Martin A.

Schain Managing Difference: Immigrant integration Poiicy in France, Britain, and the United States

IN

2004,

ARISTIDE

ZOLBERG DEVELOPED AN APPROACH TO

understanding immigrant integration that relates past experience, policies, and institutions to the present democratic management of cultural differences. Diversity, and diverse populations, he argues, is hardly a new phenomenon. Indeed, contrary to re-writings of history that represent cultural diversity as a departure from the norm, in reality heterogeneity was the more usual state of affairs. What has changed is the pattern of the management of diversity, and the relationship of these patterns to past experience. A distinctive feature of today's situation is that the differences are emerging under social and political conditions that render some of the older responses unfeasihle, either because they are impractical or because they are ruled out by the receivers' institutionalized obligation to respect human rights. . . . In this perspective, past experiences of diversity are relevant . . . as acceptance of diversity as a "fact of life" will contribute to the reduction of social tensions and the pohtical extremism they feed. . . . Moreover, management of the old differences generated

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dynamics that still play an important part in the political life of their societies (Zolberg 2004:1-2). In this paper I will compare changes in immigrant integration policies in two European countriesFrance and Britain^with those of the United States. I vdll focus first on the "national models" around which integration policies have been described, and then on the dynamics that are driving the changes and evolution of these models. I argue that national models in each country differentiate the direction, the content, and the intensity of integration policy. These differences are most evident, moreover, if we examine not only the policies themselves, but the perceived success and failure of different integration policies. I argue that three dynamics have been driving the evolving management of integration policy: problems of urban order, the development of European Union, and perceptions of failure and success. UNDERSTANDING NATIONAL MODELS Scholars have frequently compared various "models" of incorporation as if most countries have well-thought-out policies based on either national traditions or reasoned strategies for "making" foreigners into Frenchmen, Britons, or Americans. The countries that are the subjects of this paper appear to be committed to very different ways of integrating immigrant populations that vary by the use of state institutions, the kinds of policies pursued (indeed, whether or not they actually have explicit policies of integration), and the assumptions behind these policies. They also vary in terms of what they expect integration to mean, what should emerge at the end of the process.^ Finally, they appear to vary in terms of what has emerged through the process of integration. Although pubhc philosophies are often clear on objectives, they neglect other kinds of realities. First, in each of these countries, actual public policy (as opposed to policy goals) that deals directly vwth integration is limited, and often contradictory. There is often a wide gap between stated public philosophies and policy on the ground. These understandings of integration models, moreover, often ignore the

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evolution over time of both public philosophy and public policy rooted in this philosophy. If this is true, a question remains whether the concept of public philosophy has any meaning at all, apart from political rhetoric. I v^^ould argue that it does, as long as we can demonstrate empirically that "its principles continue to inspire government policy towards immigrants," and to alter the rhetoric would in itself "weaken (and perhaps even dissolve) the social fabric" (Schnapper 1994:133-135). MANAGING DIFFERENCE: FRANCE The best defined process of integration seems to be the French Republican model, which has become more explicit in detail as its assumptions have been challenged by the most recent waves of immigration from North Africa. In principle, the French model recognizes the legitimacy of collective identities only outside the public sphere. This has come to mean that ethnic and religious groups are accorded no special privileges in public policy, nor are they granted special protection. This also means that there is "color-blind" public support and recognition only for individual merit and individual advancement (Noiriel 1988:189-245; Long 1988: 82-105). The first indication of the complexity within the French Republican model can be seen at the local level, as political parties attempted to integrate the post-World War I wave of European immigrants. Between the wars, among the most powerful instruments for integrating new immigrant populations were the trade union movement and the French Communist Party, both of which sought new members (and eventually electoral support) by mobilizing workers from Poland, Italy, and after the Second World War, workers from Spain. Part of their effort certainly focused on class solidarity, but mobilization was also based on ethnic and religious solidarities (Withol de Wenden 1988: 50). The establishment of communism in immigrant communities eventually destabilized older political patterns in these same areas, but at the price of the establishment of local ethnic machines, many of which endured well into the Fifth Republic (Schain 1994).

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Wefinda similar pattern with the wave of Third World immigration after 1960. Studies on the ground provide clear evidence of the recognition of immigrant collectivities by both political parties and public authorities. Nevertheless, there are some differences, the most important of which is that the pattern of policymaking has been conditioned by what Maxim Silverman has termed the "racialized" view of the post-1960s wave of nonEuropean immigrants in a way that has clearly differentiated them -om the waves of European immigrants that preceded them (Silverman 1992, chap. 4); and the emphasis on race has probed the limits of the integrative capacities of the French version of the melting pot. In contrast to the tradition of positive sohdarity that Communistgoverned municipalities had developed toward predominantly European immigrants, by the 1970s many of these same local governments began to treat non-European immigrants as temporary residents who must be encouraged to return home (Schain 1985). As during the earlier period. Communist municipahties tended to treat new immigrant communities as collectivities, but now in an exclusionary manner. This pattern was not, however, unique to towns governed by Communists (Grillo 1985:125-127; Barou 1994: 24). Perhaps the most important change was the growth of ethnic associations after legislation legalizing them was passed in 1981. By the mid-1980s, these associations had become a network of established intermediaries for immigrant populations that negotiated with trade unions, political parties, and the state at the local and national levels (Wihtol de Wenden 1992). In contrast to earlier periods of immigration, these associations operated largely outside the established network of intermediary groups, which were then forced to recognize their independent existence. Even when established and more universal intermediary groups, such as trade unions, did succeed in incorporating their leadership, such incorporation remained conditional and problematic (Schain 1994b)
Multiculturalism and Urban Order

