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The MLG framework fits better and accounts more accurately for changing forms of governance, political conditions and intergovernmental relations in both of these countries. There are several aspects in which an MLG approach is able to describe these two states better than a traditional federalism approach that places federal and unitary systems in separate “boxes.” Our argument also appears to follow an emerging trend in the literature, as highlighted by the work of Toonen (2010), among others. German scholars in particular are quite open to studying their own federal system, as well as the EU, through the lens of MLG. As our research suggests, MLG is also an approach that is gaining [47] ground in the study of UK devolution. Overall, we suggest that what might otherwise be seen as important institutional and constitutional differences between these two polities are less significant when they are viewed through the lens of MLG.

A typology of multilevel governance systems can be viewed to encompass different forms of federal, “quasi-federal,” and unitary systems. Multilevel governance is an overarching concept, under which variation along two spectra can be subsumed. The two axes are higher and lower levels of territorial diversity, and a range from a high level of centralisation of power in the hands of the national/federal government to a high degree of decentralisation to substate units. We concur with Gagnon’s (2011) view that a common flaw in MLG theorising is that it overlooks political cultural and socio-economic cleavages inherent in multinational federations. We therefore call for further empirical and theoretical work on how multi-national federalism and autonomism can add to our understanding of multilevel governance.

As a result of devolution, most observers now consider the UK to be a “quasi-federal” system (Bache and Flinders 2004), while federal Germany prior to 2005 was described as a “hidden unitary state” (Abromeit 1992, as cited in Moore et al 2008: 396; 406, endnote 12) that was too centralised. The MLG framework is the best way to understand the changes that have taken place as well as the calls for further changes in both of these states. In this sense, MLG is much more flexible, and thus better able to subsume the study of these changing forms of governance than are traditional comparative theoretical approaches. The MLG approach, in contrast to the Westminster Model and the various conceptions of federalism applied to Germany, such as “interlocking federalism” (Benz and Zimmer 2011: 149) and “unitary federalism” (Hesse, as cited by Moore et al 2008: 396; 406, endnote 9), is broader and more encompassing. Although the concept of MLG has been criticised for being too “overstretched” (Piattoni 2009), its elasticity does have benefits. While it could be argued that applying MLG to decentralised unitary states stretches the concept even further, we might also point out that the terms federal and unitary systems are themselves often considered to be problematic in meaning (Toonen 2010: 36).

An interesting point of comparison is the discussion of UK as a “lopsided state” (Jeffery and Wincott 2006:4) versus the constitutionally uniform powers of the Länder in Germany. There has been an acceptance of asymmetry in the UK versus an acceptance of a more “unitary” federal state in Germany, although the Länder with larger economies may be more influential in some regards (Scharpf 2008: 512). As a concept, multilevel governance does not specify a uniform or asymmetrical allocation of power to subnational authorities, giving it greater flexibility in its application. As illustrated in the typology, the concept of multilevel governance can encompass both symmetrical and asymmetrical federal and unitary systems.

[48] Another area for comparison is the devolutionary reforms in the UK and federal system reforms in Germany. Both reforms brought about changes leading to more decentralised systems, and both generated questions regarding the overall outcomes of the reforms and possibilities for further changes. Toonen (2010: 39) has promoted an interesting discussion on types of system and reforms that is relevant here. He notes that, on the one hand, “legislated reform” is the most typical type of intergovernmental reform in unitary Westminster systems (Toonen 2010: 39). However, he notes that intergovernmental reform is typically different “in gradualist or consensual systems,” which includes Germany (Toonen 2010: 39). In this type of system,

“…the reform of the intergovernmental…system will most likely be conducted in an organic manner, with (framework) legislation very often following pragmatic and step by step transformations of the system. … The organic systems are supposed to change ‘from within’ which often explains… the prevalence of deadlock – Reformistau – and stagnation if vested interests are unable to mutually agree on the required strategic action…” (Toonen 2010: 39-40).

Many of these points are relevant in the federal system reform process in Germany that we examined above. It also suggests that a significant area for further research is the application of the concept of MLG to a comparative analysis of institutional reforms in polities that are traditionally considered “federal” or “unitary.”

Emerging governance structures best viewed through the lens of Type II MLG are also an area for comparative analysis, and one in which the two countries in our study share similarities. In Germany, the creation of inter-municipal bodies and other Type II MLG structures discussed above, pose challenges for intergovernmental relations. In the UK, “Distributed Public Governance” manifests itself in terms of the proliferation of “quasi-autonomous non-governmental organisations” (“quangos”) (Bache and Flinders 2004). To what extent do such changes affect intergovernmental relations in traditionally “federal” or “unitary” MLG systems differently? This is an area for further research.

The role of political parties in multilevel systems is already an emerging area of research. With respect to our comparison, the intertwined nature of political parties and “vertically integrated multilevel systems” (Benz and Zimmer 2011:159) in both Germany and the UK would make for an interesting area of comparison. The work of Hopkin (2003; 2009) is perhaps a starting point here, particularly in the context of devolution.

The research that we have conducted for this paper has also enabled us to generate several additional areas for further research. One area that appears to be at the forefront of current writing and theorising on MLG involves normative questions such as the legitimacy of MLG systems (Piattoni 2009; 2010). While we have touched on this topic in this paper, limitations of space have prevented us from exploring the issue in greater depth here. This is an area of MLG that calls for considerably more comparative study. Normative concerns [49] are also an important element in the work of proponents of the multinational federalism approach (Gagnon 2011), and this may be an important area of theoretical dialogue between the two approaches. It may also be advisable to extend the comparison of intergovernmental relations in North America versus Europe that was initially explored in Ongaro et al. (2010) to other geographic areas. Further analysis of unitary states in terms of MLG is also a promising area for future investigation.