The Transformation of Language Regimes and Citizenship Regimes in France and Germany: a comparative approach

Transcription

1 IPSA 24 th World Congress of Political Science July, , Poznan, Poland. The Transformation of Language Regimes and Citizenship Regimes in France and Germany: a comparative approach Núria Garcia, CEE / Sciences Po nuria.garcia@sciencespo.fr This paper seeks to investigate to what extent differences and similarities in French and German language regimes are linked to specific citizenship regimes. In existing literature on citizenship, stressing long-term continuity, both countries have often been opposed as idealtypes of civic and ethno-cultural conceptions of nationhood and citizenship. This dichotomy between civic and ethnic conceptions of citizenship has since been nuanced as Manichean myth (Brubaker 1999). Recent scholarship on citizenship regimes has indeed highlighted the changing nature of citizenship, showing how this institution is governed and evolves with the ideas and practices of the time (Jenson, 2007). In the same way, a restrictive understanding of language regimes as limited to official language regulations has led researchers to consider France and Germany as almost perfect exemplifications of monolingual states. A more comprehensive understanding of the notion of language regime, as including language practices and conceptions of language and language use as projected through state policies and as acted upon by language users (Sonntag & Cardinal, 2015, 6) reveals however significant differences between the two countries. Adopting a long-term neo-institutionalist approach, drawing on a variety of empirical material, this paper investigates to what extent language regimes and citizenship regimes evolve jointly. I will argue that distinct conceptions of citizenship explain differences in the shift from a monolingual to a multilingual language regime between the two countries, notably in regard to the degree of state intervention and the recognition of minority language rights. Literature review on citizenship regimes and language regimes In the political science literature, the politics and policies of language have for a long time been studied primarily through the lens of theories of nationalism (Anderson 1983; Gellner 1983; Hobsbawm 1990). For modernist authors, the linguistically homogeneous, monolingual 1

2 nation-state represents the outcome of the rationalization process entailed by the industrial revolution and economic modernization. Recent developments such as migration processes and the regionalist revival have led to question the linearity of this process and contributed to a renewed saliency of the language question in relation with cultural and minority rights in a number of European countries. The concept of language regimes allows to capture that states act upon language use through public policies and that the policies regulating and recognizing different languages may change over time and be adapted to a shifting political and social context. Selma Sonntag and Linda Cardinal define language regimes as language practices as well as conceptions of language and language use as projected through state policies and as acted upon by language users (Sonntag and Cardinal 2015, 5). From a of historical-institutionalist perspective, these language regimes can be analyzed as linked to specific state traditions and shaped by past policy choices operated at during the process of nation-building. By recognizing one (or more) language(s) over all other languages, language regimes lead moreover to institutionalizing the distribution of linguistic powers (Liu 2015, 13) that remains open to challenge if power constellations shift. In the European nation-building process, the establishment of a given language regime has been concomitant with the institutionalization of citizenship or a specific citizenship regime. National citizenship can be defined as that distinctively modern institution through which every state constitutes and perpetually reconstitutes itself as an association of citizens, publicly identifies a set of persons as its members, and residually classifies everyone else in the world as a non-citizen, an alien (Brubaker 1992, xi). The concept of citizenship regime refers to the idea that this institution is governed by the state through a series of laws, policies and regulations in different policy sectors. Consequently, citizenship regimes can be altered and adapted to the specific social and political context and evolve over time. Various scholars of citizenship studies have emphasized that a comprehensive analysis of citizenship needs to address the different dimensions it contains: Rainer Bauböck thus distinguishes between citizenship as right, citizenship as membership, and citizenship as practice (Bauböck 2001). In a similar vein, Christian Joppke differentiates between citizenship as status, as rights and as identity (Joppke 2007). The concept of citizenship regime defined by Jane Jenson is even more comprising and includes not only the dimensions of rights and duties, definitions of membership and governance arrangements but also the dimension responsibility mix, which refers to the role of the state provision of producing equality between citizens (Jenson 2007). 2

