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Christensen 2008

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International

Review of
Administrative
Sciences
Administrative reform in China’s central government — how
much ‘learning from the West’?
Tom Christensen, Dong Lisheng and Martin Painter

Abstract
The prevailing interpretation in the scholarly literature is that public sector reform
in China during the period of marketization has been driven primarily by internal,
contextual factors rather than being under the sway of particular global reform
models or theories such as New Public Management. The aim of this article is to
move beyond arguing from inference that ‘Chinese characteristics’ continue to be
dominant and to inquire into the manner and extent of external influences on cen-
tral government reform actors. We assume a ‘multi-causal’ model in which both
internal and external factors are present. From a survey of the literature on the
reforms, we conclude that, while there are some ‘unique’ features, most of the
themes (and even the results) of modern Chinese reforms are not unique and

Tom Christensen is Professor of Public Administration and Organization Theory at Department of


Poltiical Science, University of Oslo. He has published extensively on topics of civil service and com-
parative public sector reform in the leading journals in the field. He is currently working on a large
evaluation project on employment and welfare reform in Norway. He has lately co-authored several
books: Autonomy and Regulation: Coping with Agencies in the Modern State (Cheltenham: Edward
Elgar); Transcending New Public Management (Aldershot: Ashgate); Organization Theory and the
Public Sector (London: Routledge).
Dong Lisheng is Professor of Political Science at the Chinese Academy of Social Sciences (CASS),
China. His research field is comparative politics and public administration. He has published 11 books
and 13 refereed articles and has contributed to 13 books. His latest book is Provision of Public Goods
in China (Beijing: China Society Press, 2007).
Martin Painter is Professor (Chair) of Public Administration, Department of Public and Social
Administration and Acting Dean, Faculty of Humanities and Social Sciences, City University of Hong
Kong. He is currently researching autonomy and control in Hong Kong government bodies and ‘new
governance’ reforms in East and South East Asia. He was the lead resource person to the United
Nations World Public Sector Report 2005, Unlocking the Human Potential for Public Sector
Performance. Recent publications include Challenges to State Policy Capacity: Global Trends and
Comparative Perspectives (Basingstoke: Palgrave Macmillan, 2005) (ed. with John Pierre) and
‘Sequencing Civil Service Pay Reforms in Vietnam: Transition or Leapfrog?’, Governance 19(2), 2006.
Copyright © 2008 IIAS, SAGE Publications (Los Angeles, London, New Delhi and Singapore)
Vol 74(3):351–371 [DOI:10.1177/0020852308095308]

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352 International Review of Administrative Sciences 74(3)

have parallels in Western countries. Moreover, aside from the similarities in the
content and substance of administrative reforms, the patterns and styles of reform
in China and in the West in the past 20 years show marked similarities and paral-
lels. Thus, external reform ideas and influences are being diffused through reform
processes. Further empirical and theoretical analysis is required to establish the
more specific nature of scanning and dissemination, or other forms of diffusion;
the kind of learning that is taking place; and the impact that any imported models
or templates actually have on reform proposals and outcomes in particular reform
episodes.

Points for practitioners


● Whereas many scholars tend to believe the lip service the Chinese leaders pay
to the ‘uniqueness’ of China’s public sector reforms and their ‘Chinese charac-
teristics’, their leaders have been very eager to ‘learn from the West’.
● Emulation and learning at a global level are key aspects of contemporary
public sector innovation and reform, even between jurisdictions that are seem-
ingly very different from each other.
● The development of sophisticated mechanisms for scanning and selective
learning are key requirements for a rapidly developing public sector such as
China’s.

Keywords: Chinese public reforms, emulation and learning, imitation, innovation

Introduction
China’s extensive restructuring of the centre of government of the last two decades
and more has occurred in a context of marketization and of economic integration
with the rest of the world. The scope of reforms to the state sector has been far-
reaching. On the one hand, the reforms have involved economic restructuring — dis-
mantling the command economy — and on the other hand, they have involved
administrative restructuring — creating new organizations and procedures for man-
aging and steering the diminishing state sector. The first set of reforms has entailed
restructuring of state-owned enterprises and service delivery units (‘pushing into the
market’); the second set has involved, among other measures, extensive machinery of
government and personnel reforms. It is the second set that is the concern of this
article, as the first set of reforms overlap extensively with economic restructuring
more broadly. Here, we are interested more narrowly in administrative reforms.
The presence of Western influences on Chinese reformers is often acknowledged
in the literature, but the processes of influence and their impact are by and large a
mystery. One notable exception is a study of imitation and diffusion of the ‘service
promise system’ in local and provincial government (Foster, 2005). On a broader
scale, Zhang and Straussman (2003) demonstrate a number of parallels and similari-
ties (as well as differences) in central reforms in China and elsewhere in recent
decades, but they do not attempt to trace the connections systematically. However,
they note some potential sources of external influence, such as cases of cooperation

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Christensen et al. Government reform in China 353