But how can we understand this evolution of policy on the ground? Perhaps the best explanation is that the French state has focused on

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multicultural policies as it has given greater attention to issues of domestic security. As periodic urban riots that started in the early 1980s continued over more than two decades, the involvement of the state grew, and its efforts contributed to the development of ethnic organization as state agencies engaged in a sometimes desperate search for intermediaries among what became known as the "second generation" (Body-Gendrot 1993, chaps. 5 and 6; Jazouli 1992). In a sometimes desperate search for interlocuteurs valables among the "second generation," both local governments and the central state sought out and sometimes supported whatever ethnic associations they felt could maintain social order. In education, problems of rising dropout rates and student failures among the children of immigrants resulted in the establishment of several programs, the most important of which was the zones of educational priority (ZEP) (Caron 1990). Clumsy rules that targeted geographic areas, rather than populations, were made necessary by the restrictions imposed by the Republican model, and a 1978 law dealing with information.2 This has meant that relatively narrow geographic criteria have taken the place of group criteria. In this way, the Republican model had molded the way that groups are targeted, but has not prevented the implementation of special programs. In fact, various approaches to discrimination have become integral to policy on integration since 2000. Although the "race-relations" approach to integration has been far more characteristic of the British approach, France has moved in this direction, largely in response to the directives of the European Union in 2000 (Council Directive 2003a; Council Directive 2003b). The High Authority against Discrimination and for Equality (HALDE) was established in 2005, and issued its first report in May 2006. During its first year, it received more than 2,000 complaints from individuals, 45 percent of them complaints of employment discrimination.
The Public Philosophy

Looking back over the last 25 years of French policy on integration, what is most striking is first, that there has been a greater volume of policy.

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and a struggle to manage integration in a more explicit way. It has been a policy bom of a quest for public order, and has been developed as a result of challenges to that order, from the urban riots that have punctuated French urban life to the challenges posed by young girls wearing hijabs. Although flexible policies have been developed locally, mainly through administrative actions, periodic laws that deal with integration have tended to reaffirm the principles of the Repubhcan model. The second characteristic of French policy on integration has been a more intensive effort to require through state policy what had previously been assumed would emerge from residence and education. Since 1945, the French Civil Code (Articles 21-24) has stipulated that no one can be naturalized vdthout demonstrating his or her "assimilation to the French community" through knowledge of the French language. The Sarkozy law of 2003 (Sarkozy was then minister of the interior) requires demonstration of knowledge of rights and duties of French citizens, a requirement that was strengthened in the legislation passed in 2007. The new law required a contract for family unification, v^rith sanctions for violation, and those applying were required to take two-month courses that constituted "an evaluation of language ability and the values of the Repubhc" in their home countries (Schain 2008: 57). The third characteristic of French integration policy is that it is constrained by the development of European integration (see below).
MANAGING DIFFERENCE: BRITAIN

The French political philosophy on integration can be compared with a difFerent kind of British multicultural approach to integration, developed through a policy consensus between the two major political parties (Katznelson 1973: 125-126). This policy consensus was partly based on a race-relations approach to immigrant integration that was seen as sharply different from the French approach. By focusing on access racism (discrimination in housing and employment), and by providing an administrative agency as an advocate/enforcer for that policy, the Race Relations Act of 1965 provided an institutional base for integration that was agreed to by both major political parties. The extension

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of this legislation in 1968 and 1976 then provided substantial depth to this approach, which secured a bipartisan approach to immigration, race, and multiculturalism (Hansen 2000: 28; chap. 6). By 1968, the race relations approach to integration had begun to take on a life of its own, disconnected from considerations of immigration control (Bleich 2003: 84-85). The concept of "race" in Britain was applied to virtually all "New Commonwealth" immigrants (primarily those from Pakistan and India, as opposed to those from Canada, Australia, and New Zealand) in political debates about "coloured" immigration from the 1950s on. This way of looking at non-European immigrant populations was similar to the way that immigrant populations were viewed in France. However, in Britain, the difference was incorporated into the formal policy framework that was developed to manage and incorporate them. While in France, acceptance of this kind of pluralism (often called "insertion") was seen as a temporary substitute for full participation in society, in Britain it was increasingly understood as an important dimension of such participation (Weil and Crowly 1994: 118). By the 1980s, the education system had become an important proactive support for multiculturalism, which was also firmly grounded in the legal system. Thus, the British approach to integration evolved out of a poUtical compromise on immigration legislation, as an approach to ease integration with an active antidiscrimination policy. The articulation of a positive approach toward multiculturalism, although it began with race relations, very quickly evolved into a broader understanding of multiculturalism. Roy Jenkins, home secretary at the time, noted in 1966: "I do not think that we need in this country a melting pot. . . . I define integration therefore, not as a fiattening process of assimilation but as equal opportunity, accompanied by cultural diversity, in an atmosphere of mutual tolerance" (Benton 1985: 71). Jenkins' perspective was reinforced by a series of reports on education, beginning with the Swann Report in 1985. The Swann Report (Education for All) strongly advocated a multicultural education