3 While the link between the establishment of national citizenship and the implementation of a monolingual language regime in the European nation-building processes has been emphasized by different scholars of nationalism, the link between the contemporary transformations of both language and citizenship regimes has hardly been addressed in the existing literature. Focusing on the cases of France and Gemany, constructed as most-similar case comparison, I will show how despite important similarities between the two countries in regard to the importance of language in the institutionalization of citizenship, differences in the countries citizenship regime and linked to the specific nation- and state-building trajectories account for variations in the implementation of the common language regime shift from monolingualism to multilingualism observed in the two countries. Building on a theoretical framework inspired by historical neo-institutionalism, both language and citizenship will be analyzed as the object of governance, and consequently as subject to change and evolution in regard to the political and institutional context. Such a framework implies adopting a methodology of process-tracing (Collier 2011; Mahoney 2012) and focusing the analysis on moments of critical juncture where the existing language and citizenship regimes are being redefined. Critical junctures can be defined as relatively short periods of time during which there is a substantially heightened probability that agents choices will affect the outcome of interest (Capoccia and Kelemen 2007, 348). Data sources used include both original empirical data collected in the two countries (i.e. policy documents, expert interviews, press articles) as well as an analysis of existing literature on language policy and state building on the two cases. A first section shows how the implementation of a monolingual language regime is concomitant with the institutionalization of citizenship during the period of nation-state building in the two countries. A comparison of the historical trajectories of the two countries reveals how in both cases the objective pursued is to make the boundaries of language, the political space of the state and of national identity become congruent. A second section analyzes how processes of transnationalization lead to a double shift from a monolingual to a multilingual language regime and from a congruent to a disaggregated citizenship regime between the 19 th and the 20 th century. A last section explains how differences in the citizenship regimes account for variations in the implementation of this language regime shift between France and Germany, notably regarding the degree of state intervention and the recognition of minority language rights. 3

4 The role of language in the emergence of citizenship in France and Germany: a most similar cases comparison Language played a central role in the emergence of citizenship in both France and Germany. Although both countries have been categorized by Stein Rokkan as victorious centers and characterized by the early consolidation of a territorial language, variations in the timing of state- and nation-building trajectories between the two countries account for differences in the mechanisms leading to linguistic homogenization: in France, the emergence of a linguistic center was the consequence of early state formation inside a territory with marked cultural and linguistic differences. Germany on the other hand was unified culturally before being consolidated as a political center, with linguistic homogenization resulting from elite interactions within a decentralized city-network. The imperial heritage is characterized by a fragmentation between multiple centers and at the same time a certain degree of homogeneity of the population in the heart of the territory (Rokkan et al. 1999, ). Characteristics of nation-state-building processes in France and Germany Structure of the city-network Ethno-linguistic homogeneity Institutional structure State-building period Particularisms France monocephalic medium unitary medieval Breton, Flemish, Alsatian, Corsican, Occitan, Catalan. Germany polycephalic high federal 19 th century, division in the 20 th c. Frisian minority, Bavarian particularism. Source: table excerpted from S. Rokkan (Rokkan et al. 1999, 220). Nevertheless, in both cases it is only with the introduction of a system of compulsory exoeducation (Gellner 1983) at the end of the 19 th century that the national language is conveyed to the mass of citizens. Even in France where the early emergence of a political center has led to make French the official language on the whole territory at the beginning of the 16 th century, official statistics show that in 1863 more than a fifth of the population does not speak the national language (Weber 1976, ). Differences between the French and German cases should hence not be exaggerated, as in both cases political, social and cultural dynamics are closely intertwined (Baggioni 1997, 235). 4

