In 1998, UNECE Member States completed negotiation of the Aarhus Convention to enhance public participation in environmental decision-making. Three years later, only two western democracies have ratified the agreement. This paper suggests why parliamentary democracies in Western Europe have been slow to ratify the Convention. We argue that their political structure discourages strong public participation in bureaucratic policy making, in contrast to separation of powers regimes, such as the United States. To illustrate our point, we discuss examples from the U.S., selected European countries, and the European Community, which has separation-of-powers features similar to the U.S.

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