between the Chinese government and international agencies, frequent overseas


‘study tours’ by Chinese officials, the formation of the Chinese Public Administration
Society in 1988, the growing number of Western management texts being translated
into Chinese and the burgeoning of Western-style MPA programmes in China (Zhang
and Straussman, 2003: 162–3).
But most commentators view the state sector reforms introduced in recent years
in China as being driven primarily by internal, contextual factors — the emphasis is on
the ‘Chinese characteristics’: ‘China is running business on its own clock . . .’ rather
than being under the sway of particular global reform models or theories such as
New Public Management (NPM) (Ngok and Chan, 2003: 11–12). A common view-
point is that a number of special factors produce a ‘unique’ combination that means
‘local solutions’ are required and adopted: the scale and scope of China’s problems of
rapid transition to the market, some unique historical legacies and the particular char-
acteristics of its Communist inheritance. The authors of a recent study on civil service
reforms emphasize local political and institutional factors and conclude that ‘China is
running its affairs at its own pace’, although they also note that when drafting the
reforms, the party organization ‘sent study groups to more than 20 countries’ (Chan
and Suizhou, 2007: 395, 389). More generally, while the observation is made that
Chinese government slogans such as ‘small government, large society’ echo those
heard in the West during the post-Thatcherite or post-Reaganite era of state sector
reform, commentators also note that the rhetoric of these slogans is far removed
from the realities of implementation. For example, downsizing has been resisted or
deflected and bureaucratic controls have reasserted themselves (Burns, 2001: 420);
and strongly entrenched cultural factors have made systems of patronage embed-
ded in state structures hard to shift, despite restructuring plans and proposals or anti-
corruption campaigns. Observers also focus on the strategic considerations evident in
the decision-making of the state leadership, which presents a united, coherent front
and is capable of acting decisively in maintaining its development programme and
sustaining its legitimacy (Ngok and Zhu, 2003). In sum, the local context — political,
technical, cultural and so on — is highlighted, combined with the special circum-
stances of China’s decisions to marketize and ‘globalize’, creating a specific combina-
tion of reform imperatives (Ngok and Zhu, 2007).
The unravelling of reform origins and outcomes is not, however, a case of
‘either/or’, ‘internal/external’ causes and effects. In such a complex process as admin-
istrative reform, causation is multiple. Despite the prevailing interpretation in the
scholarly literature it remains to be shown from empirical analysis to what extent
administrative reforms in China have been influenced by external ideas and influ-
ences. While not undertaking such an ambitious task, the aim of this article is to
explore the external dimension more closely, to move beyond asserting that ‘Chinese
characteristics’ continue to be dominant (as the Chinese leadership has to maintain
for ideological correctness) and to inquire into the manner and extent of apparent
external influences on central government reform actors, stemming from global
reform movements or from the reform experience of other countries.
The last two decades have seen extensive reform efforts in the public sector all
around the world, starting with the NPM reforms originating in the Anglo-American
countries but spreading further to other developed industrial countries and to devel-

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354 International Review of Administrative Sciences 74(3)

oping countries (Pollitt and Bouckaert, 2004). These reforms included an extensive
agenda of administrative reform, including major restructuring at the centre of gov-
ernment and in the civil service. We now also see the spread of some post-NPM ideas
and practices (Christensen et al., 2007). Reform ideas have generally spread more
easily than structural reform elements and reform practice, meaning that there has
been some loose coupling between reform ideas and their implementation. The
spreading of reform ideas is based in certain countries, but is also helped by interna-
tional organizations such as the OECD, the World Bank, the IMF and the EU, working
as reform agents in spreading a reform ideology. Their activities may be seen as not
only spreading reform ideas, but also ‘technical solutions’ including certain structural
forms and steering systems that are seen as superior in furthering increased efficiency.
We will focus on the main reform features of the central public apparatus in China,
meaning the major ‘machinery of government’ reforms made during recent decades.
The first research question is: What characterizes the major modern administrative
reforms being made on the national level in China and what indications does one see
in them of imitation and learning from, having similarities with or inspiration from
other countries or international organizations? Here we will primarily map some
potential imitative features of the reforms. The focus will in the first place be on the
key 1998 and 2003 structural reforms at the national level (Burns, 2001; Luo, 2003;
Wang, 2003), but earlier reforms will also be touched upon. Second, we will try to
explain through a transformative approach some of the main features of these
processes. The aim of the article is an exploratory one, based on a review of second-
ary literature and public reports, without delving into details of the processes them-
selves. The secondary data currently available do not allow for any deep insight into
specific reform processes. Rather, we will suggest an agenda for further research
based on the puzzles that we identify in the theoretical and secondary analysis.

A transformative approach to imitation and learning from abroad


The dominant approach in the international literature on policy learning and imitation
in administrative reform draws on innovation and diffusion theory (Dolowitz and
Marsh, 1996). Foster (2005: 6–7), in his study of the service promise system in China,
recommends this approach to explore the way in which Chinese reformers learn or
borrow from abroad. The approach is primarily actor-centred and is organized
around seven questions (Dolowitz and Marsh, 2000: 8): Why do actors engage in
transfer? Who are the key actors? What is transferred? From where? How much is
transferred? What restricts or facilitates transfer? What sorts of transfer produce suc-
cess (or failure)? For our purposes, this framework is valuable as a list of questions or
topics for undertaking empirical research (such as case studies) but is rather limited in
its theoretical content. We propose to set imitation in a wider theoretical framework
that specifies the factors important in explaining administrative reforms more gener-
ally. We call this the ‘transformative approach’. The approach takes for granted that
reform processes, including processes of emulation or learning from overseas models
and examples, are complex and dynamic. The approach identifies the importance of
actors — political and administrative leaders — while also emphasizing that they are
constrained by environmental factors of three kinds: technical or institutional; cultural;

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Christensen et al. Government reform in China 355

and structural/constitutional (Christensen and Lægreid, 2001; Meyer and Rowan,


1977).1
‘Technical’ pressures from the environment can arise as the result of an economic
crisis, for example, which has often been noted to trigger major reform episodes
(Aberbach and Christensen, 2001). From the institutional environment, ‘taken-for-
grantedness’ or ideological dominance of certain reform ideas often develops.
Particularly in contexts where external sanctions are weak or non-existent, reform in
this vein may take the form of seeming to act simply in order to be seen as modern
and rational, without thorough implementation (Brunsson, 1989). Technical and insti-
tutional pressures can reinforce each other, as reform ideas ‘in good currency’ often
circulate faster at times of economic crisis or in the face of global economic forces,
such as those that come into play through membership of the WTO. In such contexts,
there may be a strong impetus to emulation and borrowing. Politicians — including
China’s leaders — in these circumstances are exposed to strong external pressure
about specific models of administrative reform, including reform myths and symbols,
perhaps resulting in ‘superstitious learning’ (that is, acceptance of received wisdom in
the absence of any direct experience or evidence) (March and Olsen, 1976). In such
a context it may be difficult to avoid imitation and tempting to pursue it.
Another important factor influencing and constraining executive public leaders is
the historical-cultural traditions in a country, or administrative cultural traditions
(Selznick, 1957). When a ‘reform wave’ hits a country it goes through a compatibility
test: high compatibility leads to higher acceptance and low compatibility leads to
rejection, resistance or slow and pragmatic adaptation of the reforms to the cultural
traditions (Brunsson and Olsen, 1993). For example, NPM has resonated better with
Anglo-American countries which generally favour autonomy, competition and indi-
vidualism than with Scandinavian and some Continental European countries that are
more preoccupied with equality, collective solutions, Rechtsstaat values and so on
(Christensen and Peters, 1999). A number of observers of public sector reforms in
Asia have also noted a similar reluctance to embrace fully some NPM reforms in
countries such as Japan and Malaysia, because of cultural or institutional incompati-
bilities (Common, 2001; Muramatsu and Naschold, 1996).
A third instrumental factor of importance is constitutional and structural features
(Zhang, 2005). If a country has a strong constitution, like Germany, constitutional
safeguards may prevent reforms from taking place, a contrasting situation to most
Anglo-Saxon countries where political executives can more easily decide on and
implement reforms (Knill, 1999). A related aspect is the type of political system.
Anglo-Saxon countries have more of an ‘elective dictatorship’, where the winning
party may embark on reforms quickly without having to overcome ‘multiple veto
points’, while in a complex presidential system or a multi-party parliamentary system,
particularly where there are minority governments, there will be more problems with
implementing reforms (Christensen and Lægreid, 2001).
Within this framework, in focusing on the role of foreign templates and ‘reform
borrowing’, we will draw specifically on Eleanor Westney’s (1987) seminal work on
imitation and innovation in the Meiji period in Japan (1859–1912), when ‘borrowing
from the West’ was a deliberate modernization strategy. Westney’s work reflects and
specifies the three main factors of the transformative approach and shows clearly the