5 The case of France: state-construction precedes linguistic and cultural unification In the case of France, state-building processes are paramount to the linguistic and cultural unification of the nation. The successive elites controlling the central state i.e. the Royal Monarchy, the Revolutionaries, the July Monarchy, and the governments of the Third Republic implement a strong-willed language policy leading gradually to a congruence between linguistic, national and territorial boundaries. Despite the strong continuity in the pursuit of linguistic unification, the different regimes and periods are characterized by specific dynamics. The 1539 ordinance of Villers-Cotterêts through with the king François 1 st imposes the use of the French language in all public deeds is often considered as the first step of language homogenization. While the politics of centralization of the monarchic state has undoubtedly contributed to the destruction of peripheral cultures and languages, the language policy of the Ancien Régime cannot be directly compared to that of the revolutionaries and republicans, which are political regimes based on legitimacy by the people and citizens political participation. De Certeau, Julia and Revel thus underline that under the Ancien Régime it was out of question to francize the masses, who inside a strictly hierarchized society without school policies, do not have access to written culture anyway; the objective was simply to rally elites through eliminating cultural particularisms which could underpin autonomists movements harmful to centralization (Certeau, Julia, and Revel 1975, 9 10, my translation). It is only with the transition from a government of the king s subjects to a government for and by citizens that the question of linguistic unification and the policies implemented to achieve it change in nature. In order to foster popular support for the new political regime a double political education was necessary: on the one hand, explaining the sense of the new laws to the rural dwellers in a language familiar to them namely through translation ; on the other hand, developing a policy of public education (Certeau, Julia, and Revel 1975, 10 my translation). At an initial stage, in 1790, the revolutionaries implement a policy of translation in order to publish the decisions of the National Assembly in all the idioms spoken in the different parts of the French territory 1. It is only in 1793 that one observes a policy shift and that regional languages start to be seen as the expression of the counter-revolution, as illustrated by Barère s famous quote of January 1794 according to which federalism and superstition speak low Breton, emigration and hatred of the Republic speak German; the 1 Decision of the National Assembly on January 14 th 1790 (Brunot 1967, 9:25). 5

6 counter-revolution speaks Italian and fanaticism speaks Basque (Certeau, Julia, and Revel 1975, my translation). Following Barère s report, the Convention adopts on January 27 th 1794 a decree foreseeing the nomination of a teacher in each municipality where the inhabitants speak a foreign idiom (1975, 11 my translation). Pierre Encrevé underlines that from the beginning, French language ideology is built around the link between the Republic, school and the imposition of national monolingualism (Encrevé 2002, 127). The Report on the necessity and the means to destroy patois and to universalize the use of the French language presented to the Convention by Grégoire is in line with this republican ideology of monolingualism, according to which in a Republic, one and indivisible, citizens may use exclusively the language of freedom (Encrevé 2002, 129). This policy of linguistic homogenization towards the inside is closely linked to the formation of boundaries towards the outside: language fills and circumcises the political place (Certeau, Julia, and Revel 1975, 164). The establishment of French citizenship and that of a monolingual language regime are thus closely linked and characterized by a demarcation towards the outside and a folklorization of difference (Certeau, Julia, and Revel 1975, 167) at the inside. The language ideology according to which not only the state must be monolingual, but also each citizen (Encrevé 2002, 131) elaborated during the period of the Revolution is pursued under the Third Republic. While the education measures of the July Monarchy and the Second Empire and notably the 1833 Guizot law and the 1867 Duruy law contributed to the extension of public education, it is the Ferry laws in the 1880s, making primary schools, free, secular and compulsory, which represent a turning point in the teaching of the national language to all citizens. According to official education statistics, in 1863, more than 7,5 million people i.e. a fifth of the population did not speak French. Considering that the real figure was probably even higher, Eugen Weber underlines that the government of the Third Republic found a France where French was a foreign language for half the citizens (Weber 1976, 70). While the education policies of the Third Republic have led to a stigmatization of regional and local languages and patois, different scholars have emphasized the limits of schools actual capacity to implement the linguistic homogenization decided on the government level (Chanet 1996, ). Teachers weak knowledge of the French language they were supposed to teach and the counter-productive character of certain measures led to a gap between formal decisions and their implementation. More largely, the linguistic unification of France is not a purely top-down phenomenon, but it is also the result of individual decisions to invest in the learning of the new national language. The diffusion of 6

