Multi-Level Governance and Administrative Overload: A Comparative Analysis of Air Quality Policy Implementation in Germany and Italy

The rapid growth of environmental regulations has increasingly led to an overload of administrative burdens on both public administrations and businesses, which often express dissatisfaction with these demands (Gravey and Jordan, 2020). This overload results in several negative consequences, such as non-compliance with regulations by businesses, bureaucratic overload within public administrations (Zink et al., 2024), and poor or incomplete implementation of regulations (Fernandez et al., 2024). These issues can undermine the primary objective of these regulations: the protection of the environment. The effects and dynamics of overload vary across different governance levels, from local municipalities and agencies implementing broader directives to regional and national governments. As the literature identifies, this variation can lead to failures in the implementation phase. This paper argues that the challenges in implementing environmental policies could be best analyzed within a multi-level governance framework. Based on qualitative methods, the paper will use a comparative approach to examine the implementation of the Air Quality Directive in Germany and Italy , analysing the national measures and the local level implementation (Germany, for example, adopted the Lead City Program, while Italy implemented the Regional air quality plans). Both countries were sued by the European Commission for inadequate air quality policies and share a comparable administrative structure. The analysis will apply a theoretical framework—previously tested in the literature (Fernandez et al., 2024; Coletti, 2024)—to compare the following dimensions: (a) regulatory capacity, defined as the ability of the regulatory authority to establish clear, comprehensive, and simplified rules; (b) coordination capacity, referring to the ability to bring together diverse stakeholders and agencies in decision-making processes; (c) delivery capacity, which concerns the organization of regulatory processes and the effective implementation of policies and the discretionary resources of street-level bureaucracy in relation to the specific policy, such as the air quality programs.