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system for all schools, regardless of institution, location, age-range, or ethnicity for staff/pupils. The report made a Unk between education and multiculturalism by noting that racism had an effect on the educational experiences of black children in the United Kingdom. These conclusions have been reaffirmed by numerous reports since then. (Swann 1985) Perhaps most important was the 1997 report by the Commission on the Future of Multi-Ethnic Britain, which reaffirmed the United Kingdom as a "community of communities." The net effect was what one author has called "a conceptual shift" (Brighton 2007: 5) that disassociated integration from immigrationthe management of arrivalsand, as Tariq Madood has observed, recognized integration as a two-way process of dual responsibility (Modood 2006: 2).
Multiculturalism and Urban Order

With roughly the same rhythm as in France, riots have erupted in major British cities with high concentrations of immigrant populations (for example, 1981,1991-2,2001). The British riots have had many of the same characteristics of their French counterparts, except that they have been more violent in terms of personal injury to residents and the police. The most important difference has been the political consequences of the riots in each case. The first post-World War II civil unrest in Britain was in 1948-1949 in Liverpool, Deptford, and then Birmingham, but the riots in Nottingham and Notting Hill in London in 1958 are generally cited as the first serious outbreaks. The reaction of French authorities to the first urban riots in Lyons in 1981 was to frame the problem in terms of social control and education. The British reaction to the riots in 1958 was to frame the problem in terms of race relations, the solution for which was to limit immigration, and prevent a British Little Rock (Miles 1984: 262). By 1964, however, the 1958 eventsstill seen in terms of race relationswere understood as a problem to be dealt with through a new approach to integration that would focus on antidiscrimination (Bleich 2003: 45). Similar to the French initial integration efforts, the British approach was rooted in a need to maintain public order (Hansard 711: 927, cited

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by Bleich 2003: 45). Indeed, this approach endured, and was strengthened even after three additional rounds of serious riots between 1981 and 2001, as well as the attacks on the London underground in July 2005. Nevertheless, as in many countries, including France, there is growing pressure in Britain to assert the limits of multiculturalism and support a stronger sense of collective identity. By 2001, in the aftermath of urban riots in the summer and the attacks in the United States in September, government reports indicate the beginning of a reassertion of policies of civic integration into a society based on shared values. The Cantle Report (Cantle 2001), which was being drafted at the time of the attacks in the United States, linked the summer riots to highly segregated communities, but the report's conclusions centered on the need to redress this situation through a "greater sense of citizenship," the identification of "common elements of nationhood," and the need for the "non-white community" to use the English language and 'develop a greater acceptance of, and engagement with, the principal national institutions' (Brighton 2006:10). This was followed by a Home
Office report in 2002, Secure Borders, Safe Haven: Integration with Diversity

in Modem Britain, which reassociated immigration with integration by arguing that immigration should be contingent on increased civic integration and "shared values" (Joppke 2004: 253). Thus, the attacks in London in 2005 accelerated a process that had begun four years before. Although the actual policy requirements in place by 2007 were not as coercive as those in France (or the Netherlands,) they were moving in the same direction (Brighton 2006). The most important symbolic change in this direction has been the initiation of a citizenship test and a citizenship ceremony under legislation passed in 2002. Beginning on November 1, 2005, all applicants for naturalization were required to pass a "Life in the UK" examination, together with certification in the English language. Together with new citizenship ceremonies that include a pledge of allegiance, the civics and language tests are meant to create a meaningful gateway for integration, the kind that has never existed before in Britain.

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The Public Philosophy

The British government has not reversed course on multiculturalism, although it does appear to be devoting more resources to civic integration. After 2005, governments devoted greater attention to what has often been phrased as a "hearts and minds" approach to Muslim communitiesthat is, by government attempts to enlist Muslim individuals and community organizations in their efforts to enhance security. These outreach efforts have been far more extensive than similar programs in France. The government is also pursuing cooperation at the European Union level that began with the French initiative at the meeting of interior ministers (G6) in March 2006.^ At that time, (then) Home Secretary Charles Clarke noted that he supported a more muscular integration contract that would ensure that "new immigrants live up to the values of our society," and that they could be expelled if they did not (Williamson 2006). Thus the French have begun to focus on issues of discrimination, while the British have become increasingly concerned with questions of civic integration. In focusing on the convergence of policy concerns, however, we should not lose track of the differences of the policy emphasis and content. The British debate about the new national curriculum is relatively mild, compared with the French control over educational content through the ministry of education. The British citizenship examination is also mild, compared with the new French requirements for naturalization and family unification. Compared to Britain, the French state has become a far more important actor in the integration process through direct intervention. In addition, we should be clear that convergence indicates a direction in the policy process, but not the content of the policy itself. MANAGING DIFFERENCE: THE UNITED STATES The multicultural ideal of the United States as a "nation of nations" is a recent phenomenon, dating more or less from the period around the Second World War. During most of the nineteenth century there