7 French among the population was due less to the persecution of patois than to the peasants growing appreciation of the usefulness of a less parochial language and of the skills learned in the schools (Weber 1976, 314). In the French case, characterized by the early formation of a political center and an important degree of language heterogeneity, the implementation of language education policies conveying the national language to all citizens is an instrument of implementing a republican citizenship regime, linked to a unitary and homogeneous state. The fact that the Revolutionaries initially resorted to translation before opting for language homogenization measures shows that the latter were only one among other available policy options. The monolingual language regime is thus not merely chosen for functional reasons and the imperative of ensuring communication between the state and its citizens, but it reflects a certain ideology of citizenship conflating the ideal of equality with that of homogeneity and a unitary state structure. The case of Germany : a common language as basis for state-building The case of Germany is characterized on the other hand by a polycephalous structure and the absence of a single political center or central state. Unlike France, Germany has known an early development of literacy among the population as a consequence of Protestantism and religious reform. According to Daniel Baggioni, this high literacy rate partly explains the fact that German speakers, unified by the knowledge, even passive, of a common standard, and despite the absence of a truly unitary state structure, feel that they belong to a common culture (Baggioni 1997, 218, my translation). While in the German case linguistic unification largely predates political unity, it is only with the creation of the German Empire in 1871 that German becomes the national language of a unitary nation-state (Breuilly 1993, 1) and becomes the object of language policy. As in the French case, the establishment of a monolingual language regime is closely linked to the creation of a nation-state and the establishment of citizenship boundaries. The emergence of nationalist movement in German speaking countries at the beginning of the 19 th century calling for the unification of all those speaking the German language is often analyzed as a reaction to the French Revolution and the Napoleonic wars (Miard-Delacroix 2004, 68). Jürgen Trabant underlines that German identity formation takes place precisely in the confrontation with France, also in the field of language thought (Trabant 2002, 16, my 7

8 translation). In a context marked by political fragmentation and the absence of fixed territorial borders, the image of the Kulturnation i.e. a community bound by cultural ties and notably the German language develops as substitute to the Germanic Holy Roman Empire of the 18 th century after its fragmentation (Lepsius 1982, 19). The creation of the German Empire in 1871 leads to the establishment of the boundaries of the German state s political space. However these political boundaries do not coincide with the linguistic boundaries, as the German speaking territories of the Austro-Hungarian Empire are not part of this German nation-state. The emergence of the distinction between deutsch (German) and deutschsprachig (Germanspeaking) illustrates the decline of the concept of Kulturnation (cultural nation) in regard to that of Staatsnation (political nation, nation-state) (Lepsius 1982, 20). With the creation of the Empire, the teaching of the German language becomes one of the central elements contributing to the nationalization of the German education system. At the same time, the choice of language as criteria or indicator for individuals nationality in the censuses organized by the Prussian administration leads to a politicization of the national language (Labbé 2008; Haarmann 1993, 260). Germanization policies implemented at the end of the 19 th century respond to a similar logic than those observed in France at the same period. However, the German Empire of 1871 is not confronted with the same linguistic heterogeneity of its population as the French Third Republic. The existence of a written German koinè since the 16 th -17 th centuries allows to bridge the differences between dialects and the division between low-german (niederdeutsch) and high German (oberdeutsch) (Trabant 2007, 69). In 1836 the pedagogue Adolf Diesterweg notes that pupils do not really need to learn German at school because they already speak it at home, or otherwise they only need to understand the not very significant (Quoted in Gogolin 2008, 32, my translation) deviations between the standard language their dialect. According to Prussian school statistics, in 1871 only 12,9 % of the pupils in elementary publics schools have a language other than German as their mother tongue. Polish-speaking pupils represent 85,5 % of these non-native German speakers. Pupils having other languages such as Danish, Lithuanian, Sorb, Moravian, Frisian or French as their mother-tongue represent less than 2 % of the total school population (Wenning 1996, 131). After the creation of the German Empire, this Polish-speaking population becomes a national minority inside a German nation-state and the target of an intense policy of Germanization, notably through the education system. The objective of the language education policies of this 8

