EU on to provide leadership in this area. However, “[i]t takes time, effort, mobilization of many actors, and the expenditure of political resources to keep an item prominent on the agenda” (Reference KingdonKingdon 1995) and, over the past three decades, climate change has been repeatedly crowded out by other policy challenges requiring urgent attention. In addition, a problem is unlikely to occupy policymakers’ minds unless it can be coupled to concrete solutions, that is, if opportunities exist to open an Agenda Window. It is this second part of the agenda-setting process that we now turn to.

5.1.2 Policy Stream

Climate policy development in the EU has been driven by “a strong preference for regulatory instruments” (Reference Jordan and MooreJordan and Moore 2020: 57), combined with a limited selection of market-based instruments. To this end, climate policymaking has focused primarily on setting collective decadal targets, to be implemented through the EU’s ETS and complementary effort sharing agreements, enshrining binding national targets for emissions reductions in non-ETS sectors. More recently, and in tandem with the transformation of dominant problem frames, the EU’s climate policy toolbox has expanded. The EGD has shifted the focus decisively toward long-term, whole-economy planning in line with the goal of reaching collective climate neutrality by 2050. Other notable policy innovations include a Carbon Border Adjustment Mechanism (CBAM) which will impose a levy on some imports with a view to incentivizing emissions reduction efforts outside the EU and preventing “carbon leakage,” that is, the transfer of production from the EU to countries with more lenient climate policies (Reference Abnett and TwidaleAbnett and Twidale 2021).

In contrast to ASEAN, soft policy tools, such as voluntary targets and standards, remain relatively underutilized in the EU, not least because previous applications of such instruments increased doubt regarding their efficacy (Reference Jordan and MooreJordan and Moore 2020). Nevertheless, the EU continues to experiment with some soft tools aimed at catalyzing action from actors at other governance levels. An example is the EU Covenant of Mayors, a voluntary program which promotes action by local authorities to implement European sustainable energy policies (Reference DomorenokDomorenok 2019). The European Commission has also proposed a new voluntary standard, the European green bond standard, to encourage ambitious green investments that meet high-quality sustainability standards (Reference JessopJessop 2021).

Among regional organizations, the EU is unique in being able to adopt and implement intrusive supranational policy tools. It has comparatively high administrative and technical capacities and EU institutions enjoy a broad mandate for regional policy development. The EU has been building up relevant expertise and capacities for decades, including in the highly technical area of emissions monitoring, reporting, and verification. However, it is important to note that – although its budget is large compared to that of ASEAN – the EU’s financial autonomy remains very limited (Reference Jordan and MooreJordan and Moore 2020). Capacities also differ widely on the national level, with some member states able to go beyond what is required under EU climate legislation while others are reluctant to scale up ambition, for reasons that may include a lack of resources and implementation capacity (Reference Sartor, Voss-Stemping, Berghmans, Vallejo and LevaïSartor et al. 2019). This can lead to conflicting policy priorities at Level II.

Policy development is the result of input from actors located across EU institutions. While legislative proposals can only be adopted after review and adoption by both the European Parliament and the Council, the European Commission holds a formal monopoly of initiative. As such, it has the potential to provide significant cognitive, as well as entrepreneurial, leadership on climate change at Level I (Reference Barnes, Wurzel and ConnellyBarnes 2010). However, it is important to note that the Commission is not monolithic. Although climate action has a dedicated Directorate-General (DG CLIMA), there are significant overlaps with the work of other DGs covering policy areas such as energy, environment, transport, industry, agriculture, and trade. Conflict between different DGs, due to competing interests, beliefs, and policy priorities, can dampen climate policy ambition (Reference RietigRietig 2019).

Even when internally united, the Commission’s entrepreneurial powers are not without limits. When developing policy proposals, it must consider the preferences of EU member states and parliamentarians. Both the Council and the European Parliament can make amendments to proposed policies and they may also invite the Commission to initiative legislation on a particular issue. The European Parliament also generates its own policy expertise through its influential environment (ENVI) committee. Committee rapporteurs, chosen to represent parliamentary positions in exchanges with the Council and the Commission, “play a central role in shaping policy outputs” (Reference BurnsBurns 2019: 312). Thus, in practice, EU policymaking is a product of interinstitutional negotiations, usually facilitated by informal “trilogues” between the Commission, the Parliament, and the Council (see Figure 4), with ideas for policy solutions entering negotiations through various channels.

Ideas do not emerge out of thin air. As a comparatively small administration, the Commission is heavily dependent upon external expertise and input to develop policy proposals (Reference Barnes, Wurzel and ConnellyBarnes 2010). Thus, its role in the policy stream is often that of an “entrepreneurial gatekeeper” – selecting, rejecting, or reshaping the ideas that float around in the “policy primeval soup” (Reference KingdonKingdon 1995), with a view to prizing open an Agenda Window. This soup is cooked up by a large and diverse community of specialists, which may work for nongovernmental and research organizations, industry associations and other interest groups, or public authorities at national or sub-national levels. The Commission and the legislative EU institutions regularly consult with different stakeholders to tap into this pool of expertise and to test the acceptability of policy proposals. While this makes for a relatively competitive landscape of ideas, there are important asymmetries in terms of which policy entrepreneurs gain privileged access to policymakers in Brussels. Navigating the EU bureaucracy requires time, knowledge, and resources, which are often not available to nongovernmental or not-for-profit climate policy entrepreneurs. In turn, the five largest fossil fuel companies alone have spent at least €250 million on EU lobbying over the past decade, spiking “at times when legislation is being drawn up” (Reference LavilleLaville 2019). Fossil fuel–dependent industries and businesses, such as carmakers have also invested significant resources into lobbying EU institutions, at times successfully delaying stricter emissions regulations (Reference Coen, Katsaitis and VannoniCoen et al. 2021: 127). That said, the complex relationship between the EU and business is not simply governed by money and, ultimately, EU policymakers depend on a diversity of stakeholders for reliable information and expertise (Reference Coen, Katsaitis and VannoniCoen et al. 2021).

Like the problem stream, the EU policy stream is responsive to external developments on multiple levels of governance. As we explore further below, Level I ambitions vis-à-vis global treaties such as the Kyoto Protocol and the Paris Agreement have provided important impetus and the broad parameters for EU policy development. Conversely, some policy innovations have first been tested at Level II or promoted by non-state actors before being “uploaded” onto the European policy debate. The 2021 European Climate Law, which enshrines the EU’s 2030 and 2050 mitigation targets in binding legislation, is a case in point, with prototype laws having first diffused at member-state level (Reference Duwe and EvansDuwe and Evans 2020). Going forward, consideration of domestic context is likely to become increasingly important for EU policymakers. Reference Sartor, Voss-Stemping, Berghmans, Vallejo and LevaïSartor et al. (2019: 7) argue that, in order to coordinate a European-wide transition to net-zero, “the EU will need to significantly raise its capacity not simply as a legislator, but also a facilitator of national transitions that tackle in some cases quite different issues and priorities.” This task is unlikely to be accomplished only via regulatory command-and-control measures, especially as the distributive consequences of the transition become more apparent. In this context, and as we explore in the next section, Level II politics are also likely to become increasingly consequential for efforts to open Decision Windows, that is, translating policy proposals into actionable outcomes.

5.1.3 Politics Stream

Just like problems and policies, politics in the EU unfold simultaneously on multiple levels. Given the elaborate EU decision-making procedures, consensus-building is a key prerequisite for any policy change. While no single member state, party, or interest group is able to prescribe policies in this “hyper-consensual” environment, the flipside is that concentrated minority interests may seek to block reform or ensure that adopted policies reflect the lowest common denominator (Reference Hix, Joergensen, Pollack and RosamondHix 2007: 148). Another implication is that, in contrast to national-level policy cycles, Decision Windows are rarely suddenly flung open in the wake of an election or another significant political event. Rather, what is politically possible at any given moment is determined by a complex multilevel bargaining landscape, where the room for maneuver of policy entrepreneurs at the supranational level (Level I) may be severely constrained by developments within domestic (Level II) political systems.

Due to the salience of power dynamics at Level II, conflict between member states often dominates the headlines. With regard to climate change, divisions run principally (though not exclusively) between the “older” Western and Northern European member states and a handful of “newer” Eastern European member states, led by Poland. This makes it more challenging to adopt ambitious climate goals and recent efforts to do so have resulted in protracted negotiations.

Similarly to ASEAN, albeit to a lesser degree, economic development levels within the EU are not even and there are important differences in national context that determine how willing or able member states are to support ambitious climate action. Poland’s energy-intensive economy, for example, remains heavily reliant on coal and this dependency is reinforced by a political economy that is characterized by strong links between the coal industry, the government, and miners’ unions (Reference Brauers and OeiBrauers and Oei 2020). Other Visegrád countries, notably Hungary, have often sided with Poland in EU climate debates, seeking to gain more financial support and other concessions (Reference DunaiDunai 2019). National context also shapes member states’ bargaining positions on more specific issues. For example, Germany’s decision to phase out nuclear energy – based on long-standing popular opposition – puts it at odds with a number of other EU members, including France, over the role of nuclear power in EU climate and energy policies (Reference BarbièreBarbière 2019).

