EU cultural policy seems to be a field nobody is especially interested in. Not the artists who tend to look with distrust at the European integration process, not national politicians who feel that culture and the arts are a prerogative of the member states, and even not the EU institutions themselves who fear conflicts with national interests. Still, EU cultural policy exists and its impact is growing (although still marginal, at least compared with national cultural policy in Austria) due to the fact that the EU develops continuously from a mainly economic community to a political one. Discussion about the constitutionalisation of the EU and the foundation of a Convention to prepare a constitution are clear signs of this development.

It is of high impact that a paper on cultural policy has been delivered within the context of this constitutionalisation and it is even more gratifying that this paper represents both a progressive understanding of the arts and of politics. The comments delivered here will hopefully help to trigger an urgently needed broader debate on this subject.

1. Summary of the Paper

The paper of Kaufmann and Raunig gives an overview of the history and status quo of European cultural policy, proposes new concepts and develops concrete policy recommendations. It thereby focuses exclusively on the European level; national and local cultural policies are not taken into account.

The paper starts with a description of the halting early development of European cultural policies and its first inclusion into primary law in the Treaty of Maastricht and Amsterdam. The authors positively evaluate the focus on cultural exchange and co-operation of the article in question (151) but criticise the undisputed concept of European identity that is implicit part of it. They furthermore object to the general principle of subsidiarity and propose instead to decide questions of competence according to the concrete problem at stake - there are many cases where border-crossing cultural initiatives would justify a European instead of a national engagement in cultural affairs. Finally, shortcomings of the implementation of EU cultural policies are enumerated: The "mainstreaming" requirement of taking into account culture and cultural diversity within all EU policies is rarely fulfilled and, generally, the authors notice a standstill in the field of European cultural policies

The second part "Towards New Concepts of Cultural politics" proposes new corner stones for European cultural policy:

· New forms of (politically understood) and always provisional autonomy in the field of the arts beyond ideological legends;
· Cultural initiatives as a means to create plural public spaces and transparency and to enable participation;
· development of specific, politically relevant competences of cultural workers;
· development of transversal (instead of interdisciplinary) concepts for culture, i.e. politically effective border-crossing concepts.
· development of cultural commons instead of cultural industries

According to these concepts the third part delivers (rather cursory) new tasks for European cultural policy. Multilateral initiatives and networks as well as critical publics should be at the centre of EU activities in the cultural field. To reach this aim, European cultural policy should abandon symbolical politics and focus on political contents, considerably raise its budget and simplify administration.

2. Critique

As mentioned at the beginning of this paper it is of high impact that a statement on cultural policy has been delivered within the context of the European convention. However, the paper of Kaufmann and Raunig does not really argue why one should put hopes into European cultural policy, or - to put it even more generally - why there exists something like a cultural policy of the European Union. This seems the most striking deficit of this paper that is probably due to the fact that the authors are not really interested in the structures and developments of the EU. This is why the paper focuses exclusively on EU cultural policy and excludes national cultural policies - a problematic decision if we take into account that all policies within the EU are carried out in the interplay of EU institutions and national institutions. Especially statements like "The funds available cover neither the prospects and needs of the cultural sector." (p.5) do not make much sense when meant exclusively for the European financing.

A lack of interest in the EU as such is probably also the reason that the description of early activities in the field of European cultural policy include organisations like the UNESCO and the Universal Declaration of Human Rights that are clearly not part of the EC (page 7). Although it certainly makes sense to show the general climate of the 1940s and 50s with regard to cultural affairs it would also be important to take into consideration the special role of the EC in this time as an economic enterprise with a political aim (namely to prevent fascism and war) Additionally, an analysis of EU media policy would be interesting as it started much earlier than cultural policy (in the early 70s) The argument for these activities was that television is mainly an economic and not a cultural affair and the debates around this issue show how intricately interwoven EC policies and political power play are. Those who maintained that television is a cultural good did so in order to keep this subject in the national realm while those defining it as an economic good wanted to enlarge EC competences. Consequently, those maintaining that television is an economic good aimed at EC regulations that differed from regulations for other "economic" goods. Furthermore, the development of EU media policy can be seen as a symptom of the changing self-understanding of the European Community: The directive "Television without Frontiers" (1989) only aims at preventing distortions of free competition through national protectionism while the Treaty of Amsterdam (1997) explicitly allows for subsidies for public television of the member states. These two corner stones of EU media policy can be understood as part of the development of the European Union from a purely economic towards a political project.

Thus, the development of EU policies in the fields of media and culture are part of the changing identity concept of this polity. Unfortunately, this independent variable of European policy making is not taken into account by the authors of "Anticipating European Cultural Policies". While this omission is understandable giving the many intrinsic problems of the concept of identity - theoretically blurred and practically-politically easily misused -it is also true that a democracy cannot do without this concept. (Although, of course, dynamic and non-essentialist concepts of identities are possible and should be strived for.) A democratically organised political community (and this seems to be the telos if certainly not the actual reality of the EU) needs per definitionem a demos who is the sovereign. And a precondition for a demos is some form of loyalty with a political entity, i.e. a collective political identity. It is an important aim of cultural politics of every political entity to enhance political identity and therefore, in my opinion, it does not make much sense to blame the EU institutions for this aim as Kaufmann and Raunig do on page 17. The changes of EU identity are probably also the reason for the fact that EU cultural policy that has been rather limited and clandestine during most of the history of the EU nowadays becomes broader in scope and bolder in its publicity. The identity conflicts between the European polity and its member states make it highly improbable that the unanimity rule in the Council in cultural affairs will be replaced (page 15) although I agree with Kaufmann and Raunig that this move would be of a high positive impact for effective cultural policies.

Cultural politics are - among other things - always identity politics. This holds true for the national as well as for the supranational level. The deepening and enlarging of the European project, its politicisation and the inclusion of hitherto excluded states give the question for its identity renewed actuality. European cultural policy is developed within this context. More productive than to simply deny this fact would probably prove to deal consciously with it - to search for possibilities of designing political identities more positive and dynamic and less exclusive than in the national framework. The neglect of this core point leaves the ambitious political concepts of Kaufmann and Raunig without obvious link to the political system that should implement these ideas. But only if structural and ideological presuppositions of the European Union are taken into account the paper can fulfil its own claim to contribute to the constitutionalisation process of the EU.