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seemed to be a sense among social and political leaders of something increasingly "American." Basically, this reflected a more widespread attitude about the nature of American homogeneity and the basis of American citizenship that endured until the last decade of the nineteenth century. Assimilation would flow from the operation of social institutions, what John Higham has called "a confldent faith in the natural, easy melting of many peoples into one. When fearful of disruptive influences, the Americans sought to brake the incoming current or to inhibit its political power; otherwise they trusted in the ordinary processes of a free society" (Lowi 1969, chap. 1; Higham 1963: 234). Although this ideal lacked some of the institutional support of the French Jacobin model (in particular a national system of education), it did provide an Anglo-Saxon ideal, and supported English as a common language. Indeed, the literature on the ideal of immigrant integration during the nineteenth century in the United Stateswhatever the contradictions in realityseemed destined to play a role in America not unlike that of the French Republican model. It supported intermarriage and the hegemony of English cultural and political values together vith English as a common language. The ideal gained increased institutional support at the local level, as education spread after the Civil War, even if ethnicity did in fact form a basis for initial settlements and poUtical organization for collective advancement (Fuchs 1990, chap. 1; Bridges 1984, chaps. 3-5). The most important impact of the "new" immigration of the early twentieth century was the rst government attempt to link naturalization policy with ideas about what it meant to be an Americanthe first "Americanization" programs (Higham 1963: 140-142). In the literature on the development of American identity there is considerable discussion about the difference between the "new race" ideathat Americans were/are an amalgam of European cultures, vdth the whole being distinctive and different from the partsand the "modified Englishman" idea: that Anglo-Saxon culture has dominated the American ideal, that other European cultures (Catholic and German in particular) were far less welcome as part of the melting pot, and that Asians, Native Americans,

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and Blacks were excluded from the pot entirely (King 2000: 14-19). Nevertheless, there is little doubt that at least until the First World War, there was a vdespread assumption among public and private leaders on every level that there was a pervasive cultural homogeneity in the United States, and that "interchangeability and assimilability were deemed necessary conditions for citizenship" (BCing 2000:18). On the eve of the First World War, six states in which large numbers of immigrants were concentrated organized commissions and programs that combined investigations into the living conditions of immigrant populations with civic education programs. Efforts to harmonize these efforts were coordinated by the Committee for Immigrants in America, a private group sponsored by wealthy progressive donors. The committee finally gained the support of the Bureau of Education in Washington, within which was established the Division of Immigrant Education, the unique goal of which was to publicize the need for immigrant Americanization through education. Federal support for the Americanization effort began to ebb after 1920, but numerous states continued what had become a crusade by passing coercive legislation that ranged from requiring that English be the sole language of instruction in all public and private primary schools in 15 states, to requiring that non-English-speaking aliens attend English classes in two states, to more draconian measures that were eventually declared unconstitutional (Higham 1963:260). By 19211922, Americanization programs were cut back due to the pressures of economic contraction, but the ideals and values remained dominant until after the Second World War.
Multiculturalism and Urban Order

The movement toward multiculturalism was given impetus by a process that began with ethnic organization between the First and Second World Wars, and by the recognition of the legitimacy of a multiethnic America that was portrayed by government propaganda during the Second World War. It was substantially reinforced, by the emergence of what Martin Kilson has called "Black neoethnicity" in the midst of

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the civil rights struggle the 1960s (Kilson 1975). In this sense, it had far more to do v^dth urban unrest and the civil rights movement than with immigration. As in Britain and France, the change in public philosophy was related to urban and racial tensions. Nathan Glazer has argued that Black neoethnicity was a direct result of the failure of the integration efforts of the early 1960s. For Glazer, Black Americans became the "storm troopers" in the battles about multiculturahsm (Glazer 1997: 94). Indeed, the ideal of neoethnicity, a Nation of Immigrants,'^ began to emerge at the same time that intermarriage among the children and grandchildren of European immigrants was sharply on the rise, and when important indicators of ethnic "memberships" were on the decline (organizational membership and language ability above all). Government programs in the 1960s that were said to create minorities "by ascribing to them certain characteristics that served to justify their assignment to particular societal roles," represented an attempt to deal vdth a racial crisis, not immigration or assertions of multiculturalism, but had unanticipated responses.^ Institutions that were set in place to deal vwth race problems in the United States had a direct impact on the approach that the government took in shaping immigrant integration. One indication of the change came in the legislation passed in 1972, and signed into law by President Richard Nixon. Congress voted $15 million to fund an ethnic heritage program, and history curricula were altered to include African Americans, Native Americans, as well as a variety of ethnic groups (King 2000: 32, 266-276; Fuchs 1990, part V). The role of the federal government in shaping a multicultural approach to immigration can be understood on several levels. At the most basic level, immigration law now favors and promotes diversity. The Immigration Act of 1990 included a program of "diversity visas" that would eventually provide for the admission, on an annual basis, of 55,000 immigrants from "underrepresented" countries chosen by lottery. What began as an effort to relieve the backlog of applications from Ireland ended as a mechanism for increasing the diversity of the population of the United States. Indeed, when the House and Senate