9 period is to give another mother tongue to the people in order to realize the cultural unification of the territory according to one person one language one people one territory (Krüger-Potratz 1994, 93, my translation). In 1873, German is institutionalized as sole language of instruction through a decree (Oberpräsidialerlass). Two laws adopted in 1876 and 1877 make German the only official language and ban the use of Polish in the fields of justice and administration, thus putting an end to the bilingualism which existed since 1815 in the Polish territories of Prussia (Walkenhorst 2007, ). The anti-polish language policy is initially part of the Kulturkampf led by Bismarck against the Catholic Church, but linguistic homogenization policies continue until the end of the 1880s. School administrations implemented however certain language accommodation measures, limited most of the time to a given language group and a restricted territory at the end of the 19 th century. Some authors analyze these measures as part of the school administration s strategy of pitting different minorities against each other (Krüger-Potratz 2010, 354). In Germany, the implementation of a monolingual citizenship regime is realized through a reclassification of German as national language and accompanied by a Germanization policy of minorities, rather than through a state-driven top down linguistic unification of the population as in France. Norbert Wenning underlines the paradoxical role played by language in the nation-state-building-process in Germany: with the elevation of German as mother tongue and the imposition of a corresponding consciousness in German live the Germans and they all speak high German a prerequisite for the nation a unified language is only (largely) created, after it had been considered a given for a long time. The nation-state legitimizes itself through great effort it creates something on which it was actually founded (Wenning 1996, 134, my translation). *** In both France and Germany the implementation of a monolingual language regime is concomitant with the institutionalization of citizenship during the period of nation-state building. While the trajectories followed by France and Germany are characterized by important differences, in both cases the objective pursued by the implementation of a monolingual language regime is to realize a congruence between the boundaries of language, the political space of the state and the boundaries of national identity. Monolingualism is first of all tied to the idea of democracy and seen as means to ensure communication between the citizens of various parts of the country on the one hand and between citizens, the government 9

10 and the administration on the other hand. Second, the implementation of a monolingual language regime is a means to ensure citizens mobility inside a nationalizing labor market. The institutionalization of a national language is more largely part of a boundary-making process allowing to distinguish citizens from non-citizens. Finally, the implementation of a monolingual language regime entails the recognition of cultural rights to a majority and conversely, the non-recognition of minorities cultural and linguistic rights. Language thus intervenes in all four dimensions of citizenship regimes defined by Jane Jenson. The role of language in the different dimensions of the 19 th century citizenship regime Responsibility mix Rights and duties Governance arrangements Definition of membership The state takes in charge the transmission of the national language to ensure the mobility of labor inside a national market. The institutionalization of a national language in administration and education amounts to recognizing cultural rights to a majority. The implementation of a common language is chosen as means of the creation of a democratic public sphere. Language is mobilized as formal criteria defining the boundaries between citizens and non-citizens, and as means to foster ties of solidarity and belonging between citizens. In this perspective, the implementation of a monolingual language regime must be analyzed as one specific policy option that has been chosen against other available alternatives. This policy choice can be explained only through the prevalence of a specific conception of citizenship which is intrinsically linked to language, and which cannot be reduced to a purely communicational or identity dimension. In order to create a communication space, the option of translation, considered in the early years of the French Revolution, was a possible alternative. In the same way, other identity markers were available to define the boundaries of the body of citizenship. However, in both France and Germany governing elites have chosen the implementation of a national language. The implementation of a monolingual language regime can thus be analyzed as linked to a citizenship regime which contains a homogenizing vision. In the empirical reality, efforts to make all citizens monolingual go beyond the functional imperatives of creating a communication space: the objective was not only to add a 10

11 national lingua franca allowing to ensure the link between individuals different language repertoires, but also to ban the presence of other languages from education and the public sphere. In the case of France, language homogenization policies are directed primarily against regional languages or patois spoken by a significant share of French citizens. In Germany on the other hand, these policies mainly target foreign minorities, and notably Poles. While the implementation of language education policies in the national language paradoxically leads in a first step to generalized bilingualism among the population, with individuals continuing to speak their mother tongue alongside the national language, the objective pursued by these policies was to produce monolingual citizens in the new national language. Language regime and citizenship regime shift in Europe since the mid-20 th century This 19 th century citizenship regime and the corresponding monolingual language regime are increasingly challenged by different macro-sociological changes affecting the nation-states and the international environment since the beginning and the even more so after the middle of the 20 th century. These changes include among others the increased interdependence between national economies, advances in communication technologies, post-industrialism and the intensification of migration. Linked to processes of globalization and European integration, these dynamics of transnationalization contribute to the erosion of the congruence between social and political space which affects both citizenship regimes and language regimes: As a consequence, in many central areas of human activity, the borders of social transactions now lie beyond the borders of any nation-state, and yet the majority of political institutions and regulations aspire to function only within nation-states (Zürn and Leibfried 2005, 12). Regarding language regimes, these processes of transnationalization contribute to an increased importance or usefulness of foreign language skills for a greater number of citizens and lead to a progressive extension of foreign language education to all citizens in almost all European countries. This change can be interpreted as a common language regime shift from the ideal of monolingualism to that of multilingualism. Regarding citizenship regimes, dynamics of transnationalization lead to the dislocation of the idealtypical model of citizenship of the end of the 19 th century characterized according to Max Weber by unity of residency, administrative subjection, democratic participation and cultural membership (quoted in Benhabib 2002, 454). 11