Level II dynamics are dominant in this stream; however, politics also plays out in the EU’s supranational institutions at Level I. The European Parliament has seen its formal legislative power increase during successive EU Treaty reforms and taken on a “more decisive role” in the EU politics stream (Reference BeckerBecker 2019: 156: 156). While European elections are generally viewed as “second-order elections” (Reference Hix and MarshHix and Marsh 2007), Reference BraunBraun (2021) finds that voters are increasingly motivated by genuinely European (Level I) rather than purely domestic (Level II) concerns. This may be particularly true for climate change, which is seen by a majority of European citizens as the most serious problem facing the EU (Eurobarometer 2021). Although its green ambition has fluctuated over time, the Parliament has often lived up to its reputation as an environmental champion (Reference BurnsBurns 2019). In recent debates on EU climate targets, it has emerged as the most ambitious EU institution, pushing (unsuccessfully) for a 60 percent reduction in emissions by 2030 (European Parliament 2020) and greater stringency regarding target implementation (Reference TaylorTaylor 2021).

However, recent European and national parliamentary elections have also pointed to growing polarization of political forces on both sides of the climate debate. While green pro-EU parties made substantial gains during the 2019 European elections, there was also rising support for right-wing populist parties, many of which deemphasize or oppose climate action (Reference WaldholzWaldholz 2019). Beyond electoral arenas, climate change politics in Europe have become more confrontational and fractious as pro-climate pressure groups and constituencies experiment with new social media platforms and direct action to voice discontent, from Extinction Rebellion’s nonviolent civil disobedience to the youth-led climate strikes.

Growing polarization is evident not just in climate politics but also in the wider debate on European integration, which revolves around broader questions related to EU effectiveness and legitimacy, as well as entrenched power asymmetries between member states (Reference FabbriniFabbrini 2015). This debate also puts the spotlight on the role of the European Commission, an institution that has historically sought to advance expert-based policymaking outside the politics stream, relying on technocratic rather than democratic legitimacy (Reference ShapiroShapiro 2004: 345). In practice, the Commission increasingly operates at the interface of technocracy and politics. The election of the Commission President, for example, is no longer a barely noted administrative turnover but a highly political event. As we explore further below, the launch of the EGD was in many ways a political maneuver by the von der Leyen Commission, necessary to ensure support from the European Parliament as well as the European Council. Politics also plays out in the day-to-day work of the Commission, including in the form of internal power struggles and conflicts arising from overlapping responsibilities.

Politicization of climate change is likely to increase further as the EU and its member states have to contend with growing conflict over the distributive consequences of ambitious decarbonization policies. Absent robust government intervention to ameliorate social inequity, the costs, and benefits of climate policies are likely to be highly unevenly distributed across populations, fueling popular backlash (Reference Abrams, Dietzel and HammondAbrams et al. 2020). Consequently, Level II politics can be expected to become increasingly consequential for climate policymaking at Level I (Reference Aklin and MildenbergerAklin and Mildenberger 2020). While this means contending with powerful veto-players – from populist governments to domestic lobby groups to protest movements such as the “yellow vests” in France – there is also potential for vocal domestic pro-climate constituencies to push for more ambitious action. Encouragingly, in some member states that are generally considered climate laggards, growing public concern and grassroot mobilization on climate change appears to have facilitated some policy change. In Ireland, for example, where extensive lobbying by business and agricultural groups has long constrained political preferences, recent spikes in public interest have “directly influenced” political decision-making on climate change, resulting in stronger legislation (Reference O’Gorman, Robbins, Torney and BreretonO’Gorman 2020: 87). Even in Poland, there is indication that growing concern over climate change and local air quality has triggered concrete, if modest, policy responses (Reference Elkind and BednarzElkind and Bednarz 2020).

5.2.1 Multilevel Reinforcement and the EU-ETS: Putting Kyoto into Practice

The 1997 Kyoto Protocol proved a watershed moment for the EU, leading to the introduction of the first regional ETS. As one observer comments, “you might be able to draw a direct causal line between the design of the Kyoto Protocol and the shape of European climate and energy policy” (Interview EU Commission). The establishment of the ETS represented a genuinely non-incremental policy shift, given that the EU had originally been strongly opposed to emissions trading and the other flexibility measures that had been included in the Kyoto Protocol upon the insistence of the United States (Reference Delbeke and VisDelbeke et al. 2015). Importantly, while the Kyoto Protocol introduced the possibility of carbon markets, it did not prescribe any specific policies. Thus, Kyoto participation alone cannot explain the EU’s subsequent embrace of emissions trading as its flagship mechanism to deliver on international commitments. To explain this puzzle, developments across the EU problem, policy, and politics stream during the late 1990s and early 2000s must be understood within an increasingly dynamic multilevel setting.

In the problem stream, mounting scientific evidence on anthropogenic climate change and its impact (EEA 1999; IPCC 2001) invigorated the EU’s commitment to deliver upon its international obligations. The EU had been particularly proactive during the Kyoto negotiations, notably committing to a higher emissions reduction target than other industrialized state parties, namely 8 percent between 2008 and 2012 compared to 1990 levels (Reference Van Schaik and SchunzVan Schaik and Schunz 2012). However, as yet, no internal measures and common policies existed within the EU to drive forward action toward this goal. Although GHG emissions across the EU fell throughout the early 1990s, this was mainly a result of structural changes in the economy of key member states, above all German reunification and the shift from coal to gas in the United Kingdom (Reference Oberthür and Roche KellyOberthür and Roche Kelly 2008). The slow pace of internal climate policy development and the lack of operational infrastructure to deliver on EU-wide GHG cuts resulted in a sizeable “credibility gap between international promises and domestic implementation” (Reference Oberthür and Roche KellyOberthür and Roche Kelly 2008: 39).

In the policy stream, the Commission established itself as the main entrepreneurial agent. This was partly a result of leadership changes within DG Environment, in particular the replacement of climate change unit leader Jørgen Henningsen with Jos Delbeke, who, as an economist, had a particular interest in carbon pricing and became a driving force behind the development of the ETS (Environmental Reference InsightsInsights 2020). As it started exploring options for an EU-wide emissions trading scheme, the Commission also took developments on other governance levels into account. Given that some member states – namely the United Kingdom and Denmark – were already experimenting with emissions trading, the Commission’s interest in an EU-level scheme was in part motivated by the desire to prevent the emergence of a fragmented European emissions trading landscape (Reference Grubb, Laing, Sato and CombertiGrubb et al. 2012). There was also an expectation that the establishment of the ETS would facilitate the development of a global carbon market, providing opportunities for linkages to other trading schemes and international initiatives (Reference BraunBraun 2009). Because the Commission itself did not possess much policy-relevant knowledge on emissions trading, it relied heavily on other actors for input (Reference Skjærseth and WettestadSkjærseth and Wettestad 2010). These included experts and consultants, environmental NGOs, business associations, and individual companies such as BP and Shell, which already had some experience with internal emissions trading (Reference BraunBraun 2009).

In the politics stream, the post-Kyoto moment presented an opportunity for the EU to demonstrate its capacity to act as a coherent and principled foreign policy actor. When the United States withdrew from Kyoto in 2001, the EU invested significant political capital in ensuring the survival of the Protocol. The EU’s, ultimately successful, bid to rescue Kyoto “became not just an environmental goal but also a key aim of an emergent EU foreign policy by heightening European identification with the Kyoto Protocol” (Reference TorneyTorney 2015: 49). Thus, the EU’s political ambitions on the international stage provided additional impetus for the rapid development of EU-level policies. With regard to the design of such policies, emissions trading proved politically more palpable for member states than other options, notably plans for a carbon and energy tax previously advanced by the Commission.

The EU Emission Trading Directive was adopted by member states and the European Parliament in 2003 and the ETS became operational in 2005. During its initial two phases, it functioned in a very decentralized manner, granting significant autonomy to member states in terms of setting an overall cap for emissions. In addition, most allowances were freely allocated, rather than auctioned, and industry could use cheaper external credits from the Kyoto Protocol’s flexibility mechanisms to comply (Reference LeeLee 2014). These design flaws significantly weakened the environmental integrity and performance of the ETS. Nevertheless, the combination of EU measures taken during the first half of the 2000s likely had a substantial decreasing effect on GHG emissions in the second half of the decade (Reference Dupont, Oberthür, Bäckstrand and LövbrandDupont and Oberthür 2015), allowing the EU to overdeliver on its 8 percent emissions reductions commitments under the first Kyoto commitment period (EEA 2013). Such progress at EU level, however, stands in in stark contrast to the overall failure of Kyoto to galvanize concerted global action on GHG emissions which continued to increase at record rates until 2009 (IEEP 2020).