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356 International Review of Administrative Sciences 74(3)

dynamics between the factors. Westney evokes two distinctions: first, between copy-
ing and inventing; and second, between imitation and innovation, seeing both of
them as false dichotomies. Her take on them is that successful imitation of foreign
organizational patterns requires innovation and she sees this process as ‘cross-
societal organizational emulation’.
Imitation in Japan was based in certain important preconditions. First, actors who
served as instrumentally oriented reform ‘entrepereneurs’ deliberately sought each
other out to learn and teach about overseas examples (especially in Continental
Europe). Second, cultural components were important, because insight into the con-
text in countries where the models were working helped the actors to understand
the contextual preconditions in their own country. In Japan, environmental pressure
was also a factor in stimulating the search for models to accelerate development. At
the time, Russia was a growing regional military threat to Japan, while the Western
powers were insisting on legal and other reforms as a precondition for normalizing
trade. Other environmental pressures were less immediate but also important, for
example the high prestige of certain countries or of certain organizational models, for
example the reputation for innovation and efficiency of the British Post Office. Some
of these environmental pressures were purely technical, but the imitators often tried
to exaggerate the value of an imitated model or to use an external model as a
symbol of innovation.
Westney evokes Whyte’s concept of ‘rational shopper’ (1968), but does not advo-
cate a literal interpretation of this image. The selection process was not only a matter
of optimizing the suitability of the overseas cases to fit the local environment, but
other factors were at play in the selective imitation (Westney, 1987: 23). The actors
explored different options and models in different countries before choosing, but
also sometimes based their choice on reputation. In cases of deliberate ‘best practice’
emulation, innovation was ‘deeper’ and contained many new elements, something
that was a challenge to local specialized knowledge. This also challenged the cultural
adaptation at home. Another type of imitation was more general, representing an
organizational form that was broader and existed in all Western countries (for exam-
ple, the stock exchange or the newspaper). This type demanded less knowledge of
the particularities of a case. Patterns of imitation were often cumulative, that is the
likelihood of imitating from the same country more than once increased partly
because the imitated country gave Japan support and expertise, partly because
Japanese experts had already acquired contacts, and partly also because imitation
occurred cumulatively across sectors within Japan — there was a ‘contagion effect’.
This type of dynamic seems to combine instrumental factors and cultural path-
dependency (Krasner, 1988).
Westney (1987: 25–6) stresses that an organizational model drawn from another
country can never be replicated completely in the new context. Departures from a
foreign model could be either unintended or deliberate. Unintended consequences
may occur because of either imperfect information or the influence of alternative
models, while deliberate departures may happen because of selective emulation,
adapting the patterns of the model to a different societal scale, or adapting the new
model to an environment that lacks some of the organizations that supported it in its
original setting.

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Christensen et al. Government reform in China 357

The relevance of Westney’s impressive study is obvious for China’s imitation from
abroad. We will use some of her main thoughts and ideas to elaborate on the trans-
formative approach, because she shows more specifically both the relevance of each
factor, and also their dynamic interaction. We will ask what kind of more general
mechanisms may be driving imitation and whether China is imitating more general-
ized or specific organization forms from Western countries.

Learning from the West? — institutional and cultural contexts


Not only Japan but also other countries in East Asia — including China — have a
‘tradition’ of emulation in order to ‘catch up’ and to accelerate their development.
‘Learning from the West’ has a long history in modern China (Spence, 1980), even if
leaders have normally been highly selective of what to import so as to protect their
own power and privileges. Partial and incomplete learning has also resulted from a
lack of capacity to absorb the lessons. This was the case at the initial stage of China’s
reform and opening up after 1978. Deng Xiaoping cited China’s economic laggard-
ness in the world so as to rally support behind reform and stressed the necessity to
learn from abroad, especially from the developed countries and with particular
emphasis on science and technology and on management techniques. But the lack
of systematic research into contemporary theories and practices, for example in the
field of administrative science, may have led to an inability to implement selective
imitation.
In contemporary China, many long-standing institutional and cultural traditions are
part of the overall institutional legacy: respect and deference for paternalistic, strong
political leadership; the concentration of power and privilege in Beijing among a
relatively small inner-circle elite, surrounded by its ‘court’; strong bureaucratic influ-
ence, with elements of both meritocracy and patronage in its different parts; and a
shifting balance or struggle between concentration of central power and regional
and local autonomy and influence. Post-1949 Communist China imported Soviet
techniques of party rule and state management, especially the interweaving of party,
administration and business. Some argue that a culture of corruption now character-
izes these systems of party control and privilege (Lan, 2001; Yang, 2004). In this
rather unique institutional setting, contemporary Western-style reforms clearly pose a
challenge.
At the same time, the central political-administrative structure in China, dominated
by the party, would seem to have the central power and capacity to ‘crush through’
reforms, even though the complexity in the system, and therefore also in reform
processes, is potentially very high. This is due to heterogeneity in political leadership
and leading administrative cadres — particularly the struggles between different
cliques and factions in Beijing and in the provinces — and the somewhat ambiguous
double structure of party and public administration. The complexity and hetero-
geneity in political-geographical or administrative-geographical structure in such a
vast country is also of significance.
Moreover, so far as there is the potential for reforms ‘by decree’ or by central com-
mand, this doesn’t necessarily say much about the potential for rational calculation in
such a system. Rather, we may see periods of gridlock interrupted by sudden, dra-

