Italy, an overview on Policy Analysis Regulations

Italy, an overview on Policy Analysis Regulations

1.    Why Did Policy Analysis Become so Essential?
In modern times, drafting Public Policy is no longer what it used to be. In less than half a century the world has changed dramatically: (i) Technologies have spread pervasively in every niche and crevice of our lives[1]; (ii) national borders have blurred under globalization; (iii) societies have become more complex. These three factors combined in a powerful cocktail, collapsed the traditional, ideology-driven, art of policymaking. Devising a legislative reform is no more a matter of left and right, of clear cut responses. Societies leaped forward, in the turn of few decades, from a mostly polarized spectrum, based on the dichotomy workers-industrials, to a rainbow of professions, specializations and life-styles. Consequently, public policies, nowadays, need to serve variegated societies. Moreover, the slightest dissonance can trigger far-reaching consequences. People and companies can easily move from one country to another, relocating in the regulatory environment that best suits their interests. At the same time, the conspicuous degree of digitalization brings on the table an enormous, gigantic, ridiculously massive amount of data. Statistics are impressive. In 2013, a study commissioned by IBM, pointed out that 90% of all of the world’s data were generated in the last two years[2]. Such availability spurs the competition among policy makers. Different national administrations compete to entice business and people to move within their borders and to keep the ones already in from fleeting. Policies better planned, are more likely to attain their intended objectives and therefore, they attract more users within their regulatory environment.

In few words, policy analysis aims at the optimization of resources to achieve certain objectives, via regulation. The more technologies advance, the easier it gets to retrieve data, to cross borders and the more societies sophisticate. All these factors boost the fight for having in place the most efficient rules. These are the reasons why “Better Regulation” is one of the hot cries of the last decade[3].

2.    Introductory Notes on the Evolution of the Legislative Context
To contextualize the Italian position in terms of policy analysis we should start from Europe. So first, given the contingent historical moment, we would like to acknowledge that Europe spearheaded the modernization of the Italian public administration, raising awareness on the need to establish procedures and strategies to achieve what frequently goes by the label of “Better Regulation”. Under such label we refer to the whole life-cycle of a piece of legislation, spawning from preparation, analysis and consultations to its approvals and enforcement, arriving up to monitoring its effectiveness and, eventually, to its amendment. Fifteen years ago, in 2001, the “Mandelkern Report”[4], advocated the implementation of a coherent strategy within the regulatory environment of the Member States, proposing, before the adoption of a new legislation, the execution of impact assessments, consultations among stakeholders, simplification of procedures and the set up of an institutional body specialized thereof. In 2002, the European Commission issued a Communication, which introduced some standards for Regulatory Impact Analysis (RIA) and consultations. In 2003, it followed an Inter-Institutional Agreement on better law-making, setting a cooperation agenda for the EU Commission, the Parliament and the Council of Ministers, which culminated in 2006 with the establishment of a Commissions’ Impact Assessment Board. The Board centralizes the quality control over the European regulation, further providing important support for the development on new proposals. Finally, in 2015 a cornerstone text was issued, containing the EU Guidelines on Better Regulation[5] setting the framework for any future regulatory initiative of the European Union.

In Italy, it is difficult to trace back to a precise point in time the awakening towards the need for Better Regulation. Ruling governments ever since ventilated in their election campaigns the bureaucratic vexation of people, stemming from tangled up regulations. The same critic is still in the air today. Our political history though, from one side favored a bubblesome mitosis of regulations, exacerbating the process; on the other, it hindered the reform of the process, compromising its solution. The weakness of the majority characterizing the ruling coalition forced the legislative process through troubled compromises. Even if started under meritorious auspices of coherence and rigor, legislations in Italy too often ended centrifuged through hasty drafting procedures, being victim of blunders and subsequent surgeries in emergency status. Such peculiarity of the Italian politics, which, notwithstanding the electoral reforms is not luckily to relinquish the country, reinforces the need for structured rules and procedures towards better regulations.