As this case illustrates, the inception of the ETS cannot be explained by focusing analysis on merely one level of governance. The European Commission emerged as a key entrepreneurial actor involved in orchestrating multilevel knowledge exchange and bringing together the problem, politics, and policy streams across various levels of governance. Crucially, the Commission knew that the Decision Window, dependent upon interest congruity at Level II, would remain shut for alternative policy instruments such as taxes and other fiscal levers, which – in contrast to emissions trading – required unanimous endorsement by member states. Political feasibility informed agenda choice from the start, with the Commission demonstrating not just analytical and managerial expertise but also the political acumen necessary to understand and navigate the needs and positions of different stakeholders in the decision-coupling phase (Reference Mukherjee and GiestMukherjee and Giest 2017: 11). The need to balance policy effectiveness and political feasibility explains many of the initial design flaws of the ETS, with the Commission seeking “to get the scheme underway in a form that elicited the most agreeable response by Member States and industry as well as environmental stakeholders while planning to delay some stricter restrictions to later development stages” (Reference Mukherjee and GiestMukherjee and Giest 2017: 14). Formulating ambitious policy alternatives that work in the political moment of the time remains a key challenge for European policy entrepreneurs. As we explore below, this was particular true during the aftermath of the Copenhagen climate conference and the economic crisis, when Decision Windows in the EU narrowed considerably.

5.2.2 Post-Crisis Europe: A Period of Multilevel Stagnation?

Following the establishment of the EU-ETS, most of the 2000s saw a further expansion of EU climate policies, including, most notably, the adoption of the first Climate and Energy Package, which enshrined three headline targets for 2020: (1) cutting GHG emissions by 20 percent from 1990 levels; (2) increasing the share of renewable energy sources to 20 percent; and (3) improving energy efficiency by 20 percent. These policies were consciously designed to enable positive “multi-level reinforcement, extending to the sub-national levels” (Reference Jänicke and QuitzowJänicke and Quitzow 2017: 123). For example, the Commission set up the Covenant of Mayors in 2008 with the aim of facilitating the implementation of the Climate and Energy Package at city level and the subsequent upscaling of best practices (Reference KernKern 2018). However, toward the end of the 2000s, and following the financial and economic crisis, the window of opportunity for ambitious EU-level action closed, partly as a result of negatively reinforcing multilevel dynamics. In particular, the failure of the 2009 Copenhagen climate summit to deliver a Kyoto successor treaty meant that climate-progressive voices at Level I could no longer use the policy parameters set at UNFCCC level as a lever to bolster joint climate policymaking (Reference Fischer and GedenFischer and Geden 2015). At Level II, the post-2008 recession deepened divisions between member states on whether climate policies are necessary or detrimental for economic growth (Reference SkovgaardSkovgaard 2014). Meanwhile, post-crisis public spending in the EU largely supported a fossil fuel driven recovery, also emboldening lobbying efforts by status quo industry interests at the domestic and European levels (Reference FernandezFernandez 2018). These dynamics all contributed to relative stagnation across the problem, politics, and policy streams.

At the turn of the decade, Europe started to feel the full fallout of the financial and economic crisis and the ensuing sovereign debt crisis. In the problem stream, concerns over unemployment, economic competitiveness, fiscal stability, and the future of European integration consequently crowded out climate-related concerns. This change in perception of problem urgency was also reflected in public surveys, with the percentage of Europeans seeing climate change as one of the most pressing global problems steadily declining post-2008 (Reference NgDuijndam and van Beukering 2020).

Meanwhile, activities in the policy stream slowed as much of the Commission’s previous entrepreneurial spirit had seeped away. Divisions between (and within) DG Energy and DG Climate Action could be exploited by less progressive factions of the Commission and also made those factions more accessible to business lobbying (Reference BürginBürgin 2014; Reference Fuchs and FeldhoffFuchs and Feldhoff 2016). Moreover, in the absence of a new international treaty, climate-progressive voices within the Commission found it more difficult to develop a normative justification to significantly ramp up EU climate action. The Copenhagen summit had not just been a disappointment for the EU but also “a nadir for EU climate leadership” (Reference Walker, Biedenkopf, Minas and NtousasWalker and Biedenkopf 2018: 36), with European negotiators finding themselves largely sidelined, while the United States, China, and other emerging economies hammered out the nonbinding Copenhagen Accord. The EU had gone into the negotiations with a conditional offer to increase its own 2020 emission reduction target from 20 percent to 30 percent if other key countries committed to comparable efforts. Yet, this failed to convince the United States and others of the need for binding targets, dampening member states’ enthusiasm for the EU’s long-standing strategy of “leading by example” in global climate governance (Reference Oberthür and DupontOberthür and Dupont 2011). Although the Commission made an attempt to unilaterally scale up ambition despite the Copenhagen outcome, it quickly gave in to pressure by member states and business groups, conceding that conditions for updating the EU’s emission reduction target were “clearly not met” and citing “uncertainties” surrounding implementation of the Copenhagen Accord (European Commission 2010). Thus, whereas in earlier policy debates, international commitments had provided leverage to climate-progressive voices, “in the post-Copenhagen period, the changed circumstances were the most frequently cited argument for less ambitious targets” (Reference Fischer and GedenFischer and Geden 2015: 4–5).

In the politics stream, the EU now felt the “delayed political impact of the EU’s eastern enlargement on climate policymaking” (Reference Fischer and GedenFischer and Geden 2015: 1). Poland emerged as a key veto player to more ambitious EU climate policy, backed by several other “new” member states. Yet, these states were not the only ones dragging their feet on more ambitious climate policies. As Reference BürginBürgin (2014: 700) notes, a “lapse in leadership” from the traditionally climate-progressive member states encouraged laggards to be more assertive. This meant that slackening policy entrepreneurship in the agenda-coupling phase at Level I was accompanied by a lack of political entrepreneurship at Level II (Reference Herweg, Huß and ZohlnhöferHerweg et al. 2015) during the decision-coupling phase. The political landscape in the European Parliament also changed as growing EU skepticism manifested itself in the rise of nationalist-populist movements. The 2014 European parliament elections produced a “big bang” of populist, anti-EU parties whose agendas often reflected hostility toward climate action (Reference Martín-Cubas, Bodoque, Pavía, Tasa and Veres-FerrerMartín-Cubas et al. 2019).

While climate policy development in post-crisis Europe did not come to a halt altogether, it moved forward in a more incremental manner, with shrinking opportunities for policy entrepreneurs to push for path-departing change. In some cases, ambition had to be dropped significantly to push policy proposals through narrow Decision Windows. In other cases, Decision Windows remained shut. For example, although the EU began, for the first time, to explore in earnest the implications of a long-term climate target, namely, to reduce GHG emissions by 80–95 percent by 2050, the resulting low carbon roadmap for 2050, presented by the Commission in 2011, never received political endorsement from the Council due to a Polish veto. Even within the Commission, as one observer notes, a serious commitment to a mid-century target was seen as “too ambitious” and “not helpful” by many (Interview NGO Stakeholder). A new Energy Efficiency Directive, adopted in 2012, was watered down in the legislation process, providing member states with a number of exclusions and exemptions and high levels of discretion in implementing the directive (Reference ZygierewiczZygierewicz 2016). In 2013, planned EU regulations on reducing emissions from passenger cars were weakened after German chancellor Angela Merkel personally intervened in support of the car industry (Reference CarringtonCarrington 2013) and the credibility of EU regulatory efforts in the area was reduced even further in the aftermath of the 2015 Dieselgate scandal (Reference Becker and TraufetterBecker and Traufetter 2016).

In October 2014, after tense negotiations, EU leaders managed to agree on a second Climate and Energy Package, which introduced new headline targets for 2030: reducing GHG emissions by at least 40 percent from 1990 levels, increasing the share of renewable energy to 27 percent (binding only at EU level), and improving energy efficiency by 27 percent (indicative target). This was not an ambitious outcome as targets “did not go far beyond what would be reached with existing policies and, most importantly, were (partly) defined as ‘non-binding’” (Reference Fuchs and FeldhoffFuchs and Feldhoff 2016: 58). According to Reference CareyCarey (2015: 7), the lack of nationally binding renewable energy targets was “partly a result of the perception that Brussels had been too intrusive in the case of the 2020 package,” with member states wanting more control over their national energy strategies and energy mixes. It also reflected the result of intense lobbying by businesses, who had privileged access to high-level insiders, notably then-energy Commissioner Günther Oettinger (Reference Fuchs and FeldhoffFuchs and Feldhoff 2016; Reference Fitch-Roy, Bensons and MitchellFitch-Roy et al. 2018). Thus, as the EU went into the 2015 Paris negotiations, its internal policies largely reflected political achievability and concerns over cost-effectiveness rather than scientific urgency.

5.2.3 Multilevel Reinforcement and the European Green Deal: Putting Paris into Practice

Even after the adoption of the 2015 Paris Agreement, EU climate ambition was initially slow to pick up. Climate change did not enjoy the highest political priority in the face of other urgent challenges, from continued worries over economic growth to the refugee and migrant crisis, Brexit, and heightened security concerns over terrorism and a resurgent Russia. Policy action focused primarily on updating regulation in order to comply with the existing 2030 emissions reduction target. However, since 2018, multilevel reinforcement dynamics and a coming together of the problem, politics, and policy streams have moved climate change back up the policy agenda, culminating in the EGD.