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conferees emerged with a final agreement on the 1990 legislation, they called their compromise agreement a victory for cultural diversity, "for family unity, and for job creation" (Tichenor 2002: 274). Even as an afterthought, American political leaders were seeking to promote what European leaders either feared or sought to carefully manage: cultural diversity. A second key federal program that has shaped the national approach to multiculturalism is the antidiscrimination effort initiated by the Civil Rights Act of 1964. Under rules developed by the Equal Employment Opportunity Commission (EEOC) in 1965, employers were required to file annual reports not only about the race of their employees, but about their sex and ethnicity as well. These rules not only included immigrant groups in their mission, but also provided the basis for proactive action by the EEOC that promoted the employment rights of diverse groups, including immigrants (Blumrosen and Blumrosen: 4). In the same way, the Voting Rights Act of 1965 has been applied to immigrants in ways that promote diversity. Since 1975, the Voting Rights Act has required ballots and other election assistance in languages other than Enghsh in jurisdictions where at least 5 percent of voting-age citizens are not proficient in English and literacy rates are below the national average.^ Finally, the approach to religious diversity at the national, state, and local levels has both permitted and encouraged multiculturalism in the United States. The absence of state sponsorship in the United States does not mean that religious organizations are not accorded a privileged status. Under specific conditions, they are granted a special tax status that permits exemption from both national and local taxes. Various forms of recognition are also implied when local governments recognize religious holidays as a reason for school absence and suspension of restrictions for parking cars. In each of these areas, policy was initially formed in the context of a need to promote and maintain public order Increasingly, however, it is driven by institutionalized interest group activity. Well organized ethnic interest groups have protected and expanded entry require-

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ments that favor their constituencies (Fuchs 1990, chaps. 13, 18). In addition, business groups have been consistently active in ensuring access for Mexican and Latin American workers for agribusiness. Thus, illegal border crossing at the Mexican border and the enforcement of controls can be seen in terms of cycles of enforcement that reflect the influence of employer interests (Schain 2008: 219-220; Andreas 2000; Cornehus 2004:1). Islam, however, has not posed the same challenge to integration policy in the United States that it has in Europe for three speciflc reasons. The flrst is that most Arabs in the United States are not Muslim (25 to 30 percent are estimated to be Muslim), and at least a third of American Muslims are African American and not immigrants at all (Project MAPS 2004:47-48). The second reason is that the Muslim immigrant community in the United States is predominantly middle class, and has not been implicated in patterns of urban unrest. Finally, the Muslim-immigrant community in the United States is very small, and therefore does not have much influence on thinking about immigration policy. Nevertheless, as Zolberg has noted, the pattern of integration of Islam in the United States provides an interesting case study. In a way that followed similar arrangements for Jews after the Second World War, schools and workplaces recognized Muslim dress codes, dietary restrictions, and holidays (the lead having been taken by African American adherents) beginning in the 1970s (Zolberg 2004:17, 51). Therefore, the precedents of Jews, and Catholics before them, have eased the way for Muslims through established institutional arrangements and legal precedents. Although officially there are no public funds for the construction of mosques available under the American version of separation of church and state, in general there were no problems using funds :om foreign sources for their construction, as well as for the construction of schools. This relatively easy relationship declined after 2001, but the process has remained the same, following the pattern established for Catholics and Jews. One important change is that Muslim organiza-

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tions have now increased their role in defending civil rights, much as Catholics and Jews had done in earlier periods (Hagopian 2004: 9-71; MacFarquhar 2006). Perhaps more important, activists in these communities are looking at the experience of other immigrant groups as a model of how to understand their own position in American society (Nagel and Staeheh 2005).
Relevance of the Public Philosophy

The public philosophy of multiculturalism in the United States, born of public policy strategies to deal with urban unrest and racism, has endured challenges and debates during the past 30 years. Unlike what has occurred in Europe, in the United States there has been little attempt to reinforce or reinvent policies of civic integration. In fact, the questioning of the American multicultural model was far more intense during the years before the crisis of Islamic extremism than during the years since (Schuck 2003, chap. 4 and 324-331). What appears to be a laissez-faire policy on integration is nevertheless shaped in a variety of ways by the states and by the federal authorities. The United States does not have an explicit integration policy, at least at the national level. It does, however, have a durable permissivefi-amework,based in constitutional law (dealing mostly with questions of discrimination and the establishment and expression of religion), and on legislation. Pohcies originally developed to deal with race relations, rather than immigrant immigration, have been important in shaping integration of immigrant communities since the 1960s by providing a strong, proactive national antidiscrimination structure that served as a model for the British eftbrt after 1965. Thus, in different ways, the integration processes in France, Britain, and the United States have moved toward different kinds of multiculturahsm.