Formally, however, the Regulatory Impact Analysis (RIA) timidly peeped out on the Italian legislation, for the first time in 1999 (“Legge Sulla Semplificazione”, n. 50/1999). By 2003, it was extended to regulatory authorities, under OECD recommendation. However, the turning point arrived on the 28th November 2005, with the enactment of the Law n. 246. With the expressed purpose of achieving the purported simplification, such Law empowered the government to define “the general criteria of the RIA procedures, including the phase of consultations” (art. 14, par. V). Three years later[6], the government finally made use of the attributed power and, with a decree of its president, ruled out the blueprint for Policy Analysis in Italy (DPCM n. 170/2008)[7].

3.    The Italian Mosaic on Policy Analysis: The Substantive Perspective
Following the European example, the Decree n. 170 decentralized to each ministry the preparatory work for the proposal of regulatory reforms. By so doing, it is possible to profit of the concrete expertise of each administration over the subjects under its own sphere of competence.

The procedure of analysis is compulsory for each initiative of the government (art. 2), provided few exceptions. Among those, stands out a puzzling one for Constitutional reforms (art. 8). There exists also a case by case exemption to be granted by an oversight body, identified in the Department for Juridical and Legislative Affairs (DAGL[8]) of the “Presidenza del Consiglio”. The norm accordingly created, within such Department, an “Office for the Analysis and Evaluation of Regulatory Impact”[9], delegating to that body all the duties related to RIA and Monitoring and Evaluation activities (M&E)[10].

The most relevant disposition of the Decree is probably art. 4, which attempts to lay down a structure for the RIA, setting out specific criteria and providing a model sample at annex A. The norm explicitly requires the continuous adjournment for the model, at least every three years. At the time of writing, eight years have passed but the model has remained unchanged. Accordingly, the preparatory analysis of a public policy in Italy encompasses the following sections: 1. Objectives and context; 2. Consultations; 3. Evaluation of the “option-zero” or no-intervention; 4. Alternative solutions, ordered for invasiveness; 5. Justification of the proposed solution; 6. Consequences on the market and competitiveness; 7. Enforcement and monitoring. There is no mention to quantitative and measurable analysis.

According to well-accepted practices, the preparatory phase has to contemplate consultations with the stakeholders, in conformity to the principles of transparency and proportionality (art. 5). The RIA culminates then in a Report which, the proposing administration submits to the DAGL for approval. The DAGL can ask for clarifications or addenda. Without such approval, the reform cannot be registered on the parliamentary agenda for discussion (art. 7). The report essentially has to follow the sections mentioned for the RIA and explained at annex A (art. 6, par. III).

In a nutshell, these are the norms addressing directly policy analysis in Italy. However, it is sufficient to navigate through the websites of the administrations to notice that the Decree 170 only represents one tip of one iceberg, whereas the cap of policy analysis is far more complex than that. There are in fact three other verification procedures, other than the RIA, closely intertwined with it, at times overlapping. The first and most coherent one is the mentioned M&E (or VIR in Italian), which takes place after the reform is running for a minimum of time. This is the natural development of the RIA, since it verifies the accuracy of its RIA’s forecasts, starting from the indicators and comments thereby outlined.

The M&E procedure is detailed in the Presidency Decree n. 212, promulgated on the 19th of November 2009[11]. The norm, in general, requires a biannual analysis after the implementation of the reform. It is the same administration that carried out the RIA to be responsible for its verification through M&E activities. In parallel, the administration has to obtain the approval of the DAGL on its M&E analysis (art. 2), however there is not mention of a control mechanism. The law is indeed silent on the consequences of a missed analysis by the competent administration. The M&E analysis complement the original RIA also in its structure, as it follows by its main sections: a) Degree of target achievement; b) Cost analysis; c) Effects analysis; d) Degree of compliance; e) Criticalities; f) final remarks with suggestion of necessary adjustments. The scheme also features spurious categories, which would have better fit as subsections of one of the macro areas already quoted, e.g. “effects on the simplification” or “incidence on the concurrence of the market”, and others not appropriate for a supposedly technical analysis, such as “coherence with the government program” (art. 3).