Although many of its components build on existing EU policies and regulations, the EGD has been described as “revolutionary in concept” (Reference TsafosTsafos 2020). For the first time, it lays out an integrated, long-term plan for the transition toward a climate-neutral Europe by 2050, covering all sectors of the economy and also addressing issues such as waste, pollution, biodiversity, and sustainable food consumption. The EGD has been promoted by the Commission as “a new growth strategy” for Europe (Reference Von der Leyenvon der Leyen 2019), and in the wake of the COVID-19 pandemic, it has become a key part of its economic recovery strategy (Reference Dupont, Oberthür and von HomeyerDupont et al. 2020). The EGD also explicitly addresses the distributional consequences of decarbonization through a Just Transition Mechanism, designed to support fossil fuel–dependent regions in the transition toward net-zero and to get recalcitrant member states, notably Poland, on board. Another central element of the EGD is the European Climate Law, which turns the EU’s 2050 climate neutrality objective into a legal obligation. The law also enshrines the EU’s 2030 emissions reduction target, which has been raised from 40 percent to at least 55 percent to ensure consistency with the 2050 target and to demonstrate higher ambition in line with the Paris Agreement’s five-yearly ratchet mechanism (Reference SkjærsethSkjærseth 2021). Thus, as with previous EU climate policy outcomes, the emergence of the EGD cannot be fully understood without taking into account interactions between the international, regional, national, and sub-national levels.

In the problem stream, the publication of the IPCC’s Special Report on Global Warming of 1.5°C in 2018 was instrumental in raising awareness of the urgency and complexity of the climate change challenge (IPCC 2018). A Commission communication in November 2018 first introduced the vision of a climate-neutral Europe by 2050, explicitly citing the need to “respond to the recent IPCC report” and “lead the way worldwide” (European Commission 2018). This was also a direct response to the Paris Agreement which “really refocused the discussion on the mid-century goal and the long-term need for serious transformation” (Interview NGO Stakeholder). The sense of urgency was underscored by real-life events, as droughts and heat waves in Europe reached unprecedented levels, both in terms frequency and severity (Reference Büntgen, Urban and KrusicBüntgen et al. 2021). Climate change now polled as the second most important problem facing the EU in Eurobarometer opinion surveys (Eurobarometer 2019). The declaration of a “climate and environmental emergency” by the European Parliament, following similar declarations by European cities, regions, communities, and states, confirmed that global warming was being recognized as a top concern (Reference RankinRankin 2019).

In the policy stream, momentum for long-term, whole-economy strategic planning had been building up for some time. Important foundations for the EGD and the European Climate Law had already been laid, for example, in the form of the 2018 Governance Regulations. As such, the EGD can be seen as the culmination of a longer process of climate policy transformation in the EU, “from narrow, separate climate and energy policy initiatives to broader coordinated packages aimed at achieving increasingly ambitious climate targets” (Reference SkjærsethSkjærseth 2021: 26). The concept behind the European Climate Law also has a long history. Similar framework legislations had already been established in several member states before the Commission picked up the idea at a politically opportune moment. The international context also shaped opportunity structures for policy change. Both the Paris Agreement and the IPCC’s 1.5°C report set the framework for a transition to net-zero by 2050, providing leverage for EU-level actors in support of increasing ambition (Reference SkjærsethSkjærseth 2021). In contrast to the Copenhagen experience, the EU had played a key role in the negotiations at Paris and managed to achieve many of its policy objectives, meaning that leading European Commission officials were able to evoke a sense of ownership and stake in the implementation of what was seen as a “major win for Europe and its allies” (Reference CañeteCañete 2015).

In the politics stream, important changes at Level I included electoral gains for European green parties, as well as the confirmation of a new Commission under the leadership of Ursula von der Leyen, who immediately declared climate a “signature issue” (Reference FarandFarand 2019). Indeed, observers expressed surprise at “how aggressive the push by this new Commission has been” (Interview UNFCCC). Others concur that it “was a very hard-won battle” (Interview NGO Stakeholder). As Reference MuntaMunta (2020) argues, it was partly due to the political contestation that accompanied von der Leyen’s appointment that she made environmental sustainability a priority part of the Commission’s work program. Her backroom nomination by the European Council left von der Leyen “in desperate need of a strong programmatic statement which would pacify the EP and simultaneously signal responsiveness to the European Council” (Reference MuntaMunta 2020: 8), with green transitional policies promising the greatest overlap of interest.

Bottom-up pressure for more ambitious climate policies was also building up. 2019 saw unprecedented levels of public engagement on climate change, as evidenced by significantly increased media coverage (Reference Pianta and SiscoPianta and Sisco 2020) as well as the success of the Fridays for Future strikes. This broader change in political mood at Level II also helped facilitate agreement on the EGD and stronger climate targets in the European Council. In December 2019, the Council endorsed the long-term goal of a climate-neutral EU by 2050. Although Poland secured an opt-out from implementing this objective, other EU leaders agreed to press ahead and two other hold outs – the Czech Republic and Hungary – dropped their resistance after securing guarantees on nuclear energy. In December 2020, after arduous negotiations, all member states agreed to the updated 2030 target (Reference Mathiesen and OroschakoffMathiesen and Oroschakoff 2020). Thus, while Decision Windows were by no means wide open, leaders within countries that supported stronger climate goals were willing to act as political entrepreneurs (Reference Herweg, Huß and ZohlnhöferHerweg et al. 2015), facilitating decision-coupling through concessions and “carrots” such as the Just Transition Mechanism.

While the holistic approach of the EGD has been broadly welcomed by green campaigners, business associations, and other stakeholders, many of its specifics have invited fervent criticism. Above all, the 2030 emissions reduction target of at least 55 percent has been criticized as insufficiently ambitious. Going forward, a key question is how resilient commitment to the EGD will be in the wake of major crises such as the COVID-19 pandemic and the war in Ukraine. Both events provide strong reason and ample opportunity for more ambitious climate action; however, at the same time, they may divert political attention and resources away from the net-zero transition. As Reference Dupont, Oberthür and von HomeyerDupont et al. (2020) argue, the political salience of the climate crisis enabled the Commission to provide continued policy entrepreneurship in the wake of the pandemic, joining forces with other stakeholders to turn the COVID-19 crisis into a window of opportunity and putting the EGD at the center of its recovery strategy. In contrast, the immediate threats to energy security resulting from the war in Ukraine have prompted some member states to resort to short-term solutions, such as an extension of coal use or the development of new infrastructure for liquefied natural gas (LNG), which risk strengthening fossil fuel dependency. It is too early to predict the long-term effects of COVID-19 and the Russian invasion of Ukraine on international, European, and national climate policymaking. Yet, the EGD clearly provides opportunities to link these and other global crises to the climate challenge. Moreover, the adoption of the European Climate Law makes it more difficult to deviate from agreed climate targets. As the Commission’s Frans Timmermans emphasized, the fundamental idea behind the law is precisely to make sure that more immediate crises do not distract from these long-term objectives: “it allows you to focus on other things without losing track of what you need to do to reach climate neutrality” (qtd. in Reference RankinRankin 2020).

6.1.1 Problem Stream

Since the Rio Earth Summit of 1992, where the Climate Change Convention was first agreed upon, governments of AMS have largely sought to deprioritize the problem of climate change. While ASEAN leaders did acknowledge the science of climate change and the necessity of global action, they did not accept that they should bear responsibility for it. From ASEAN’s adoption of the Berlin Mandate at COP-1 to post-Paris Agreement, AMS have continued to prioritize economic development over climate goals. This was despite AMS largely accepting IPCC findings and recognizing their own vulnerability to climate change. AMS have attempted to use UNFCCC fora to “upload” their own policy preferences: to push for developed countries to (i) increase their own legally binding contributions to reflect historical emissions trajectories; and (ii) provide more generous financial and technical assistance to developing countries.

A significant stumbling block to climate negotiations between Annex-I and non-Annex parties has been different interpretations of the “common but differentiated responsibilities” (CBDR) principle. While the EU sees itself as taking on a leadership role, it also sees the responsibilities of developing countries as flexible and evolving. For AMS, on the other hand, the CBDR principle is taken to mean that the burden of mitigating climate change falls squarely on developed countries (Reference Goron, Rueppel and HofmeisterGoron 2014: 109). This has led to gridlock in negotiations between more progressive climate leaders such as the EU, and non-Annex parties like the AMS, particularly in negotiating a successor to the Kyoto Protocol.

The framing of the policy problem in ASEAN (Level I) has remained largely limited because problem frames are almost always advanced by political and economic elites. ASEAN does indeed have some agenda-setting power through the chair, which rotates annually and alphabetically among members. Like the EU, rotating chairs can set the agenda with climate change formally on the ASEAN agenda since the Bangkok declaration of 2012. However, unlike the EU, the climate agenda has been limited because it is only state actors who get to set the agenda (see Figure 5). ASEAN’s strategy of economic growth is described to be exclusionary in that it consistently excludes competing agendas, particularly in the space of human rights broadly defined, that contest entrenched models of economic development within individual states (Reference GerardGerard 2014). ASEAN’s attempts to engage with regional civil society has also been highly troubled – groups with agendas incompatible with ASEAN’s preferred growth model, including certain environmental NGOs and activists, have been excluded from regional policy forums (Reference GerardGerard 2014).