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358 International Review of Administrative Sciences 74(3)

matic gestures and initiatives, or big swings back and forth between different
tendencies, as in the Mao era. These may be the result of the shifting power of dif-
ferent factions in the leadership. While, during the reform era since the late 1980s, the
broad reform direction has been more or less consistent, nevertheless, we will note
the tendency for reforms to stall and for ‘backsliding’, punctuated by sometimes dra-
matic initiatives and ‘breakthroughs’, at which point fresh ideas and new directions
are announced (see Baumgartner and Jones, 1993). At such points of time, imitation
may be evident as part of a process of external legitimization for renewed internal
reform momentum.
In sum, we might expect China to show varying degrees of imitation from abroad,
as would be expected from Westney’s theory. First, close and calculated imitation
could occur as a result of deliberate instrumental reform strategies directed by strong
political leaders, either by actively looking for overseas models or by encouraging and
facilitating reform ideas to enter and be used in China, particularly in the presence of
strong technical environmental pressure (for example, a need to comply with WTO
requirements). Second, partial and incomplete learning may result from a lack of
capacity to absorb the lessons. Third, the imitation process may be characterized by
a tug-of-war between political leaders and public institutions resulting in uncoordi-
nated imitation from abroad (for example, as a result of the search for ideas and ini-
tiatives by ambitious, entrepreneurial provincial leaders). Fourth, imitation could be
more pragmatic and reluctant due to cultural resistance and overall ‘reform gridlock’
due to institutional and political factors. Each of these possible patterns of imitation
may be found at different times or even simultaneously in different sectors of reform.
In the following sections, we provide a brief outline of the different phases of central
administrative reforms in China since 1980.

Reform phases and types of imitation

Reforms in the 1980s


Ngok and Zhu (2007: 218) see the central administrative reforms in China in the
1980s as streamlining reforms. Since China was in a rather early phase of the market-
oriented economic reforms, this decade is seen more as ‘institutional reconfiguration
than functional reorientation’ (Ngok and Zhu, 2007: 222). The purpose of the 1982
reforms was to downsize the central government. Restoring of offices which were
abolished or made redundant during the Cultural Revolution and rehabilitation of
cadres disgraced and removed from positions led to the swelling of the State Council
ministries and agencies in the late 1970s and early 1980s. At the same time, the pro-
motion of the ‘four modernizations’ made the streamlining of the central government
seem a necessity (Dong, 1994). The aims of downsizing, reducing staff and improv-
ing efficiency led to a cutting down of the agencies in the State Council from 100 to
61 and about a 40 percent reduction in staff.
The reforms that addressed overlapping domains and unclear definition of func-
tions of public sector organizations (Lan, 2001: 443) showed parallels with similar
trends elsewhere based on the ‘single-purpose organization’ principle (Boston et al.,
1996). However, the basic administrative structure catering to the planned economy

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Christensen et al. Government reform in China 359

system remained intact and the number of departments/agencies increased to 72


towards 1988, with an addition of 82 provisional organs at the central level. The
reforms seem to have been internally driven, concerned with post-Cultural Revolution
adjustments and with the emergence of a new set of leaders and priorities, while also
being resisted and influenced in their implementation by bureaucratic politics.
The background of the 1988 reform was that the organization structure and the
problem structure were not compatible. An old administrative system was faced with
the demands of emerging economic reforms (Ngok and Zhu, 2007: 218). The main
aim was to strengthen the central government’s capacity for macro-economic control
(Luo, 2003). This was to be done by separating the governmental apparatus from the
Party apparatus (with the Party having the upper hand), and make a clearer separa-
tion of government and the state-owned enterprises — the first of many such efforts.
A slight downsizing of the units in the State Council was also decided on. These
reforms were actually not implemented to a great extent, partly because they were
opposed by the bureaucracy and the Party cadres, and partly because of the
Tiananmen incident in 1989 (Lan, 2001: 444).

Reforms in the 1990s


Deng’s tour to Southern China in early 1992 signalled the end of a period of political
and economic stagnation. When the CPC in the autumn of 1992 confirmed the intro-
duction of a market economy, it was even more evident than before that there had
to be public sector reforms to adapt to the new economic realities, i.e. a functional
transformation of the government was needed (Ngok and Zhu, 2007: 224). The
1993 reforms that followed very much renewed goals and means from the 1980s
reforms, but the depth of and political will behind the reforms were stronger. The
reforms tried to establish and develop an administrative system that could be suited
to a developing market economy in China. The concept of ‘administrative system
reform’ was proposed, to underscore the scope of the reforms, instead of using the
more limited concept of ‘institutional reform’. The core of the reform was to alter
deeply the functions of the government by separating the government on all levels
from the state-owned enterprises. Some mergers and devolutions of ministries and
agencies happened, and the State Council was reduced from 82 to 59 units, some-
thing that lagged behind expectations, especially concerning the slow restructuring of
the departments dealing with economic management. As before, the slow pace was
attributed to a lack of political capacity and effort to push them through.
In the case of civil service reforms, the initial urge to imitate western models was
followed by a clear decision to reject key features. Since the mid-1980s extensive
studies had been conducted of contemporary Western civil service systems. The
political neutrality and job security of professional civil servants were noted as the
main features of these systems. The plan to establish the new Chinese civil service
system, as approved by the Party at its Thirteenth National Congress in 1987, made
a distinction between the two categories of political affairs and professional work.
However, since mid-1989, it had been stressed that ‘the civil service system is a com-
ponent of the Party’s organization line and cadre system’. In particular, China should
not ‘copy those principles and stipulations of the western civil service system that are