Separate from the RIA and the M&E analysis, the third control brought about in the Italian crusade for Better Regulation goes by the acronym of ATN, which approximately translates as Technical-Normative Analysis. The inception of this other tool does not find a direct recognition in a law of the parliament. It rather represents an additional check the government has levied on its rule-making process. In particular, the test is required by a “Directive” of the “Presidenza del Consiglio”, dated 10 October 2008. This further test is prompt to verify the incidence of the proposed regulation on the existing body of laws, with special regard to its conformity to Constitutional and European norms, as well as relevant jurisprudence (art. 2). The directive expressly enucleates the purpose of the ATN as to ensure the strict necessity of regulatory reforms (art. 3, let. a); oversee and stimulate the recourse to simplification tools (let. e); analyze the impact of the regulation on the market concurrence levels, on the freedoms of the regulated subjects and on liberalization processes (let. l). On these topics, the scope of the ATN test clearly converges with the RIA. Indeed, as a matter of principle, there is no reason for the establishment and codification of a separate tool of analysis only pertaining the legislative impact of a new reform. The administration could and should consistently integrate the ATN as a subtest within the RIA. As a proof, the incipit of the RIA already demands an evaluation of the normative context in which the new regulation is going to graft. This is frequently the most extensive and detailed part, as the producing administration stresses the descriptive introduction. The partition unfortunately ends up creating considerable noise around the same reform, which now is accompanied to parliamentary discussion by two separate analysis, decisively overlapping on many points, but responding to slightly different set of criteria.

Our picture, however, is not yet exhaustive, as there is another evaluation required to all governmental administrations trespassing the scope of the previous tests. This is the MOA[12] or “Measurement of Administrative Burdens”. What is the concrete difference of such procedure from the measurements required by the RIA and the M&E, is difficult to say. In practical terms, public administrations themselves acknowledge that the activity underlying this analysis concretely interconnects with the two abovementioned. I have almost no doubt that, once the diligent administration has calculated its costs, it uses the same figures to fulfill all its reporting requirements. However, these activities find their discipline in different pieces of legislation, which, through different verbal formulas, provide different guidelines.

More in detail, the MOA was introduced by the “Statuto delle Imprese” (“Statutes for Enterprises”), Law n. 180 of 2011[13]. This procedure is two-pronged. One consists in attaching a list of all the information burdens, monetized in their respective costs, introduced and repealed by a new secondary act of an administration. Secondary acts, in general do not undergo the RIA. However, the same list, has to accompany now legislative proposals. Accordingly, the Statute introduced the MOA list a section of the RIA, modifying Law 246 of 2005 (cfr. art. 14, par. 5-bis). The statute further requires the proposing administration to annex the same list to any regulatory initiative addressed to the general public (art. 7). A problem here could arise with regard to the concrete methods used from time to time, by the administration in order to measure the relevant burdens. The government elaborated specific guidelines on how to produce and present the MOA lists (DPCM n. 252, 14 November 2012) and later specified how to calculate each burden (DPCM, 25 January 2013[14]). These norms do not account for the general preference laid out for the RIA, in favor of the EU Standard Cost Model (the DPCM 170/2008, Annex A). The degree to which these different norms and standards conflict with each other is beyond the purpose of the present work, which however cannot but judge the legislative technique adopted with some disapproval. In practice, we are not aware of cases, where costs were accounted for in different ways, in different regulations, but we fear this is rather the consequence of an entrenched tendency to avoid quantitative analysis by the Italian administrations, rather than a virtue of the legislation.

The second activity of analysis demanded by the MOA to each administration consists in drafting an annual balance of all the burdens on citizens and business deriving from the regulations that pertain to its office (art. 8, sec. II). This clearly overlaps with the M&E activities reinforcing my perplexities for the confusion on quantification methods[15].