Figure 5 Decision-making in ASEAN

The ability of ASEAN to produce more substantive responses to the climate emergency and act as a regional “problem broker” is further undermined by low value congruence as, compared to the EU, the region straddles considerable economic and geographical diversity. AMS belong to different, and sometimes overlapping, groups in climate negotiations and have not managed to speak with a united voice. The China-led G77, where almost all AMS are members, is highly diverse and its position in climate negotiations has been described as a “lowest common denominator” approach that reflects this diversity (Reference Goron, Rueppel and HofmeisterGoron 2014: 105). As a result, ASEAN lacks a “common narrative” in negotiations and regional joint statements on COPs do not stand out from G77 statements (Reference Goron, Rueppel and HofmeisterGoron 2014: 108). Instead, AMS have participated in a range of diverse coalitions such as the Association of Small Island States (Singapore, somewhat inappropriately), the Like-Minded Developing Countries coalition (Indonesia, Malaysia, Philippines, Vietnam), the Least Developed Countries group (Cambodia, Myanmar, Laos until 2019), the Cartagena Dialogue for Progressive Action (Thailand, Indonesia), and the Coalition for Rainforest Nations (Indonesia, Laos, Malaysia, Thailand, Vietnam) (Reference Goron, Rueppel and HofmeisterGoron 2014: 105). This diversity is further complicated by ASEAN’s consensus model of decision-making where nothing is purportedly done without the consent of all ten members.

Despite these obstacles, developments leading up to the ratification of the Paris Agreement have facilitated modest progress in getting AMS to pay more substantial attention to the policy problem. This has worked in three interrelated ways. Firstly, the change of tact by climate leaders in engaging with the global south following the failures of Copenhagen in 2009 resulted in a more “bottom-up” Paris Agreement. The voluntary nature of Paris encouraged AMS to develop their own climate initiatives in return for funding and technical support. This facilitated opportunities for problem framing focused on both mitigation and adaptation, with climate initiatives such as the REDD+ program which seeks to minimize forest degradation being adopted in Vietnam and Indonesia (Reference HicksHicks 2019; Reference PinanditaPinandita 2020).

Second, adverse climate events have led to some acknowledgment among ASEAN leaders of the severity of the problem. In particular, the annual transboundary haze, caused by forest fires in Indonesia that spread to neighboring Malaysia and Singapore, is a significant “focusing event” that regularly causes social and economic disruption. Coupled with the findings of the fourth and fifth IPCC assessment reports (2007 and 2014), this created an urgent sense among ASEAN leaders that climate change was indeed a threat to economic growth and livelihoods in the region.

Finally, as Southeast Asian economies become increasingly globalized, large domestic firms with strong political ties are facing pressures from international investment and consumer markets for private-sector climate disclosure and environmental and sustainability governance (ESG). This external pressure has prompted ASEAN governments to reframe the problem of environmental degradation as a problem of market access at a time when state development priorities are increasingly contingent on national economies being integrated into global markets.

These three developments contribute toward a very limited agenda-coupling where climate change is recognized but subjected to the priority of economic growth. Post-Paris, climate change in ASEAN (Level I) is framed primarily as a sustainable development issue with the emphasis on the need for financial and technical assistance. Within member states (Level II), there is some diversity on how the problem is framed. In more industrialized countries like Thailand, the problem of climate change is often connected to the vexing issue of domestic energy demand which is heavily reliant upon fossil fuels for its energy needs (IEA 2020). In Singapore, the problem is often framed as a market opportunity within the context of the country’s post-industrial economic transition (National Climate Change Secretariat 2020). In economies dominated by extractive industries, such as Indonesia, the problem of climate change takes second place to the imperative of better management of natural resources to derive continuing economic benefit for politically influential agribusinesses (Reference Wijaya, Chrysolite and GeWijaya et al. 2017). Overall, the framing of sustainable development post-Paris has allowed individual AMS to claim that dealing with climate change is compatible with economic growth priorities.

Within these limitations, NGOs and think tanks have nonetheless sought to reframe the policy problem at the national level (Level II) through public and closed-door advocacy with national governments and domestic industry. For instance, climate NGOs in Singapore have also sought to radically reframe the policy problem by challenging the government’s narrow narrative on climate change. In 2020, the Activism in Crisis initiative, organized by a network of domestic NGOs including SG Climate Rally and Speak For Climate, sought to expand the problem frame of the climate crisis to include social justice and economic equity issues on the basis that “those who are already excluded by society and who contribute the least towards the climate crisis will be affected most by it” (Activism in Crisis 2020). However, such radical initiatives are rare in the region where climate agenda-setting at Level I continues to be monopolized by ASEAN elites and civil society actors are routinely subject to repression (see politics stream below). As a result, sustainable development has been seized upon in the ASEAN context as a means to legitimate economic growth in the context of environmental protection – to the detriment of problem frames which would compel a robust policy response in the form of stringent regulation of industrial development.

6.1.2 Policy Stream

The climate policy stream in ASEAN demonstrates a strong normative preference for facilitative and flexible solutions. ASEAN climate policy eschews intrusive supranational regulations and collective target-setting that characterize the EU approach. Instead, ASEAN climate governance consists largely of a series of “soft laws” that provide member states with a range of optional policy instruments and guidelines that they could adopt at home. Regional climate policy is largely organized under the purview of the ASEAN Working Group on Climate Change (AWGCC), formed in 2009, as a consultative body that would support coordination and collaboration between sectoral bodies of AMS.

Insider policy entrepreneurs at the AWGCC (Level I), often ASEAN bureaucrats and scientists, selectively “download” and develop a range of potential policy solutions from various global platforms that include natural resource management systems, coastal rehabilitation systems, biodiversity management and ecosystem rehabilitation tools, and peatland management systems (ASEAN 2018). At the same time, other regional platforms, particularly the AATHP, and the APG, organized under the purview of the ASEAN Economic Community (AEC), also provide climate-relevant policy solutions for member states. AEC initiatives are often promoted by neoliberal technocrats or economists within ASEAN (Level I) forwarding market-integration agendas (Reference JonesJones 2015: 6). With the exception of the Haze Agreement which is legally binding, these “downloaded” and adapted tools serve as a set of regulatory guidelines for member states to pursue their own environmental or energy market agendas, and provide platforms for knowledge-sharing, collaboration, and capacity-building. While they facilitate policy-transfer and capacity-building, current regional policy options, bereft of emissions and decarbonization targets, do not sufficiently drive the required climate ambition.

The search for collective climate solutions is a significant challenge for a region as diverse as ASEAN. AMS have significant differences in emissions profiles with vastly different national-level climate targets underpinned by different levels of state capacity and readiness. Singapore has emerged as a regional first mover when it comes to adaptation, in the form of desalination capacity, land reclamation, and sea walls to address rising sea levels. However, the country has not demonstrated any leadership at the regional level, though it strives for global market-leadership in green investments. There are perhaps limits to Singapore’s ability to serve as a regional exemplar given that its emissions profile is relatively unique in the region with a large proportion attributable to the petrochemical industry, an almost nonexistent forestry sector, and – also unlike the rest of the region – an energy mix that is almost entirely reliant upon natural gas (96 percent).

In contrast, the region’s largest emitter, Indonesia, must contend with a large proportion of its emissions originating in the forestry sector and its national climate plan rests heavily on reducing emissions from forest degradation. However, politics often has the final word on implementation. The Pakatan Harapan government in Malaysia (2018–2020) is indicative of the political contestation underlying climate policy, with the ruling coalition containing several rivalrous constituencies with some factions promoting progressive climate policies in opposition to others engaged in vigorous lobbying for the country’s controversial palm oil industry (Reference VarkkeyVarkkey 2019). Even among the progressive faction, progressive climate policies did not translate into concrete development of measurement, reporting, and verification (MRV) capacities as required by the Paris Agreement (Reference YeoYeo 2018). When it comes to less developed AMS like Cambodia, Myanmar, and Laos, country-level capacity and resource constraints impede any move toward developing MRV capabilities, precluding the possibility of monitoring state or corporate emissions, let alone instigating an ETS (UNFCCC 2019). Unfortunately, pledges made in 2009 at the Copenhagen COP promising climate financing of $100 billion per year by 2020 to developing nations has failed to materialize (Reference Carty, Kowalzig and ZagemaCarty et al. 2020). ASEAN itself has no financing mechanism to assist poorer member states with the Asian Development Bank providing the main source of climate financing within the region, albeit with very limited funding for technical assistance (ADB 2021).

While the EU account demonstrates a competitive arena for potential regional-level policy solutions, albeit variable over time and within limits set by its commitment to technocratic institutionalism, exclusivist regional (Level I) and national (Level II) participatory structures in ASEAN place severe constraints on who is allowed to propose and advance policy alternatives. Relatively weaker levels of political accountability and participation in Southeast Asia have deep social and historical foundations. Cold War era economic development in pro-capitalist regimes saw the often-violent repression of independent civil society and the empowerment of regime-linked business interests (Reference RodanRodan 2018: 44; Reference Carroll, Carroll, Hameiri and JonesCarroll 2020: 46). In the state-socialist regimes of Indochina, independent organizations were all but wiped out during this period of state reprisals. While subsequent processes of democratization produced divisions among elite factions and enabled a fragile reemergence of civil society in certain countries, the latter have never fully recovered from the often-brutal repression during the Cold War era. Organizational weakness within civil society has been further exacerbated by economic globalization and the neoliberal reforms of the post-Cold War era that increased the mobility and power of capital (Reference RodanRodan 2018: 44).