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360 International Review of Administrative Sciences 74(3)

derived from the multi-party system and the concept of separation of three powers’.
In 1993 the new personnel system was established with the publication of the
‘Provisional Regulations on the State Civil Servants’. But the programme was down-
graded to being part of the administrative reform rather than a key component of the
political reform aimed at implementing the concept of division of Party and state.
Chinese civil servants are called on consciously to be in line with the Party in a politi-
cal sense (Dong, 1994: 43–61).
The new round of reforms in 1998 had some rather broad and partly ambiguous
goals: setting up an efficient, well-coordinated and regulated administrative system;
establishing a corps of professional and highly competent civil servants; and gradu-
ally developing an administrative system with Chinese features that could coordinate
with and manage the socialist market economy (Luo, 2003: 21). Ngok and Chan
(2003) sum up the reform by three foci: streamline the bureaucracy, reduce the
number of civil servants and change the main functions of government related to the
economy. One aim was to strengthen the role of law in the administrative system
through adopting large volumes of new legislation.
The aim of strengthening the macro-control of government resulted in a focus on
the specialized economic management departments (industrial departments). Most
of them had to be dismantled and in doing so three strategies were used: down-
grading by giving them a more subordinate formal status; corporatization, that is
making them state corporations and moving their former administrative tasks to
other organs; and merging either ministries or departments into ministries (Ngok and
Zhu, 2007). The eventual aim was that the state-owned enterprises should become
‘independent legal entities managed by professional business managers and fully
operating under the market forces’ (Lan, 2001: 440). The 1998 reform also encom-
passed the establishment of a strengthened Ministry of Labour and Social Security to
cope with increasing social problems as a result of the market-oriented reforms. In
sum, the reforms involved two parallel types of restructuring: first, corporatization,
that is the hiving off of the business management function to state-owned corpora-
tions; and second, the restructuring of planning, control and oversight ministries and
other agencies. Reduction in the number of bureaucratic personnel involved in
administrative oversight and detailed planning was also an intended outcome. Each
of these aims was only partly achieved.
In accordance with a plan put forward by PM Zhu Rongji, the National People’s
Congress approved a sweeping reform to streamline the bureaucracy and reduce the
staff size of the central government by one-half (Yang, 2004: 37–8). The 1998
restructuring (implemented at the central level immediately and followed by local
levels in 2002/03) reduced the number of central government ministries from 40 to
29, many of them related to dissolving and merging industry-related ministries, but
increased somewhat the number of bureaus directly subordinate to the State Council
(Ngok and Zhu, 2003: 11). These reforms were aimed at promoting the unity of
administrative authority at the centre and curbing the fragmentation (an aim that
echoes post-NPM trends in the West).
The 1998 reform also included a strengthening of the units regulating the mar-
kets. The 1998 reform had the dual aim of reducing the role of the Chinese govern-
ment with respect to direct involvement in market processes, while at the same time

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Christensen et al. Government reform in China 361

strengthening the government’s role as a regulator of market activities, resulting in


several administrative reorganizations. A main aim was to make the government
apparatus more effective and efficient. In doing this, the leadership in many ways
adopted a strategy typical for many Western countries, but it was done in a shorter
period of time and with no intention of losing political control. The OECD regulatory
model launched in 1997 has the same duality, but the starting point in most of the
member countries was much less control of the economic sector than in China.
In the period 1998–2000, one-stop shop service centres were established in
China. Chinese officials and scholars had much discussion of the Citizen’s Charter
movement in the UK and one-stop shop practices in the West before this initiative
was implemented in China. At first their aim was to attract foreign investments,
through making it easier for foreign firms through simplifying local rules and regula-
tions, but later the aim was more to give better service to the residents (Sønne, 1999;
Yang, 2004). This type of reform began rather early in many Western countries, but
spread and was revived in the 1990s. The Centrelink reforms in Australia are com-
monly viewed by reformers internationally as a model, so these organization forms
may have been an inspiration in the contemporary period in China (Halligan, 2004).

Reforms after 2000


The changes made around 2000 related to what was labelled vertical administration
— implying increased central hierarchical control, supervision and regulation – and
reflect an international post-NPM reform trend (Christensen et al., 2007). They were
mainly driven by internal crises and mismanagement, particularly at local levels. They
combined an empowerment of central agencies in Beijing and systematic use of
regional/local representatives who were responsible to the central level, in order to
counteract the influence of lower levels (Yang, 2004: 99–101). The ‘re-centralizing’
reforms also recall a recurring theme of central–local conflicts in Chinese administra-
tive development (see Lan, 2001).
The negotiations concerning WTO membership resulted in the exposure of China
to strong international pressure (Yang, 2004: 57, 58, 164, 307, 308). In anticipation
of problems in the negotiations, China’s leaders embarked on some economic and
administrative reforms in advance of acceding to WTO membership. This external
pressure provided the major background for the new reforms of 2003 (Ngok and
Zhu, 2007). The regulatory reforms of 2003 implied an increased distance between
administrative and regulatory agencies on the one hand and business on the other
(Yang, 2004: 58–60). This seems to take inspiration from traditional regulatory struc-
tures in the US, which seem to have influenced the official OECD regulatory model
that had its breakthrough in 1997 (Christensen and Lægreid, 2006). China seems in
this respect to have imitated more of a generalized Western organizational form than
a specific model from a specific country, a mechanism Westney (1987) pointed out
for Japan. The 2003 reform was again about rationalization of economic institutions,
but more now about fine-tuning than about downsizing. The main aim of the 2003
reform was to ‘deepen the reform of the management system of state assets, to
improve the macro-economic control regimes, strengthen the financial regulatory
system, to integrate the domestic trade and foreign trade, and to enforce the food
safety and production safety regimes’ (Ngok and Zhu, 2007: 230).

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362 International Review of Administrative Sciences 74(3)