CONVERGENCE AND THE EUROPEAN UNION

Christian Joppke has made a persuasive argument thatin part as a reaction to perceived failure there has been a convergence of integration policy in Europe around civic integration and antidiscrimination

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policy (Joppke 2007: 243). The new trend tends to emphasize civic integration policies that create an obligation for immigrants who wish to attain the rights of citizens to individually demonstrate that they have earned those rights. The development of a policy of civic integration was moved to the European Union level at the initiative of Nicolas Sarkozy, when he was the French minister of the interior. In March 2006, the interior ministers of the six largest European Union countries (the G6) agreed to pursue the idea of an "integration contract," using the French model as a starting point. The initial step was to create a committee of experts to investigate the procedures used in all member states. They then planned to propose such a policy to the other 19 countries of the EU. Indeed, one of the first initiatives of the French presidency in 2008 was to propose a comprehensive, compulsory EU integration program. The compulsory aspect was finally dropped in June, but a "European pact on Immigration and Asylum" was passed by the European Council in October 2008. Three criteria were accepted for acceptance and integration in Europe (according to the French government): language mastery of the receiving country; knowledge and commitment to the values of the receiving country; and access to employment.^ At the same time, antidiscrimination programs in all European countries have grovi in importance, and have increasingly benefited those immigrants who have made it past the door. First initiated in Britain in 1965, the antidiscrimination approach was given a major push by the Treaty of Amsterdam in 1997 and two directives of the European Council in 2000 (Council Directive 2003a, 2003b). The treaty, which came into effect in 1999, brought questions of immigration, and to some extent integration (particularly the revised Article 6a on how to combat discrimination based on sex, racial, or ethnic origin, religion or belief, disability, age, or sexual orientation) into the EU structure. Policy would be harmonized on the basis of proposals made by the commission, and actions of the Council of Ministers. The directives obligated all EU countries to constitute commissions that would both monitor and act against patterns of racial discrimination. Since then

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the emerging institutions have begun to offer immigrant communities a measure of recognition and protection. Thus, both of these evolutions in policy have created overlapping similarities in the approach of all European countries to questions of immigrant integration. If the first has constrained policies of multiculturalism, the second has given new support and legitimacy to racial and ethnic diversity. The United States has long required some aspects of civic integration now being promulgated in Europe; and U.S. antidiscrimination policy was a model for the British program, which is nowin turna model for other European countries. FAILURE AND SUCCESS The French, British, and American models imply criteria of success and failure based on their objectives. In the French Republican model, the acceptance of common cultural and historical references is important, as well as conformity with French cultural and legal norms, in particular the acceptance of a common public space that is separate from religious faith and expression. The British model accepts cultural and racial and religious diversity as a necessary dimension of participation in society, rather than simply a way station to a deeper nationhood, but implies a civic commitment to political-culture values. The American multicultural model implies a similar commitment to what Lawrence Fuchs has called a permissive civic culture that protects diversity (Fuchs 1990: xv). Although perceptions of policy failure of integration have been widespread and politically salient for the French and the British, this issue has not been nearly as important for the Americans. For the French, the perception of failure began in the early 1980s, vdth the beginning of cycles of urban violence that culminated with nationwide riots in November 2005. The policy debate has tended to focus on the failure of the school system to effectively integrate new waves of immigrants as effectively as it had previous waves, on spatial concentrations of immigrants, and on urban unrest. For the British, the perception of failure began in 2001, and has grown vdth intensity after the attacks in July

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2005. In the American case, the perception of failure was widespread among intellectuals during the decade of the 1990s, but has faded since (Sahns 1997, part III; Huntington 2005; Schessinger, Jr 1991). Peter Hall has argued that policy failure and attempts at adjustment may very well lead to further failures (Hall 1993: 79). The problem is that in each case, the reference to national models has sometimes blinded the government to its success, and has made it more difficult to deal with its failure. In each case, the policy focus implied by the national model has been successful in achieving critical objectives, while what has not been emphasized has resulted in failure. As a result of the Amsterdam Treaty, one set of standards that we can use to evaluate relative success and failure has been formalized in a list of "Common Basic Principles for Immigrant Integration Policy in the European Union," agreed to in the Hague Program in 2004 as part of a common program for integration. Among the 11 agreedupon principles, the most important are employment as a key part of the integration process, education as critical to preparing immigrants to be more successfiil and more active participants in society; access for immigrants to institutions, goods, and services; and participation of immigrants in the democratic process and in the formulation of integration pohcies and measures (Council of the European Union 2004: 19-24). At their core, these principles generally refiect criteria that are also used by specialists to measure degrees of integration in the United States.^ From these principles, we can derive several measures of integration that can give us some indication of relative success and failure. If we look at two dimensions of integration, socioeconomic and cultural, it is evident that success in one does not necessarily predict success in the other, and in important cases, relative success in education and employment may correspond with evident failure in the convergence of value acceptance (see fig. 1). Not surprisingly, unemployment rates among immigrant populations have been generally higher than those of the native population, with the exception of the United States, where relatively high unemployment rates among Hispanics offsets higher employment among

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other immigrant groups. Compared to the United States and Britain, however, unemployment is higher by far among French immigrants. Moreover, youth unemployment is also highest among the French, almost three times the level of immigrant youth unemployment in the United States (see table 1)! Educational attainment is more complicated. Educational attainment among immigrant populations at the university level is as great as or greater than that of the native population in all three countries. Yet, the proportion of immigrants who drop out, or who never get to
SUCCESS IN CULTURAL/VALUE INTEGRATION