4.    Follows: The Subjective Perspective or the Cosmo of Authorities
If the situation is not pristine as a matter of substantive rules, it becomes worse once we take into account the subjective side of Policy Analysis in Italy. The cry for Better Regulation spilled into frantic appointments of key analytic functions to a constellation of offices, services and departments, which cannot but struggle to coordinate.

We have mentioned the DAGL, the department elected as the central player for RIA and E&M analysis by Law 246/2005. The DAGL surely is the closest thing we have to the classic oversight body, as known in other countries[16]. However, the shortcomings of the system did not take long to materialize. Policy Analysis requires complex judgements, or at least it should, equally drawing from the knowledge of Law, Economics and Political Science. It requires some statistical lingo, some familiarity with cost benefit analysis, some data and figures analysis. However, the Department for Juridical Affairs and Legislation was (and is) populated mostly by legal experts, who lacked the technical expertise to tackle an effective policy forecast, with all its implications. In order to cope with such impairment, the help of the Department for the Coordination and the Economic Planning[17] (CIPE) was put at the DAGL disposal. Specifically, another Decree of the “Presidenza del Consiglio” instituted, within the CIPE, the “Nucleus for Verification and Evaluation of Public Investments”[18], at whose interior we find the “Group for the Regulatory Impact Analysis” (DPCM, 15 July 2009). The mentioned Decree bestowed this body with the task of succoring the DAGL on the most technical aspects of the analysis, in particular dialoguing with single administrations to explain the procedural flaws committed.

Needless to say, a more accurate and orderly reform would have better instituted a special single body entrusted with policy analysis operations. Such organic perspective would consent a rigorous selection of the professional profiles best suited for policy analysis, with greater savings in coordination and requalification costs. In any case, the dicephalus nature of the oversight body partly remitted to the competent office of the DAGL, partly to the competent team of the CIPE, is not the worst problem of the system. These two bodies at least found some synergy. Unfortunately, this is not the case for many other public units also implicated in the system of policy analysis.

To start, we notice a structural incoherence in the division of ministries, from which stems the juxtapositions of many different offices, with identical roles. In Italy exists a Ministry devoted to “Constitutional Reforms and Parliamentary Relations” and another to “Simplification and Public Administration”. The descriptive meaning of these titles, does not collide, however in practice the ministries do. The Ministry for Constitutional Reforms, in fact, does not limit its operation to Constitutional Reforms, but rather coordinates the whole array of institutional reforms contained in the program of the government. Respectively, the Ministry for Simplification cannot but achieve its purpose by reforming the administration. As a result, many offices within the respective bodies deal with the same policy analysis..

First, there is the “Unità per la Semplificazione e la Qualità della Regolazione”( hereinafter referred to as “Unit”). Such unit was established and regulated also by secondary legislation (DPCM, 12 June 2013[19]). It gravitates within the “Presidenza del Consiglio”. It directly refers to the Ministry for the Simplification and Public Administration. The Unit was devised as the operational arm of a special Committee, created in 2006 and composed by different ministers. The Committee serves the purpose of steering and coordinating the government action towards simplification and better regulation, presenting an annual relation to the Parliament, on past activities and future strategy (Law n. 80, 9 March 2006). The Unit heavily partakes with Better Regulation activities: it curates the annual plan of action for better regulation, ordering the intended legal reforms; it promotes the coherence and simplification of the existing regulation; it promotes the digitalization of the public administration; it coordinates the process of better regulation by monitoring and taking active part in the initiatives singularly started by each administration; it even holds consultations with stakeholders and receives their proposals and comments (DPCM, 12 June 2013). Hopefully, behind the walls of the PA, this Unit works in close connection with the DAGL and the other bodies. In any case, the attribution of the respective powers is scattered in heterogeneous sources, against the preached values of regulatory quality.    

Always within the Ministry for Simplification and PA, nested in the Department of the Public Function, we find the Office for Simplification and Removal of Bureaucratic Burdens[20]. As ruled in the ministerial Decree of 17 November 2015, such office has the task of “promoting and coordinating the policies of normative and administrative simplification, in order to achieve better quality of regulation, cut the administrative costs of compliance for the users, increase the competitiveness and the rule of law for citizens and enterprises”. Again, “the office promotes legislative and administrative reforms coherent with the national strategy of digitalization [..]; curates the drafting of a balance sheet for administrative burdens; monitors the effects of the simplification actions; promotes consultation of the stakeholders”. The pleonasm is evident.