Explaining broad patterns of change


The scholarly literature on Chinese administrative reform has overwhelmingly
emphasized internal historical factors, the special needs of China’s rapid economic
transition in an era of globalization and domestic political considerations. Yang (2004:
2), in his broad analysis of market transition and the politics of governance in China
during recent decades, stresses that three major factors explain the reforms: the
changing economic conditions; internal politics and political leadership; and crisis. The
Tiananmen incident is seen to have paved the way for a dual strategy — strengthen-
ing the political machinery while renewing the commitment to economic reforms,
mostly connected to Deng’s celebrated tour in 1992 and the reforms that followed.
Yang (2004: 9) also emphasizes the fact that the post-Mao Chinese state started out
with a lot of organizational resources and mobilizing capacity (an important instru-
mental precondition for reform, as pointed out by Westney (1987)). Yang (2004:
311) highlights the way that the Chinese leadership has ‘jealously guarded the party’s
political dominance while promoting economic liberalization and development’. Their
programme is seen as stressing ‘order rather than democratic ideals, technocratic
control rather than popular participation (except at the grassroots level), governability
rather than regime type’. The Chinese state is now seen as some sort of managerial
state that is more efficient, more service-oriented and more disciplined.
Where authors address the influence of external models, particularly NPM, there is
some ambivalence in the arguments, with most writers acknowledging the potential
for external influence — particularly as China became more integrated with the global
economy — before coming down on the side of a kind of ‘Chinese exceptionalism’
point of view. Lan’s (2001: 446) position on the public sector reforms in China is that
even though it is tempting to link China’s administrative reform efforts in recent
decades with global efforts of ‘reinvention’ of government, they are better viewed as
a continuation of reform efforts started a long time ago. In other words, he offers a
mainly internal explanation, based on a cultural path-dependency argument (Krasner,
1988). He shows that downsizing and simplifying the central bureaucracy was a
theme already in the 1958 reforms. A recurring struggle has also been a tug-of-war
between the central government and the regional government apparatus, with
several later efforts to strengthen the central government. This was a theme already
in reforms in 1958, which brought features of decentralization. The ever-recurring
theme of party–government relations was also on the agenda then, as were govern-
ment–business relations. The latter problem was connected to a worry, repeated 30
years later, that the government apparatus on all levels was too involved in micro-
management of public enterprises. In the late 1950s, combining the first and third
problem led to a transfer of the responsibility for most of the enterprises to lower
levels of government, a tendency reversed in the 1960s, contributing to a large
growth of the central public bureaucracy. Lan (2001: 454) sees in the efforts at
administrative reform over 50 years in China a recurring theme of ‘downsizing,
expansion, downsizing again, and expansion again’, reflecting some kind of ‘ebb-
and-flow’ mechanism as pointed out by Olsen (1988). The reform efforts have
always been top-down, initiated by some of the central political leaders.
At the same time, Lan (2001: 457–62) emphasizes that China’s administrative

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Christensen et al. Government reform in China 363

reforms arise from a combination of different background factors including both


internal and external influences. Internal political factors are highlighted: a firm con-
viction within the leadership that China has to maintain its stability at all costs, some-
thing that became very important after 10 years of turmoil during the Cultural
Revolution that ended in 1976; and the special features of China as a ‘traditional’
society, where social hierarchy and lack of democracy has been evident, leading to
acceptance of strong central control. But factors that bring external influences and
models into the argument are also highlighted: first is the belief that China had to
change to win respect in the international community, a symbolic feature based in
the institutional environment, and a factor that echoes a century-old (at least) orien-
tation of learning from Western countries while preserving the traditional Chinese
culture, values and political system. Second, it is readily acknowledged that under
Communist rule, the Soviet model of governance was influential and was imitated
(albeit with ‘Chinese characteristics’), although the model was increasingly seen as a
failure, spurring reforms which (presumably) began to draw on other models. This
may show a lag resulting from a combination of superstitious learning and know-
ledge limitations.
Ngok and Zhu (2007), in an analysis of restructuring and reform in China from the
1980s through the 2003 reforms, seem to want the ‘best of both worlds’ by giving a
place in their argument to two parallel trends, namely a worldwide administrative
reform trend and administrative reforms with ‘Chinese characteristics’. One view is
that these trends are connected; another is that China’s administrative reforms have
a different point of departure compared to Western industrialized societies, and
follow a different trajectory as a result of unique socio-political settings (Burns, 2001).
A case can certainly be made for the ‘uniqueness’ view, by emphasizing the authori-
tarian features of a strong party and political leadership and the rather late start of
installing market principles to enhance economic development. It has also been
argued that the administrative reforms may have been a substitute for political and
constitutional reform and a means to cope with a potential legitimacy crisis of the
authoritarian Chinese state. Pursuing similar lines of argument, Ngok and Zhu (2003:
2) argue that China’s reforms cannot be understood by a simple administrative theory
such as NPM, because of the need for economic development and a wish to regu-
late the process of market transition. But we can readily agree that the drivers of
reform, the political context and the mix of reform issues confronted were not iden-
tical to those where NPM originated in the West, while still observing the impact of
NPM and Western models more generally on the way the problems were defined
and the solutions selected. Of importance is of course also the opening up of China
to the international environment, meaning both more technical and institutional
pressure for imitation from the West.
The case for seeing connections between local reforms and international reform
trends is not, as stressed earlier, of the kind that requires a mono-causal explanation.
The large-scale socioeconomic transformation in China, from a planned economy to
a ‘socialist market economy’, and from a traditional agricultural society to a modern
and industrial one, is most likely a result of both internal and external pressures.
Similarly, the reforms undertaken show a mix of internal and external starting points
and end points. Arguably, the external factors are of growing importance (a point

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364 International Review of Administrative Sciences 74(3)

that is often made in connection with administrative reforms everywhere).


Globalization and China’s economical internationalization are seen as an important
background for recent administrative reforms. Relatively speaking, the first of the two
decades of reforms seems to be more domestically based, as efforts to reshape the
Communist state in order to suit the market-oriented economic setting and to
enhance the capacity of governance (Ngok and Zhu, 2007), while the 1998 and
2003 reforms are seen as more externally driven by economic globalization.

Explaining imitation in different phases of reform


In sum, despite the conventional wisdom, we feel the jury is still out on the extent to
which external models such as NPM were important in the trajectory of China’s
administrative reforms. One approach that we believe could bring a more balanced
view would be to explore the differences between the role of internal and external
factors in different periods and for different kinds of reform in different sectors. Some
hints on the value of this approach can be found in the existing literature,
The 1982 reform in China could primarily be seen as internal and instrumentally
driven. One way to see this is from the ebb-and-flow perspective proposed by Lan
(2001). After turmoil in the Mao era, an expansion in the State Council happened and
in 1982 it was time to streamline and downsize the administrative apparatus. The
political will was there and the scope of the reform seems to show that any cultural
or other restraining factors could be overcome (Baumgartner and Jones, 1993). The
external pressure for reform doesn’t seem to be that evident and it was too early to
see any influence from economic transformation and globalization.
The reform in 1988 was important in many ways because it put high on the politi-
cal agenda what the political leadership should do with central government when
facing two challenges — increasing domestic economic growth and increased eco-
nomic globalization. This opened up some traditional and recurring themes that have
since been of importance in all the reform efforts in China: how to divide the party
and a professional government administration, how to divide government and pub-
lic business activities, and how to do these things without losing political control.
Resistance against the reforms proposed was evident from Party cadres and the
bureaucracy, a reflection of heterogeneity in central government and a sign that
actors were defending their interests and privileges. The international environment of
economic actors was of increasing importance but, during the 1980s, was far less
important as a source of reform pressure than was the case later.
The starting point of the 1993 reform was a very typical exercise of political entre-
preneurship by Deng, evocative of the reform rhetoric and leadership of Reagan,
Thatcher and Roger Douglas. Deng not only put his political strength and prestige
behind the reform, but managed to push through a functional transformation of
government related to the introduction of a market economy, or in the Chinese
version ‘a socialist market economy’. Even though the structural changes related to
the functional transformation could have been clearer and more forceful, the restruc-
turing train had started to roll and there seemed to be no way back. Internal resist-
ance was less evident this time, while the environmental factors were generally
stronger. Overall, the Chinese reforms followed a pattern that was consistent with a