SUCCESS IN SOCIO-ECONOMIC INTEGRATION

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FR

NL

Figure 1: Two Dimensions of Integration Success/Failure

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Table 1: Unemployment Rates for Immigrants and Natives in 2 0 0 4 Immigrants France Britain Netherlands US 13.8% 7.3 10.3 5.8 Nonimmigrants 8.0% 4.7 3.6 6.9

Sources: Data from OECD 2006: 73; European Community Labour Force Survey.

upper secondary education, is disastrously high in France, very high in the United States, but comparatively low in Britain (see table 2). These differences are confirmed by an analysis of achievement scores in reading, math, and science among immigrant children in 10 countries, including France and Britain, compared with native children of the same age. Low achievement scores were almost 40 percent higher in France, compared with Britain. Some of this difference can be accounted for by differences in socioeconomic status. In France, if we control for socioeconomic status, lack of achievement at the lower levels continues to be significant, while in Britain, first-generation immigrant children do as well (or as poorly) as others of the same age (Schnepf 2004: 12, 23, 33-36,40). This is important because educational attainment has
Table 2: Educational Attainment of Immigrant Populations, 2004
Less Tinan Upper-Secondary Education Native-born France Britain
US

University Degree or Greater Native-born

13% 20 27

Foreign-born 56% 45** 32.8

Foreign-born
12% 28 27

35% 49 12.5

UK = no qualification -"O" level; France = BEPC (first-cycle high school) "no qualification: UK = 10%; France = 50% Sources; (France and Britain): OECD in Figures, 2005: 65; European Community Labour Force Survey; INSEE, Enqute emploi de 2005; Dustmann and Theordoropoulos (2006): 20. US; US Bureau of the Census; US Congress (2004)., CBO, A Description of the Immigrant Population, November, 2004.

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Table 3: Unemployment Rates of Foreign-born Populations by Level of Education Attainment, 2003-2004

Low Education France Britain Netherlands US 18.4 12.2 6.5 9.1 Medium Education 14.4 7.9 7.3 5.7 High Education 11.8 4.2 3.3 4.3 Diff. Low/ High -36% -66% -49% -53%

Source: Data from OECD (2006: 53).

a Strong impact on unemployment rates for immigrants (for natives as well) (see table 3). Political representation can be understood as integration through politics. As Richard Alba and Nancy Foner have noted, election of immigrant candidates to political ofce is a measure of their integration "in the same sense that entry by minority individuals into high-status occupations is (Alba and Foner 2009). Table 4 indicates that immigrant representation is roughly similar for all three countries at the local/ state levels, but sharply different at the national level, where the more porous American system has generally succeeded in providing better access than either Britain or France. France has consistently had the worst record by far in this area (Anwar 2001). Nevertheless, attitudinal surveys indicate that by several measures, France has been at least as accepting of immigrant populations as Britain, and by others, even more accepting. Indeed, the idea that "immigration is having a good influence" is (perhaps surprisingly) accepted in Europe, and the confidence that Muslim immigrants
Table 4: Political Integration of immigrant Populations, 2004 % Population France Britain US 5% 7.9 12.5 % Electorate 2.7% 6.6 7.4 % State/ Local Reps 3.3% 2.6 3.2 (state) % National Representation 0% NA 2.3 5.3 HR/3.0S

Source: Alba and Foner (2009).

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seek to adapt to customs in their country, and that there is no confiict between devout Muslim practice and living in modern society, is far more strongly held in France than in other countries (see table 5). These societal attitudes are refiected in attitudinal patterns among the immigrant population who identify as Muslim. French Muslims are the most integrative in their orientation and the least confiicted between their Muslim and national identities (see table 6). In addition, a recent study of Muslim elites in Europe indicates a similar pattern. Thus, the British and American records of economic integration of immigrant populations are far better than that of France. These figures, combined with periodic urban violence, have left the impression that French immigration policy has failed, in comparison with policy in the past, and compared vdth other countries (Britain and the United States, for example). The British record of educational integration appears to have been remarkably successful (even if we control for SES), and the record of the United States somewhat less so; the French record, however, is the worst of the three. No doubt the poor French economic performance is linked to the failures of the educational system, where almost two-thirds of immigrants did not attain the level of upper secondary school, and 50 percent simply dropped out without any degree (INSEE 2005: 5). The French record of placement of immigrants in the university system is better than is often assumed, but school retention is far worse than is often stated. Therefore, programs to keep immigrant children in school may be more important that high-profile programs to place them in elite universities. Nevertheless, among immigrant groups in Europe, French people who identify as Muslim appear to be the most "European." As a minority community, they have the most positive views of their compatriots who are Christian (and Jevdsh), and are among the least sympathetic to radical Islam.^ They are the most supportive of ideas that are consistent with the French Republican model. Within Europe, Muslim immigrants in France of Islamic origin, by far the largest Muslim community in Europe, have the strongest national identity and are the most inclined toward integration.