12 Language regime shift: From monolingualism to multilingualism The policy objective of extending foreign language teaching to all pupils since the beginning of the 20 th century can be paralleled to the 19 th century education policies aiming to convey the national language to all citizens during the nation-building period. While the national education system has historically been instrumental for the linguistic unification of France and Germany and the spread of the national language over the whole territory, since the middle of the 20 th century the teaching of foreign languages to all citizens has become a central mission of this same education system. This change in policy objectives can be analysed as a language regime shift from the ideal of generalized monolingualism to generalized multilingualism. Under the effect of processes of social transnationalization, foreign language skills become directly useful in the daily lives of an increased share of citizens. Foreign language skills become a key resource for individuals integration in the new patterns of exchange and social and spatial mobility. According to Jürgen Gerhards multilingualism assumes an added importance under the conditions of transnationalization and Europeanization. Since the nation states usually speak different languages, trans border exchange is only made possible, or made considerably easier, when people have the necessary transnational language skills (Gerhards 2012, 48). In the same way as regional languages limited the circulation of their speakers inside the national markets emerging in the 19 th century, skills in only the national language now confine their speakers horizons of action to the boundaries of the nation-state. As Eric Hobsbawm puts it, to be monolingual is to be shackled, unless your local language happens to be a de facto world language (Hobsbawm 1990, 116). Consequently, individual multilingualism becomes a resource allowing to improve individuals chances of access to the most recognized universities and diplomas and to better professional career prospects. More largely this transnational linguistic capital (Gerhards 2012) increases the possibility of expanding and internationalizing one s network and social relations and to participate politically outside one s country of origin. Foreign language skills are thus an important factor allowing to distinguish between those who benefit from European integration through engaging in social communication at the European level, and those who do not because they do not travel or speak second languages, and they consume popular culture in the vernacular (Fligstein 2008, 5). 12

13 While foreign language skills in general become more and more important, not all language skills have the same value on the international market: geopolitical factors such as the increased dominance of the United States in international politics since World War I (Laponce 2001, 488) and individuals upward language learning choices contribute to make English a hyper-central language occupying a pivotal position inside the world language system (de Swaan 2001, 4 6). Philippe van Parijs thus qualifies English as global lingua franca in the sense of a language widely used for communication between people with different mother tongues, whether or not it enjoys an exclusive or privileged official status, and whether or not it has been from the start, or has gradually become, the native language of some of the linguistic communities it links together (van Parijs 2011, 9). Comparing the ratio between native speakers and secondary speakers of the world s most widely used languages, he shows that while Mandarin and Spanish outrank English in terms of native speakers, English has a much greater spreading power as second language. National language education policies have played an ambivalent role in this language regime shift: while these policies are in part a reaction to the increased predominance of English on the international level, they have at the same time contributed to create this same predominance. In de Swaan s and van Parijs models, the predominance of English is analyzed as the consequence of the sum of uncoordinated and unintentional individual choices. However, these individual choices are only made possible by a change in education policies and largely determined by the language offer, which exists inside the different education systems, and thus the result of policy choices. During a debate on the future European language regime, Abram de Swaan himself notes that first there was a de facto language policy which was an education policy in all the member states and which resulted in 80 % of youngsters learning English. [ ] It was a language policy that did not say its name (Bourdieu et al. 2001, 63, my translation). An overview of language education policies of the different EU member states allows to assess the empirical reality of this convergent language regime shift from monolingualism to multilingualism: while the specific timing and trajectory varies, at the beginning of the 21 st century, the learning of at least one foreign language is compulsory for all students in the European Union, with the exception of Ireland. Despite this convergence, the number of years during which this first foreign language is learnt and the existence or not of a compulsory second foreign language remain subject to variation between European countries. 13