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Christensen et al. Government reform in China 365

general international model of governmental economic management, with a division


of ownership, regulative bodies and business activities.
The 1998 reform was by far the most thoroughly prepared, comprehensive and
forceful to date. By now, the political leadership and state reform experts would have
observed closely the successes and failures of their reform efforts relative to the eco-
nomic reform targets they had set themselves, and would also have been increas-
ingly exposed to the currents and trends of global reform thinking through the
integration and opening up process. The opening up of the China market to the out-
side world created increased external pressure, both from international public actors
and strong private business actors. While we have noted that the reforms echoed the
OECD model of regulatory governance, the reforms also had some deviant features
compared to Western countries. One important feature was that China had a much
more complicated administrative structure related to economic activities and there-
fore the restructuring was more demanding and potentially conflict-ridden, particu-
larly because it encompassed large-scale downsizing. Another was that the Chinese
political leadership had little intention to let go of state control of business activities,
and therefore aimed at a structure with a strong element of public ownership.
The relevance and impact of overseas models in the 1998 reforms was ambiguous.
Although models of ‘corporatization’ were a ‘hot topic’ in state sector reform in the
NPM era, the model of the government business enterprise corporation under arm’s
length ministerial oversight also had a much longer lineage in the West. If ‘imitation’
was occurring, here was a case, perhaps, of Westney’s second type, where a general-
ized form (the ‘government corporation’) was adopted. As to the rationalization of
oversight and planning ministries, the circumstances of moving from a command
economy had no precedent in the West, nor did many countries have the kind of elab-
orate planning and control systems that China wished to retain. Here, the model may
have been Japan (for example, MITI) and other East Asian countries where such plan-
ning and guidance in a market economy were commonplace (Zhang and Straussman,
2003: 147–51). At the same time, the overall intended result — to concentrate on con-
trol in the core government apparatus and to let go of some control on non-core (state-
owned corporations) — had similarities with the reforms of the early 1980s in New
Zealand and Australia (Campbell and Halligan, 1992; Gregory, 2001).
The 2003 reforms demonstrated a high degree of continuity from the 1998 ones,
but under more intensified external pressures. The process of seeking membership in
WTO had the effect of pushing China further down the Western market and regula-
tive path, and the pressure persisted after membership was decided on. Engagement
in WTO negotiations and institutions brought to bear a typical technical environmen-
tal pressure from WTO and the member countries towards China, but also an institu-
tional pressure, leading China to adopt a belief that the Western model was the most
efficient and modern one (see Olsen, 1992). The reforms made may also be seen as
using an international actor for domestic purposes, i.e. to discipline and change the
behaviour of bureaucrats. In that way the WTO membership provided new opportu-
nities and new dynamics for further restructuring of the administrative system in
China.
If, at the initial stage of the reforms, learning from abroad was general in charac-
ter, arguably it became more specific and selective in the later reforms. It is normal

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366 International Review of Administrative Sciences 74(3)

nowadays to conduct research into the foreign counterparts for most reform pro-
grammes. For example, Dong Lisheng was commissioned to submit two reports on
the reform trends in the foreign civil service systems on rewards and pension
arrangements, as well as on the remuneration and salary management for the
Ministry of Personnel, when it prepared proposals to the central government on
furthering the cadre and personnel system in 2003. Since 2006, preparations have
been made for the launching of a new round of administrative reform to be
announced by the new government in the spring of 2008. The Chinese Public
Administration Society was asked by the State Council leaders to submit proposals,
partly reflected in ‘On the Directions of the Administrative Reform in China’ by the
CPAS Secretary-General Gao Xiaoping and his colleague Shen Ronghua (Dong,
2007).2

Conclusion
Our exploratory study of modern public reforms and imitation in China has been a
broad one, without presenting detailed data on the precise mechanisms of scanning
or imitation. The main slogan of modern Chinese development is that the country has
a ‘socialist market economy’. It is not easy to tell whether this is a reality or a political
symbol. It may be that implicit acceptance of this as objective reality as distinct from
symbolism has clouded the scholarly debate on whether the development of
modern China’s public reforms and economic development has to be seen as some-
thing uniquely Chinese, or whether there are close parallels with reforms elsewhere
and, hence, a greater likelihood that Chinese reforms have been imitated fully or
partly from abroad. The answer to this question seems to be some kind of ‘both/and’.
The crucial question is what were the important factors or driving forces behind
the development and reforms during the last two decades — were they internal or
external? Most of the themes (and even the results) of modern Chinese reforms are
not unique and have parallels in Western countries, more often in a generalized form
than as a result of borrowing and learning from one country. First, the recurring cycle
of downsizing and upscaling in the central administrative apparatus is nothing
particularly Chinese, but a common theme in administrative history in many countries,
related to changing goals and constraints, complexity, the dynamic between special-
ization and coordination and so on (Downs and Larkey, 1986; Raadschelders, 1998).
Second, the growing interest in China for increased formalization and rule of law in
administrative affairs is also rather typical for a developing country. There has been a
long-lasting debate within the IMF and World Bank, for example, about whether
African countries need ‘more Weber’ or ‘more market’.
Third, the more specific solutions and models China started to use from the 1980s
were very Western and not particularly Chinese. Basic market features concerning
production and organizing of economic processes were already to hand in many
Western countries, as were US-, OECD- and EU-related regulatory models. Models for
organizing the governmental apparatus towards industry were to be observed in
neighbouring East Asian countries. The evidence is at best ambiguous whether these
solutions and reforms were heavily filtered through Chinese norms and values. Thus,
it has been a surprise for some observers and scholars that China has used some of