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Table 5: Attitudes Toward Immigrants and Muslims A good thing people from ME and N Afr coming to your country French Response British Response Spanish Response German Response
US 58

Immigration having good influence on your country

Muslims in your country mostly want to adapt to national customs

No conflict between being a devout Muslim and living in modern society

74

Growing Islamic ID good

46

45

11

57

43

22

35

27

62 34

45 47 52

21

36

13 11 37

17 33

26 42

Source: Pew Research Center (2006a: 3, 6, 8,10; 2006b); IPSOS (2006).

CONCLUSION

In the politics of integration, the management of difference plays an important role. In this process, management of the old differences generally reflected in national modelsgenerated dynamics that still play an important part in the political life of their societies. On the other hand, perceived failures in the management of new differences, combined with pressures generated by European Union, have resulted in what is often termed a process of convergence. In analyzing policy convergence, it is useful to look at three dynamics: direction, content, and intensity. Although there has been a movement toward conversion of integration policy in France and Britain, this movement has come from very different directions. France has moved toward more robust antidiscrimination policy, and has developed policies that tend to favor some "positive discrimination" in education. Both sets of policies, however, are relatively weak, compared with the British efforts. They are severely limited by the assumptions

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Table 6: Muslims in Europe: Attitudes Toward Identity, Fellow Citizens, and Modernity Removing headscarf Religion People necessary for ntegra- important with tlon: % Yes Men/women part of your life % No Difference "Muslims in ID with in your country want to adopt national customs

different "country" religious and practice a "religion": threat to our way of life

Paris Muslims London Muslims

9% 5%

20% 7%

23% 9%

6% 22%

+1 -12%

78% 41

Source; Nyiri (2007). "Source: Pew Research Center (2006a: 3.11-12; 2006b).

of the French model, and are hobbled by limits on gathering and using data on discrimination. On the other hand, more recent efforts to provide muscle to civic integration policies are well within the French tradition. Convergence in Britain has taken the form of a movement toward policies of civic integration, and reconsideration (at least at the margins) of the multicultural national curriculum. However, education policies seem to have worked relatively well, and the civic integration effort has resulted in considerable confusion about "the common elements of nationhood." In the case of the United States, policies of civic integration have been weakened over time, while antidiscrimination policy has been strengthened in favor of positive support for multiculturalism. In all three countries, there has been a movement toward more intensive policies, more in Britain and France than in the United States. In each case, convergence has come from a very different direction, based on a perceived but different sense of policy failure. In each case, however, the timid policy movements have been shaped and limited by the dominant policy paradigm based on national tradition and national struggles to integrate new immigrant populations. Indeed, in France and Britain, that paradigm has been stretched and modified, often in contradictory ways. Nevertheless, the clear failures

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do not seem to have undermined the authority of the existing policy paradigm, and its advocates have retained both their passion and their legitimacy. This helps to explain whyat least until novi'important national differences remain.^" In many ways integration policy on both sides of the Atlantic is convergingboth in terms of expectations and in terms of permissive and proactive state action. In practice, if not in principle, France has accepted multiculturalism as a condition of social order; Britain has promoted multiculturalism through a broad spectrum of public policy since 1965; and in the United States, multicultural policies have been shaped by immigration law and antidiscrimination instruments that emerged from the civil rights movement. While French practice has been more multiculturalist than is generally acknowledged, the American instruments that have supported multicultural policy have also been stronger than is generally understood.
NOTES

1. Many of these differences are reflected in the annual report (since 2005) of the Migration Integration Policy Index. While the European Union (EU) 15 have an index of 60 (out of a possible 100), it varies between a low of 39 for Austria to a high of 88 for Sweden. The French index is 55; the British 63. 2. The legislation that authorizes the prohibition against the collection
of ethnic data is Loi no. 78-17 du 6 Janvier 1978 relative l'informatique,

auxfichierset aux liberts, modifled in 2004. The National Commission on Computers and Liberty lists seven criteria that could be used to measure "diversity." The decision of the Constitutional Council was elaborated in Le Monde (November 25, 2007). 3. This was one of a continuing series of meetings of the six interior ministers of the largest countries in Europe that have taken place outside of the formal EU context since 2003. 4. The phrase is a title of an essay written by John F. Kennedy in 1957 and published by the Anti-Defamation League in 1958. It was pubhshed commercially 1964. Kennedy's remarks echoed the main

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lines of President Harry Truman's 1953 introduction to the Report of the President's Commission on Immigration and Naturalization. 5. The quote is meant to apply to France, not the United States, but is cross-referenced to Glazer (1954:158-173). See Ireland (1994:10-11). 6. My thanks to Professor Peter Schuck (Yale/NYU) for pointing this out. See Chin (1996: 273). 7. See www.euractiv.com (2008). The European Pact on Immigration and Asylum (13440/08), was approved by the JHA Council on September 25 and adopted by the European Council. A statement was issued by the French Council of Ministers on November 12, 2008. 8. The most comprehensive example is Fix et al. (2005). The chapters focus on education; work and work supports for immigrant families; and civic engagement. 9. They are, for example, the only Muslim group in Europe in which a majority believes the attacks of September 11, 2001 were carried out by Arabs. See Pew (2006: 4). 10. For similar conclusions about convergence of citizenship policy, see Howard (2005: 714-717).
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