The “Cosmo” does not end here. We find another abundant office, whose task seems precisely overlapping with the policy analysis functions delegated to the DAGL, the CIPE and the Unit. This is the SNSRE or the “Office for Normative Support, Studies and External Relations”[21]. This body is embedded within the Department for Institutional Reforms whose mission, to start with, is considerably rooted into policy analysis. The Department supports the President for the coordination, direction and promotion of new initiatives, also of regulatory nature (art. 23, DPCM 1 October 2012). This department, differently from the Unit, appears under the Ministry for Reforms. Within the department, the Decree of the Minister for Reforms and Parliamentary Relations, dated 21 September 2015, established the SNSRE with the task of carrying out “the activities of study, analysis, elaboration of normative proposals” (art. 5). A limitation restricts the scope of the policy analysis of the SNSRE to Institutional Reforms. However, on those, there subsists a clear duplication[22]. To put the cherry on the cake, within the Ministry for Reforms, there is also the “Office for the Legislation Program” with additional powers of monitoring, collecting statistics and proposing legal reforms.

This  confused constellation reflects only the organization of the government. The legislative body also contains other offices, whose main function is to ensure Better Regulation. In particular, the powers of policy analysis are extremely dispersed within the Senate, which disposes of a multitude of interesting “services”. First, we count the “Service for the Quality of Normative Documents”, which splits into the “Office for administrative feasibility and RIA of pending drafts of legislation”, the “Observatory on the Enforcement of Legislation” and the “Office for the review of Legislative Documents”. The boundary between the activities of each office is fairly blurred. The first, most interestingly, is deputed to report on the feasibility and the regulatory impact of any legislative proposal. According to the norm, it is not bound to take into account the work previously done by the myriad of others. In practice it does, hopefully, but there are no clear rules as to how incisive the counterchecks can be and to what extent they might oppose the opinion of conformity released by the DAGL. Furthermore, the norm demands to this Office to “elaborate criteria, parameters and methods” for policy analysis, which are presented “for political approval”. The procedure and effects of such approval are unknown. For what about the second Office, the observatory, it “curates the census and the technical analysis of the existing legislation” and “carries out studies and research on the legislative production as a whole, as well as on the enforcement of specific legislations and their effects”. The third office is in charge for the “collection of the existing legislation on techniques for better legal drafting and it ensures their application”.

Moreover, there are other 11 offices at the senate, heading to the “Service of Studies” and the Service for the Budget, all involved into policy research, analysis and evaluation[23].

In order to render visually how complex is the structure just described we tried to scheme it into Venn Diagrams, where the different test are indicated by a number and the different administrations by a letter. The Legend explicating each acronym in Italian follows. It includes the relevant pieces of legislation taken into account. The scheme, for practical reasons, excludes the offices of the Senate previously described.

5.    Upcoming Occasions for Thorough Restructuring, New Possible Balances Between Senate and Government
Policy Analysis is a serious activity. It deserves careful planning, however the enthusiasm with which it was implanted in Italy most certainly overshot. The messy proliferation of plethoric ministries, departments, offices, units, nucleuses and groups, all tackling an aspect of policy analysis creates a riffraff of duties and discording voices, which cannot but prejudice the quality of the function.

We recognize it would be contradictory to pretend a perfect legislation for the establishment of the policy analysis system. Such perfect legislation, as a matter of fact and logic, would undermine the need for a policy analysis system in the first place. Nonetheless, if the system is wisely devised, again according to logic it should lead to its own regeneration in the shortest time. If this is not the case, like in Italy, that alone constitutes a reasonable red flag indicating the system was not well-devised.