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Christensen et al. Government reform in China 367

the models in a more idealized and pure form than most Western countries, for
example in reforms in the health and education sectors, where the degrees of
marketization, user pays and decentralization have gone much further than any of
the models (even the US) (Painter and Mok, 2007; Tam, 2007). On the face of it,
China seems to have accepted both as a technical fact and as a myth that the
Western models are the most successful and the ones to copy. Recently, some
Chinese scholars have noted the unquestioned borrowing from the West and offered
at least two reasons: the simple-minded belief that the trendy Western administrative
theories and methods are worth following and, more likely, a lack of thorough study
and understanding of the Western administrative reforms (Dong, 2007).
Fourth, aside from the similarities in the content and substance of administrative
reforms, the patterns and styles of reform in China and in the West in the past 20
years show marked similarities and parallels (Zhang and Straussman, 2003). We can
observe the same phenomena and use the same analytic tools to describe and
explain both: the role of crises, whether enhancing or modifying reforms (Aberbach
and Christensen, 2001; Christensen and Lægreid, 2001); the pressure of external
forces and the effects of an increasingly global institutional environment; the pres-
ence of ‘windows of opportunity’ and the role of policy entrepreneurs in picking up
on ideas or solutions that are ‘in vogue’ (Kingdon, 1984); the weight of the past or
tradition (path dependency) and the phenomenon of ‘punctuated equilibrium’
(Baumgartner and Jones, 1993); and so on.
The research topic outlined here in our broad analysis does not presume that
China’s reforms have primarily been driven by learning or imitation based on overseas
experience or that such influences were significant in all instances of reform.
However, we have found that external reform ideas and influences are being dif-
fused through the reform processes to some degree, perhaps through more or less
systematic scanning and analysis but otherwise through more indirect or less sys-
tematic forms. The question to pose for further empirical and theoretical analysis
concerns the more specific nature of any such scanning and dissemination, or other
forms of diffusion, the kind of learning that is taking place and the impact that any
imported models or templates actually have on reform proposals and — ultimately —
outcomes in particular reform episodes.
In developing this research agenda, the transformative approach suggests a num-
ber of preliminary hypotheses. First, we presume a leadership that continues to be
‘reform-minded’ and not preoccupied with clamping down and drawing back from
reform due to internal struggle, domestic political crisis or social unrest. In that con-
text, we hypothesize that the greater the pressure from the technical environment, in
particular the urgency and intensity of the pressures on the Chinese government
arising from the way global economic forces and technological change are impacting
on reform issues in different sectors, the more likely it is that there will be systematic
search for and strategic adoption of overseas models. To the extent that the sources
of these models and ideas are themselves a set of ‘global change agents’ operating
in key arenas within the wider global economy (for example, WTO institutions and
processes, international standard setting organizations, World Bank experts and so
on), the institutional environment will reinforce the pressures for emulation and tend
to lead to both generalized and, more particularly, specific adoptions and diffusion.

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368 International Review of Administrative Sciences 74(3)

However, in this situation, the kind of learning that takes place depends on how
closely connected the local reformers and their immediate advisers are with these
arenas and hence how knowledgeable they are about the details of the models
and ideas. ‘Superstitious learning’ rather than the selective emulation of Westney’s
‘rational shopper’ is more likely where the knowledge gained is not first-hand but the
ideas come indirectly via third parties, who may simplify and distort them for a variety
of reasons.
Such shallow or partial learning is also more likely in situations where the pres-
sures from the technical environment are less significant for a particular set of reforms
and reformers than domestic pressures embedded in China’s structural, cultural and
constitutional traditions. In the process of adaptation and implementation of ideas
from abroad, the ‘reality testing’ of the imported models will always in some meas-
ure be influenced by these cultural and institutional factors. Where the weight of
these domestic forces is especially strong and the sense of Chinese identity and
tradition especially acute — for example, in the case of reforms to China’s Communist
Party-led state bureaucracy — we can expect to find less interest in and more resist-
ance to Western models and ideas. Where there is some evidence of imitation, it is
likely to be more ‘generalized’ in form, such as adopting a type of organizational form
or a broad concept (‘marketization’, ‘corporatization’, the ‘super-ministry’, etc.) and less
a case of detailed learning from specific Western measures or experience. We are
also likely to find more cases of shallow or distorted imitation behind which ‘business
as usual’ goes on.
Correspondingly, receptivity among Chinese reformers to particular models and
ideas will be higher if path-dependent or traditional ideas and institutions are aligned
with the underlying principles and aims of the proposed reforms. As in the case of
Meiji Japan, the reformers will search out sympathetic and acceptable models and
ideas. We would hypothesize, for example, that in China’s party-controlled state
bureaucracy, some of the ‘disciplining’ and ‘control’ aspects of the OECD templates of
‘performance management’ would be attractive to reformers (and hence would be
emulated), while those aspects of the same public management reforms that
granted genuine professional autonomy to bureaucratic actors would be ignored or
suppressed by the reformers. The rhetoric and even the myths of performance man-
agement as a Western reform will be selectively and to some degree strategically
deployed in line with prevailing norms and traditions.
In order to test these hypotheses and others that could be derived from the same
theoretical starting points, ideally we need the kind of in-depth analysis of central
reform actors and episodes that is familiar in studies of central reforms in Western
democracies, where researchers have conducted in-depth interviews, done surveys
and drawn heavily on publicly available government documents that give detailed
analysis of official thinking (see Christensen and Lægreid, 2001, 2007; Pollitt and
Bouckaert, 2004). Case study strategies are clearly ideal for exploring these questions
(Foster, 2005). Rarely are these sources and strategies readily available to researchers
on public administration in China and there is a particularly high level of sensitivity
when it comes to central government high level reforms. Nevertheless, particularly
where China’s leaders themselves attribute some of the origin of a reform proposal
to an idea or model drawn from the West, some degree of access may be gained by

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Christensen et al. Government reform in China 369

researchers to some of the actors and processes through which learning took place,
as such cases would already have involved some degree of openness to both
domestic researchers and ‘foreign experts’. Indeed, in the best traditions of public
administration research, the kind of analysis being suggested here might be viewed
as a contribution to understanding the role and effectiveness of emulation and learn-
ing in China’s future administrative reforms.

Notes
1 The technical environment refers to that part of the environment that deals with the technical
aspects of an organization, for example related to the production of services or decisions, as
when an agency gets resources from a ministry and has to use them for the intended
purposes. The institutional environment comprises ideas and myths about appropriate
organization structures, rules, procedures, personnel and so on which are circulating among
other national or international organizations to which an organization relates.
2 Dong Lisheng was invited by the CPAS to conduct research on the government reforms of the
major European countries (Dong and Hu, 2006: 119–35).

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