These historical developments have produced illiberal regional and national institutions that are largely designed to satisfice the interests of key politico-business coalitions, while silencing or containing the policy preferences of non-elite actors. Indeed, not all policy entrepreneurs are made alike as regional and domestic policymakers often exclude or marginalize groups with agendas that run contrary to preferred models of economic growth. An excellent example of this phenomenon is Singapore’s Emerging Stronger Taskforce which was formed to much fanfare in May 2020 to ensure that the country’s post-COVID economic recovery has a strong focus on “green growth.” Indicative of its function, the Taskforce is entirely composed of establishment and industry figures, including the Asia-head of Exxon Mobil and includes no civil society representation (Reference HicksHicks 2020). While industry groups were invited to collectively propose policy solutions for recovery through the Alliances for Action initiative, citizen participation was relegated to a “dialogue series” for individuals called the Emerging Stronger Conversations (Reference TanTan 2020). At the regional level, while ASEAN has sought to buttress its legitimacy through greater engagement with civil society on policymaking following the Asian Financial Crisis, it has systematically excluded human rights and environment activists and groups whose agendas threaten dominant interests (Reference GerardGerard 2014).

These exclusivist participatory structures work in practice to narrow the range of acceptable policy alternatives to the status quo, given that grassroots activists, NGOs, and think tanks have been key vectors for the diffusion of ambitious metagovernance norms in the region. The World Resources Institute (WRI) Indonesia, for example, is a well-resourced and prominent advocate for inserting the influential Science-Based Targets (SBTs) into the accountability structure and operational decisions of industry and government. Acting as a policy entrepreneur, WRI Indonesia has attempted to enhance transparency around carbon emissions by pushing for “data loops”Footnote ¹ that could be used to ratchet up climate ambition on the part of government bodies and the private sector (Reference Dagnet, Cogswell, Grinspan, Reichart and DrewDagnet et al. 2019a).

Within the broader NGO sector, one climate activist from Singapore reports that they build strategy by “cherry-pick[ing] the best practices that are supported by science and implemented well in other contexts” (Interview with NGO stakeholder, Singapore). Other activists interviewed cited a broad range of “influences” on their advocacy strategies including IPCC reports and recommendations, more ambitious climate targets of other states, peer-reviewed climate science research, UK-based think tank Common Wealth, and even political ideologies like eco-socialism. However, their potential to exert influence is limited by the fact that many of these organizations lack a significant “social base” of support in society, and as such, find it difficult to gain political traction at a national level. Environmental NGOs in Indonesia, for example, have achieved important policy victories working closely with and advocating for local communities directly impacted by specific environmental disasters but this kind of activity generally fails to cut through at the national level.

For their part, private sector actors exposed to global consumer and investment markets have also begun to advance climate policy alternatives. Politically protected industries in the region have begun to advocate for carbon disclosure and transparency initiatives in response to the proliferation of ESG standards within global industries, as they seek to diversify their investment portfolios and expand beyond national borders (Reference Al-Fadhat, Carroll, Hameiri and JonesAl-Fadhat 2020). Public endorsement from national government has duly followed in some countries, such as Singapore. Elsewhere, the private sector has sought to reassure international investors by proactively filling the gap left by inconsistent state regulation, such as in Indonesia. The proliferation of private sector sustainability standards in the region, however, is haunted by the specter of greenwashing (Reference Berliner and PrakashBerliner and Prakash 2014). Private metagovernance norms such as ESG standards are often “downloaded” selectively and presented by business groups as “win-win” solutions which in reality resolve problems of market access but do little to address the underlying drivers of environmental degradation.

6.1.3 Politics Stream

In contrast to the EU, the politics stream in ASEAN is highly asymmetrical. Climate politics is informed by the region’s notoriously closed political economy dominated by powerful politico-business cliques with vested interests in sustaining carbon-intensive domestic industry. Reflecting the legacy of state corporatism in the region, climate policy obstructors are also often deeply enmeshed within the state apparatus, with national (Level II) and regional (Level I) institutions reflecting the extractive growth industrial preferences of this broad class of actors. Actors who fall outside this cabal have little access to political decision-making and highly circumscribed opportunities to put pressure on governments. It is possible that a nascent informal grassroots monitoring and advocacy sector could galvanize the kind of broad-based public support witnessed in Europe through the actions of Greta Thunberg and Extinction Rebellion. However, the challenge of building public support faces powerful structural constraints where regressive political forces will often exploit entrenched socio-economic inequity to frame climate change policies as contrary to the economic aspirations of the populace.

Despite some variation, the ASEAN region is heavily wedded to high-emission models of development centered on extractive industries dependent upon the use of fossil fuels (Reference Gellert, Carroll, Hameiri and JonesGellert 2020; Reference Hatcher, Carroll, Hameiri and JonesHatcher 2020). Such “resource dependency” is tied to the interests of dominant elite groups (often politically connected conglomerates), as well as diverse constituents which rely on these industries for their livelihoods. As noted in the EU chapter, many businesses located in developed countries will also offshore their emissions to jurisdictions with laxer regulations. Taken together, global and local business elites have historically sought domestic market dominance through political patronage (with the notable exception of Singapore) resulting in favorable economic policies, large state subsidies, and the marginalization of competing societal interests, such as organized labor. In return, pliable political elites have benefitted from private sector largesse with donations being channeled to their partisan support bases. Despite the economic and political upheavals of recent decades, such politico-business coalitions have endured and remain deeply entrenched within the state apparatus. Key industries plugged into global supply chains, particularly forestry, mining, and fossil fuels (notably coal and petroleum products), have long enjoyed the patronage of political elites and this is set to continue as global and domestic demand for energy and resources climbs ever higher (IEA 2021).

These local structural realities often determine the outcome of political contestation surrounding climate policy implementation, severely reducing opportunities for decision-coupling, particularly at Level II. A key policy instrument in Indonesia to curb emissions through halting deforestation – the Moratorium on Primary Forests and Peatlands – serves as a useful illustration. While the Moratorium, in place since 2011, has had some positive impact on deforestation rates, it also displays significant limitations (Reference Murdiyarso, Dewi, Lawrence and SeymourMurdiyarso et al. 2011; Reference Wijedasa, Sloan and PageWijedasa et al. 2018) with illegal fires frequently breaking out in protected areas (Greenpeace 2017). The Peatlands Restoration Agency identifies local “interest groups” and provincial- and district-level governments as key sources of policy corruption, with the agribusiness lobby enjoying close ties to local government officials (Badan Restorasi Reference GambutGambut 2016: 11–12). In forestry concession-heavy regions like Sumatra and Kalimantan, district heads are infamous for awarding forestry concessions to shell companies which are covertly owned by family members (Reference VarkkeyVarkkey 2015). Concessions are then sold to commercial agribusinesses with the district head and their cronies pocketing the proceeds, rather than the district government. For their part, agribusinesses continue to be major funders of local politicians’ election campaigns.

The energy sector in Indonesia is plagued by similar political issues that expand domestic demand for fossil fuels like coal. Indonesia is producing electricity in excess of domestic demand, and the present Widodo administration’s industrial development plan is based on significant expansions in coal power (Reference Arinaldo and AdiatmaArinaldo and Adiatma 2019: 4–5). Such deleterious environmental outcomes are a direct result of politico-business coalitions dominating the politics stream. Following substantial intra-elite friction in the lead up to the 2019 presidential election, President-elect Widodo formed a “grand coalition” of political allies and former rivals based around a national infrastructure project (Reference Renaldi and WiresRenaldi and Wires 2019; Reference Wijaya and NursamsuWijaya and Nursamsu 2020). This national project would allow prominent political officeholders and their backers to economically benefit from infrastructural developments in return for their political support, as well as gaining popular legitimacy for the new government by delivering on GDP growth. The role of coal in driving this project is notable as key political figures and their allies hold coal-mining concessions or financial stakes in coal-fired power plants. For instance, Widodo’s plan to move the Indonesian capital city from Jakarta to East Kalimantan will drive greater demand for electricity in the latter. Here, Widodo’s supporters and former rivals will be well-placed to benefit as several hold land concessions in that area. A 2019 report by several environmental NGOs names notable individuals who have stakes in companies with land concessions, coal mines, and coal-fired plants in the region (Forest Watch Indonesia et al. 2019). These include the Coordinating Minister for Maritime Affairs and Investment Luhut Panjaitan, prominent oligarch Hashim Djojohadikusumo (brother of current Defense Minister and former presidential candidate Prabowo Subianto), head of Widodo’s legal team Yusri Mahendra, and former Vice-President Jusuf Kalla (Forest Watch Indonesia et al. 2019, see also JATAM 2019). Predictably, the Indonesian government has continued to allow increases in coal production, with 2,000 new mining operations starting up in January 2018 alone.