14 Foreign language teaching in the EU member states in 2010/2011 Compulsory first foreign language Compulsory second foreign language Years of study first foreign language Years of study second foreign language France yes yes 9 2 Germany yes no 8 / Luxembourg yes yes 10 9 Belgium yes yes* Bulgaria yes yes 8 1 Czech Republic yes yes 7 1 Denmark yes no 7 / Estonia yes yes 9 6 Ireland no no / / Greece yes yes 7 5 Spain yes no 10 / Italy yes yes 10 3 Cyprus yes yes 6 4 Latvia yes yes 7 4 Lithuania yes yes 8 4 Hungary yes yes 9 2 Malta yes yes 11 5 Netherlands yes no flexible / Austria yes yes 9 1 Poland yes yes 9 3 Portugal yes yes 7 3 Romania yes yes 8 6 Slovenia yes yes 6 4 Slovakia yes yes 8 5 Finland yes yes 7 3 Sweden yes no 9 / United Kingdom yes** no 3 / Average EU27 8 3,7 * except in the Francophone community. ** except in Scotland. Source : Eurydice Key data on language teaching (Eurydice 2012). 14

15 Citizenship regime shift: from congruence to disaggregation Dynamics of transnationalization and regional integration have also led to a change in the 19 th century citizenship regime in Europe, which was characterized by a congruence between its different dimensions. According to Seyla Benhabib, contemporary developments within the European Union both reveal the disaggregation of various dimensions of citizenship and their continuing problematic coupling of cultural identity with political privileges. While throughout the EU a dissociation of cultural identity from the privileges of political citizenship can be observed for EU citizens, for third-country nationals the ties between identities and institutions, between national membership and democratic citizenship rights are reinforced (Benhabib 2002, 460). In the rights and duties dimension of citizenship regimes identified by Jane Jenson, processes of European integration have led to a decoupling between the space of political, civil and social rights: while political rights continue to be dependent on national citizenship, the creation of a European Union citizenship status has entailed the creation of a second stratum of political rights that goes beyond the boundaries of the nation-state. For instance, EU citizens have the right to vote in local and European elections in other EU member states of which they are not national citizens. Nevertheless, national citizenship continues to be crucial, as the rights attached to EU citizenship do not exist independently of national citizenship status from which they are derived. Social and civil rights have become even less dependent on national citizenship. Maurizio Ferrara thus underlines that the traditional link between rights and territory has become much looser: for most civic and social rights, the filtering role of nationality has been neutralized (Ferrera 2005, 207). At the same time the responsibility mix dimension remains primarily national. As since the 1970s policies of market building won over policies of market correcting (Hansen 2000, 144) the current EU treaties do not provide a legal basis for a comprehensive social policy and member state governments are reluctant to delegate competences in this field to the European level. According to Wolfgang Streeck, as far as the completion of the internal market is concerned, it does not matter that European citizenship has remained limited to freedom of movement and contract within the internal market (Streeck 1995, 413). As a consequence, state provisions at the national level remain central for ensuring citizens welfare and social rights. 15