Times are ripen for a thorough and consistent revision of the actual system. Two are the leading factors. First, last year, with the publication of the Law for the Reorganization of the Public Administration the parliament bestowed upon the actual government the power to restructure the Italian system for Policy Analysis. In particular, the Parliament consented the Government to modify the organization of the “Presidenza del Consiglio”, as well as of the ministries and independent authorities, with regard to the “empowerment of the mechanism and tools for the monitoring and evaluation of the public activity”[24].

On the other side, the current constitutional reform offers the occasion for a better restructuring of the policy analysis conducted by the Senate. In the text under referendum, the proposed art. 55 would officially elevate policy analysis at constitutional level. The reform explicitly states, the Senate “evaluates public policies, the activity of public administrations and verifies the impact of European policies on the territories. It contributes to [..] monitor the enforcement of the laws of the State.”

Such major change, tackling both the sides of the mess, could trigger a better coordination between the policy analyses of the government and the Senate. Ideally speaking, the reform should sharpen the powers of the Government. Policymaking is undoubtedly an activity pertaining to the executive power, it is of vital importance therefore to aggregate one single Department solely deputed to policy analysis. This department shall aggregate the scattered offices currently sharing general powers of analysis and distributed in different ministries. It is of great importance that such Department gathers legal experts, economists and administrative experts. These cumulatively have the language to communicate with the different administrations on a case by case approach, in order to cover all the necessities of Policy Analysis. This body also should concentrate the competence for conducing general researches, with the help of relevant administrations, for reform proposals, so as to maximize the knowledge acquired by conducing regular policy analysis. Such centralized and specialized solution would make sure the government keeps up with new studies and techniques advancing in other countries or in the academia. Coherently, the Policy Analysis should be streamlined, conducing the current MOA and the ATN within the scope of the RIA and the E&M analysis. On the other hand, the Senate, in coherence with its role of a democratic guarantee should limit its activities to fact checking, cutting loose the current aspiration as a policy maker. The role of the Senate should coherently be foremost at the service of the not governing parties, which need to enjoy of the same technical support available to the government in order to challenge the results of a policy analysis advanced by the government. To achieve such objective, however, the Senate should remain neutral offering only a technical service, upon request of the minorities. Moreover, in line with this activity of fact checker, the Senate and not a Government body, as it is the current case for the DAGL, shall express his opinion on the regularity, comprehensiveness, accuracy and reliability of the policy analysis laid down by the Government together with a proposed draft of reform.

6.    Conclusions
Briefly, to conclude, a centralized perspective makes it easier to model an efficient dichotomy between the government and the parliament. It suits Montesquieu’s system of balances and counterbalances better , reflecting the division of powers among our institutions. Nonetheless, the paradox is bogging us down. If the system of policy evaluation is flawed, how will the administration arrive to understand the urge to replace its policy evaluation system? We are confident that the upcoming reforms will turn the Italian system of policy analysis under the spotlight. Then, the necessity for a thorough revision cannot but emerge limpidly. In the waiting, stay tuned with our review, were we are going to offer more ideas on how to reform the system, after a comparative assessment of other administrative models for policy analysis, like the American, the British and the German one.