Problems in the politics stream also manifest outside the domain of patronage politics. Some countries such as Singapore face a formidable dilemma when it comes to decarbonizing an economy which is wholly dependent upon the petrochemical industry for its basic function, with 96 percent of its energy use reliant on natural gas. Unsurprisingly it is the petrochemical industry, dominated by major fossil fuel corporations, which accounts for 75 percent of all industrial emissions and close to 45 percent of total emissions, making it, by far, the single largest contributor to GHG emissions in the country (Reference TanTan 2019). Contrary to its international commitments, the government is actively supporting the expansion of this industry. Indeed, the chair of the Inter-Ministerial Committee on Climate Change personally inaugurated refinery plant expansions for Total and ExxonMobil in December 2019 and March 2020, respectively (Prime Minister’s Office Singapore 2019; Reference NgNg 2020).

Governments such as in Singapore face a hard reality, caught between the imperatives of decarbonization and continued economic development dependent upon heavy industry which cannot be easily transitioned to nonfossil fuels. Oil majors have been seen as essential developmental partners by the government since the 1970s (Reference NgNg 2012), fostering a “deep sense of reciprocity and goodwill” among both political elites and corporate boards (Interview with NGO stakeholder, Singapore). The economic salience of the petrochemical industry has only strengthened in recent years, as demand for non-oil exports decline and a socially fraught transition to a global financial hub which has undermined high-wage manufacturing jobs (Reference TanTan 2020). In this political context, the continued presence and expansion of oil and gas in the country is politically beneficial to the ruling party – the industry provides over 25,000 high-wage jobs. While social welfare provisions have expanded considerably (including wage-subsidies for low-income Singaporeans), since the ruling-Peoples Action Party’s electoral setback in 2011, the party has yet to develop a more comprehensive plan to tackle long-term structural employment. This effectively means that on the climate mitigation front, the government’s policy options are limited to technological innovations and market incentives.

At the same time, various opinion polls indicate that public support for ambitious climate policies has grown in the ASEAN and wider Asia Pacific region over the past decade (Reference KimKim 2011; Reference Seah and MartinusSeah and Martinus 2021). However, they still lag behind similar polls for the EU (UNDP and University of Oxford 2021). Furthermore, none of the ASEAN states have fully declared a climate emergency, with only the Philippines and Singapore having declared “partial” emergencies in 2021 (Reference KurohiKurohi 2021; SunStar 2019). This raises the stakes for civil society in the region to challenge governments’ lack of overall climate ambition as well as the structural factors that lead to environmental degradation. Correspondingly, we observe the emergence of informal grassroots regimes of civil society actors, operating largely at Level II, across the region that (i) monitor and report environmental degradation and climate policies, and (ii) advocate for policy alternatives either as policy entrepreneurs or political adversaries. While climate activism may appear unremarkable in Western liberal democracies, it has been an important driver for climate ambition and transparency, political accountability, and participatory policymaking. In contrast, climate activism in Southeast Asia is conducted within very limited political spaces where collective action can sometimes be criminalized or violently suppressed. Understandably, climate issues have rarely entered into mainstream electoral politics, though this could see some change in the coming years. In the lead up to the 2020 general elections in Singapore, two climate NGOs, SG Climate Rally and Speak for Climate, organized a climate scorecard for all political parties based on a number of metrics, the first of its kind (SG Climate Rally 2020). This was supplemented by a concerted campaign to get members of the public to individually lobby their political candidates to adopt more ambitious climate targets.

Despite significant inroads, the politics stream in the region continues to be characterized by significant power asymmetries. In countries such as Indonesia and Cambodia, environmental activists continue to be harassed by government officials and worse (Reference PenhHuman Rights Watch 2020; Mongabay 2020). In Singapore, young climate strikers who individually posed for photos with placards were hauled up by the police for questioning over the country’s strict illegal assembly laws (Reference HanHan 2020). Most governments in the region continue to systematically exclude civil society with competing claims from climate and economic policy debates. The Singapore state, by far, demonstrates the most sophisticated mechanisms for controlling participation while excluding political contestation. NGOs are handpicked to attend closed-door consultations, with more radical or adversarial groups excluded. At these closed-door sessions, activists report that government representatives are more concerned with explaining the government’s climate policies rather than seriously considering alternatives (Interviews with NGO stakeholders, Singapore). Publicly, government figures attempt to corral the support of climate NGOs in order to legitimize government policies.

A key weakness faced by many of these NGOs and think tanks in the region is that they lack significant social bases of support, and as such, find it difficult to gain political traction beyond their limited immediate constituencies such as local communities and domestic supporters. Environmental NGOs in Indonesia, for instance, often rely on working closely with and advocating for communities directly impacted by specific environmental disasters but enjoy little broad-based support beyond these. More concerningly, the Indonesian government’s poor management of the COVID-19 pandemic has dampened societal mobilization against the unpopular Omnibus Bill that dismantles a number of environmental and labor protections (Reference NgJong 2020). Furthermore, mining companies and agribusinesses have leveraged a range of voluntary private standards to engage more with local communities which has had the impact of relocalizing contestation rather than allowing the scaling-up of advocacy efforts (Reference PenhSinclair 2020). Variegated outcomes from these engagements tend to militate against the development of a broader domestic movement against extractive industries. While specific NGO initiatives in Singapore seek to mobilize more broad-based support for climate issues, these are still in their infancy with the SG Climate Rally, one of the largest groups, only starting in mid-2019. Movements that frame the climate crisis around principles of distribution and justice are starting to take shape and will require significantly more broad-based support to start to properly challenge powerful entrenched interests.

6.2.1 ASEAN Agreement on Transboundary Haze Pollution

The AATHP was created in 2002, largely driven by the governments of Singapore and Malaysia, in response to the transboundary haze crisis caused by forest fires for clearing land for commercial palm oil and timber in Indonesia. Unlike most ASEAN agreements, the AATHP is legally binding, and predates the Paris Agreement by over a decade. By December 2003, over half of AMS had ratified the agreement, with Indonesia holding out the longest but finally ratifying in 2014. The agreement is multilevel in nature and is integrated into both regional and Indonesian domestic forestry and peatland management initiatives. It is further complemented by Indonesia’s Moratorium on Primary Forests and Peatlands that has been in place since 2011 as a condition for REDD+ funding. The AATHP effectively rescales the governance of peatlands and forest fires in Indonesia by creating a regional task force of technical experts to provide regulatory standards for national and sub-national governance actors to monitor and intervene in forest fires. While not primarily designed to target GHG emissions from its inception, the agreement has sufficient teeth to tackle forest fires on a transnational scale by allowing regional actors access to local points of regulation, with domestic capacities further buttressed by international pressure and aid. On paper, such arrangements create the potential for multilevel reinforcement for curbing GHG emissions through preventing seasonal forest fires.

As with the national moratorium (see Section 6.1), the AATHP has been regularly undermined by local elites in cahoots with agribusinesses (Reference Hameiri and JonesHameiri and Jones 2013). District heads in Indonesia have been known to deny regional experts access to politically protected plantations, while also intentionally underfunding sub-national institutions that are part of the regional fire control architecture (Reference Hameiri and JonesHameiri and Jones 2013: 471). Sub-national political elites have also consistently resisted efforts to rescale haze prevention to the regional level by insisting on the deployment of local firefighting resources. This often meant that fires were not tackled until the burning was completed (Reference Hameiri and JonesHameiri and Jones 2013). These problems are not just consigned to the sub-national levels in Indonesia. As kickbacks from agribusinesses funnel upward to national politicians, public discourse in Indonesia is increasingly framed in terms of protecting national development and “national interests.” In 2019, amidst growing controversy, the Widodo administration instructed agribusinesses not to publicly share information on their palm oil concessions, with Greenpeace accusing the Indonesian government of “actively blocking” attempts to reform the troubled palm oil sector (Greenpeace 2019). Such moves acutely reduce transparency and public accountability in forest fire governance, further undermining regional attempts of monitor and tackle forest fires.

The problems in Indonesia’s domestic politics stream that undermine regional climate governance have deep historical roots. The New Order era from 1965 saw the regime open forests to logging companies and agribusinesses where control over forests became increasingly concentrated in the hands of oligarchs and state-owned forestry concessions (Reference Gellert and ShefnerGellert 2015: 78–79). While the global demand for palm oil has been often cited as a cause for forest degradation (Indonesia is currently the largest global supplier), the induced domestic demand for palm oil is equally significant. This happened through deliberate government policies from the 1970s that substituted cheaper forms of oil (particularly coconut oil) with palm oil (Reference GaskellGaskell 2015: 30–37). The World Bank also actively promoted palm oil as a “development crop” in Indonesia since 1965 (Reference Gellert and ShefnerGellert 2015: 80). Neoliberal market reform and political devolution following the fall of the New Order accelerated the expansion of extractive forestry. Political decentralization led to a further proliferation of patronage networks, with Singapore- and Malaysia-based palm oil companies, backed by their respective governments, getting in on the act as palm oil production became increasingly regionalized (Reference VarkkeyVarkkey 2015).

Consequently, regional haze-control initiatives have ended up protecting agribusinesses due to close connections between domestic political elites and agribusinesses, and the ensuing dominance of these networks within the politics streams of key AMS. Haze prevention efforts end up being focused on smallholders and local communities who lack powerful political backers (Reference Hameiri and JonesHameiri and Jones 2013: 471–472). For example, the now-discontinued “Adopt-a-District” programs led by the governments of Singapore and Malaysia targeted small-scale slash-and-burn farmers when commercial plantations account for 80 percent of the haze (Reference VarkkeyVarkkey 2015: 195–199, 215). This allowed these two respective governments to appease public outrage against the haze by targeting “elements that did not affect their plantation business interests in Indonesia” (Reference VarkkeyVarkkey 2015: 202).

Non-elite policy entrepreneurs, particularly conservation NGOs, have nonetheless emerged to alleviate environmental outcomes, seeking both collaborative and adversarial engagement with agribusinesses. These engagements largely revolve around agribusiness-led forums on the implementations of transnational voluntary sustainability standards in the palm oil sector, notably the Roundtable on Sustainable Palm Oil (RSPO). However, the ability of NGOs to impact outcomes within such forums is limited by the cooption of collaborative groups for the legitimation of business agendas and the exclusion of more adversarial groups (Reference Ruysschaert and SallesRuysschaert and Salles 2016). With little or no access to domestic and regional policy forums, adversarial groups have responded by publicly highlighting the environmental and human rights abuses of individual companies in order to elicit public responses from multinational corporations that regularly use palm oil for their products. One such report by Friends of the Earth (2022) has led to large multinationals such as Nestle and Danone cutting ties with palm oil producers accused of environmental harm and human rights abuses (Reference Sirtori-Cortina, Afanasieva and DahrulSirtori-Cortina et al. 2022). Disconcertingly, palm oil imports are growing in markets (particularly in China and India) that do not demand conformity to sustainable standards (Reference DauvergneDauvergne 2018), thus significantly reducing the leverage of non-elite policy entrepreneurs.

6.2.2 ASEAN Power Grid

The idea of a regional power grid to meet regional energy needs was first floated in 1998, with a memorandum of understanding signed in 2012. By the end of 2015, the APG became a fully functional part of the broader AEC that sought to build an integrated regional market through eliminating domestic barriers to trade and investment. The APG follows the “2+X” approach of the AEC where two member states can proceed with regulatory reforms without waiting for others to be similarly prepared. The APG provides a good example of ASEAN’s “open” regulatory regionalism in that regional institutions provide an overarching regulatory framework that national governments can adopt to pursue their own energy market priorities. As with the AATHP, the APG is not primarily designed as a climate governance instrument. However, a regional grid provides opportunities to facilitate a greater share of renewable energy sources into domestic energy markets, while allowing more developed countries (like Singapore) with acute spatial limitations in adopting renewables. The APG would, thus, facilitate energy trading between countries with ample renewable sources to countries with lower access to renewables, which would in turn, foster greater investments in renewable sources in less developed countries (Reference Ahmed, Mekhilef and ShahAhmed et al. 2017a).

While the APG has taken off, it suffers from two critical limitations. Firstly, energy grid projects have suffered from low rates of adoption. APG projects have been largely limited to trading between Thailand and its less developed neighbors (Cambodia, Myanmar, and Laos), with some limited involvement between Indonesia (the region’s largest electricity consumer by far), Singapore, the Philippines, and Malaysia (Reference Ahmed, Mekhilef and ShahAhmed et al. 2017a). Similarly, multiple reports have also indicated that the APG appears a set of “bilateral conduits” rather than an integrated regional network (Reference JonesJones 2015: 15; Reference Ahmed, Mekhilef, Shah and MithulananthanAhmed et al. 2017b). At Level II, policy entrepreneurs operating there reported considerable national government circumspection toward the prospects of furthering APG connections and “citing national energy security” as a reason (Interview with NGO stakeholders, Singapore and Indonesia).

At the same time, insider policy entrepreneurs operating largely at Level I, such as the Economic Research Institute for ASEAN and East Asia (ERIA) and the Energy Studies Institute (ESI) at the National University of Singapore, have stepped in to support ASEAN in building a more integrated regional energy market. Keen to avoid the perils of taking sides in domestic politics, these insider policy entrepreneurs have largely focused on the technical limitations of the APG (ERIA 2015; Reference Andrews-SpeedAndrews-Speed 2016). Notwithstanding these limitations, the ERIA and the ESI have proved to be a useful focal point for the diffusion of metagovernance norms to govern integrated energy markets. For instance, the ESI (at Level I) has actively promoted the pan-European Nord Pool power exchange model, successfully replicated in India and Southern Africa, as a viable model to facilitate greater integration around the APG (AEMI 2015; Reference Andrews-SpeedAndrews-Speed 2016). Similarly, the ERIA have also promoted the use of Distributed Energy Systems (DES) as a technical solution that would support both ASEAN (Level I) and individual member states (Level II) in increasing their share of renewables through lowering capital costs (ERIA 2018).

Despite promising policy entrepreneurship at Level I, the APG is undermined by powerful domestic politico-business coalitions in the politics stream at Level II that obstruct decision-coupling. APG agreements would necessitate the removal of long-standing domestic fuel subsidies to energy consumers (Reference VictorVictor 2009). This has, in turn, prompted significant resistance from state-owned energy firms and politically influential energy-consuming industries (particularly in Indonesia and Malaysia) that owe their dominance to these long-standing subsidies (Reference JonesJones 2015: 16). The removal of subsidies would also affect the incomes of workers and low-income groups in the region, causing concern to political elites as the distributive impacts of fuel subsidies are key to the durability of many political regimes in the region (Reference JonesJones 2015). Beyond domestic fuel subsidies, transborder energy projects can be unattractive for local elites in areas dominated by patronage politics. Reference KarimKarim (2019: 1,564), for instance, documents how APG projects between Sarawak (Malaysia) and West Kalimantan (Indonesia) were slowed down by local political elites in the latter because (cheaper) energy imports from Malaysia would undercut lucrative local energy projects. Development of the latter, while eschewing cheaper APG sources, allows local political elites in West Kalimantan to access kickbacks from economic elites in return for approving energy projects.

Secondly, the APG is falling short on the renewables front. While the APG has targeted a 23 percent share of renewables by 2025, this would involve the region doubling its current share of renewable energy sources which does not appear on the cards, even for ASEAN (The ASEAN Post 2019). Rather, APG participants are prioritizing the affordability and availability of fuel types rather than environmental sustainability (Reference Ahmed, Mekhilef, Shah and MithulananthanAhmed et al. 2017b). This has led to the overwhelming use of fossil fuels within the grid despite the availability of renewable sources in the region (Reference Ahmed, Mekhilef, Shah and MithulananthanAhmed et al. 2017b).

Asymmetries within the domestic politics stream also explain limitations to the uptake of renewables in the broader region. The coal industry in Indonesia, for example, receives fifteen unique government subsidies, only seven of which have been quantified by analysts (Reference Clark, Zucker and UrpelainenClark et al. 2020). In 2015 alone, these seven subsidies were estimated to be around US$ 946 million, while renewables only received a cumulative subsidy of US$ 179 between 2010 and 2015 (Reference Clark, Zucker and UrpelainenClark et al. 2020: 8). Further complicating matters is the position of the state-owned electricity provider Perusahaan Listrik Negara (PLN) within these patronage networks. Energy regulations in the country emphasize domestic self-sufficiency, which the PLN leads by working closely with domestic fossil fuel companies that are either state-owned or part of oligarchic networks (Reference BosniaBosnia 2018; Reference GuildGuild 2020). Simultaneously, the PLN effectively prices out renewable energy producers through convoluted tariff negotiations and stipulations on local content that preclude the benefits of cheap imported renewable technology from China, among others (Reference WicaksonoWicaksono 2015; Reference GuildGuild 2019). The PLN has also been reported to have flatly refused to buy solar energy from fossil fuel producers looking to transition away from coal (Reference MauliaMaulia 2021). Furthermore, the tariffs levied by the PLN are often in contradiction with the policies of the Ministry of Energy and Mineral Resources, which, similar to ASEAN, is aiming for a 23 percent renewable energy share by 2025 (Reference AgustinusAgustinus 2016; Reference WaltonWalton 2019). Notwithstanding this, the Ministry itself has previously imposed its own tariffs on renewable energy, effectively disincentivizing investments into renewables (The Jakarta Post 2017).

Due to these entrenched elite interests at Level II, as well as the limited political space afforded to competing demands at both levels, policy entrepreneurs have found it difficult to actively advocate for the expansion of renewable energy. Even in countries like Singapore where the government has been more open to sourcing for renewable sources, policy entrepreneurs there (Level II) have reported that their advocacy efforts have been thwarted by domestic politics in neighboring countries. Indonesia and Malaysia, for instance, have recently curbed renewable energy exports to Singapore in order to boost their own faltering renewable targets (Free Malaysia Today 2022; Vietnam Reference PlusPlus 2022). This limits the impacts of advocacy for the adoption of renewable sources with activists in Singapore stating that any cross-border collaboration on renewables will have to accommodate the interests of elite groups on both sides (Interview with NGO stakeholder, Singapore). At the same time, international NGOs such as Greenpeace have also sought to put global pressure on ASEAN governments to phase out coal and increase their renewable shares through a highly critical Power Sector Scorecard for individual AMS (Greenpeace 2020). This is further complemented by their direct advocacy toward investment banks in East and Southeast Asia to halt further investments in coal power plants (Greenpeace 2021). Despite these pressures, any optimism toward the APG reaching its renewables target should be tempered with caution.