Mattia Morani


[1] Specifically on the issue in perspective to Policy Analysis cfr. Porcaro, The Industrial Internet will Transform Policymaking, Sept 28 2016, Bruegel Blog Posts, http://bruegel.org/2016/09/the-industrial-internet-will-transform-policymaking/
[2] SINTEF ”Big Data, For Better Or Worse 90% Of World’s Data Generated Over Last Two Years”, Science Daily, 22 may 2013
[3] For a general overview of Policy Analysis see Fischer, Miller, Sidney, Handbook of Public Policy Analysis, (eds) (2007); Goodin, Moran, Rein, The Oxford Handbook of Public Policy, Oxford University Press (2008); La Spina, Espa  Analisi E Valutazione Delle Politiche Pubbliche, Bologna, il Mulino (2011).
[4] http://ec.europa.eu/smart-regulation/better_regulation/documents/mandelkern_report.pdf
[5] http://ec.europa.eu/smart-regulation/guidelines/toc_guide_en.htm
[6] Law 246, art. 14, par. V, requested an intervention within 180 days, but quis custodet ipsos custodes?
[7]http://www.normattiva.it/atto/caricaDettaglioAtto?atto.dataPubblicazioneGazzetta=2008-11-03&atto.codiceRedazionale=008G0197&currentPage=1
[8] Dipartimento per gli Affari Giuridici e Legislative.
[9] Ufficio per L’Analisi e Verifica dell’Impatto della Regolamentazione.
[10] This is known in Italy as VIR or ”Verifica dell’Impatto della Regolamentazione”.
[11] “Regolamento recante disciplina attuativa della verifica dell'impatto della regolamentazione (VIR) “http://www.normattiva.it/atto/caricaDettaglioAtto?atto.dataPubblicazioneGazzetta=2010-01-30&atto.codiceRedazionale=010G0017&currentPage=1
[12] In Italian “Misurazione Oneri Amministrativi”.
[13]http://www.normattiva.it/atto/caricaDettaglioAtto?atto.dataPubblicazioneGazzetta=2011-11-14&atto.codiceRedazionale=011G0238&currentPage=1
[14] The government directions are contained in the annexes to “Decreto del Presidente del Consiglio dei Ministri del 25 gennaio 2013 "Criteri per l'effettuazione della stima dei costi  amministrativi  di cui al comma 5-bis dell'articolo 14 della legge 28 novembre 2005,  n. 246, ai sensi del comma 3, dell'articolo 6 della  legge  11  novembre 2011, n. 180”, cfr. http://www.gazzettaufficiale.it/eli/id/2013/04/16/13A03240/sg
[15] Most importantly, the MOA requirements have been extended to Independent Public Authorities as well as public local entities. It is consequently established a special committee for the coordination within these subjects. Cfr. Art. 6, Legal Decree n. 70, 13 May 2011, converted into Law n. 106, on the 12th July 2011.
[16] For which see M. BENEDETTI, Il controllo sull’analisi di impatto della regolazione: l’esperienza degli oversight bodies, in  Rivista trimestrale di diritto pubblico, 2012, 4: 1057-1105.
[17] Dipartimento per il Coordinamento e la Programmazione Economica (DIPE).
[18] Nucleo di Verifica e Valutazione degli Investimenti Pubblici (NUVV).
[19] The first order norm attributing such power to the government is the Legal Decree 181/2006, converted into Law, with amendments on the 17 July 2006, n. 233, under the title “Urgent disposition on the restructuring of the powers of the “Presidenza del Consiglio” dei Ministri e dei Ministeri”.
[20] “Ufficio per la semplificazione e la Sburocratizzazione”. The latter word in English would amount to something like Debureaucratization. A word that, by its very nature, tells a lot about the simplification attempts of the Italian Government.
[21] “Ufficio per il Supporto Della Normativa, Gli Studi E Le Relazioni Esterne”.
[22] Not to critic the incoherence of such policy analysis function with the other function attributed to the SNSRE, which consists in entertaining relations with the Parliament, the European institutions and the Regional administrations.
[23] I will report them only here, not to vexate the reader. They consist of: (i) Ufficio per la documentazione degli effetti finanziari dei testi legislativi; (ii) Ufficio per la verifica della quantificazione degli oneri connessi a testi legislativi in materia di entrata; (iii) Ufficio per la verifica della quantificazione degli oneri connessi a testi legislativi in materia di spesa. These three are within the Service for the Budget. Within the Service for Studies we find one office of analysis for each of the following sectors: Economic and Finance; Labor and Health; Justice and Culture; Foreign Affairs and Defense; Federalism; Comparative Legislations and The European Center of Research and Parliamentary Documentation.
[24] The norm, at art. 8, par. I, let. c) achieves this result with a contort referral, asking for the enforcement of the principles at art. 11, 12 and 14 of Law n. 59/1997. This is the Law Bassanini, for the simplification of the PA, which at art. 11, par. I, let. c) states the principles reported in the text.

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