16 In the governance arrangements dimension, a different kind of decoupling is visible: the European integration process leads to the emergence of a new political arena and the delegation of decision-making in certain policy fields to the European level, this level of government is not accompanied by the emergence of a corresponding public sphere. In other words, in the absence of a European demos or body of citizens, policies decided at the European level continue to rely on an indirect legitimacy from 27 separate demoi, through elections held in 27 member states. The institutional mechanisms giving access to the EU, civil society participation and public debates remain structured by national public spheres. The alternative governance arrangements to those of the standard model of liberal democracy (Jenson 2007, 62) developed by the EU have been contested as contributing to the democratic deficit and legitimacy problems of the EU. At the same time, the European integration process and more generally globalization significantly constrain national governments policy-making choices. All in all, these developments lead to a decoupling between the level at which citizens vote and express their preferences and the level at which decisions are made. Regarding the definition of membership dimension, the creation of a European citizenship status has given rise to a two tiered status of membership (Benhabib 2002, 461). As national citizenship gives access to EU citizenship, it grants rights not only inside the member state in question but also across the EU. At the same time, as EU citizenship does not have a distinct existence from national membership, the acquisition of national citizenship status remains the only means of access to membership in the European citizenship regime. The boundaries between citizens and non-citizens thus continue to be decided at the level of the different member states through citizenship and naturalization requirements. In the same way, the national level remains salient for individual s identity formation. While different survey based studies have shown that national and European identification are not mutually exclusive (Frognier and Duchesne 2002), but the percentage of citizens for whom Europe is the first or only focus of identity remains extremely low. In other words, if identity is conceived of as a multilevel set of attachments, Europe is now a part of it for the majority of its citizens. If, on the other hand, one clings to an exclusionary concept of identity, European attachment is still highly minoritarian (Kholi, quoted in Jenson 2007, 65). 16

17 *** Under the impact of processes of transnationalization affecting the different European countries, both language regimes and citizenship regimes have thus been subject to important changes since the moment of their institutionalization at the end of the 19 th century. The monolingual language regime corresponding to a citizenship regime characterized by the congruence of political, social and cultural space has been replaced by a multilingual language regime consistent with a disaggregated multilevel citizenship regime, where the various dimensions of citizenship do no longer coincide with the boundaries of the nationstate. This evolution raises the question of the link between change in language regimes and citizenship regimes: to what extent are they evolving jointly and as part of a self-reinforcing dynamic? In how far are mechanisms of path dependence in one field acting as an obstacle for changes in another field? End of the 19 th century Mid-20 th century onwards Citizenship regime Congruence Disaggregation / Multilevel Language regime Monolingualism Multilingualism Not all of the dimensions of citizenship regimes are equally affected by the shift towards multilingualism, which touches primarily upon the responsibility mix and in a more limited way on the rights and duties dimensions: the state thus takes in charge the transmission not only of the national language but also of foreign languages to all citizens. In parallel, more or less extensive cultural and linguistic rights are recognized to speakers of regional and minority languages, but these rights are generally not extended to migrants languages. The governance arrangement and the definition of membership dimensions remain tied to the national language: not only do national political spheres remain monolingual, but also access to European decisions is granted in the national language of citizens home country. While the absence of a common language on the European level is seen as an obstacle for the emergence of a European public sphere, the multilingual language regime of the European institutions does not require citizens to be multilingual. In the same way, the national language remains a key criterion for defining the boundaries between citizens and non-citizens and migrants lack of proficiency in the national language is perceived as problem of integration. 17

18 The role of language in the different dimensions of the 20 th century citizenship regime Responsibility mix Rights and duties Governance arrangements Definition of membership The state takes in charge the transmission of the national language and one or more foreign languages to all citizens. A variable and limited recognition of cultural and linguistic rights to national minorities, but not of migrants. National democratic spheres remain monolingual and citizens are granted access to European decisions in their national language. The national language remains a key criterion for defining the boundaries between citizens and non-citizens. Citizenship regimes as explanatory variable for differences in language regime change between France and Germany The common language regime shift from monolingualism to multilingualism observed in most European countries takes a specific form in each case. This section argues that the variations in language regime change observed between the French and German cases are linked to differences in the citizenship regimes of the two countries. However, not all of the dimensions of citizenship regime equally affect language regime change: while differences regarding the responsibility mix dimension account for the variable degree of state intervention in the achievement of multilingualism, and variations in the rights and duties dimension explain the differential recognition of minority and regional languages, the governance arrangement and the membership dimension only play a marginal role in the shift from monolingual to a multilingual language regime, or even act as an obstacle to this change. Differences regarding the responsibility mix dimension explain variable role of the state Variations in language regime change between France and Germany are visible first of all in the responsibility mix dimension: while in France the ideal of making all citizens become multilingual is the exclusive competence of the state, in Germany this same objective is to be reached through a joint effort of state run education policies, the market and individual initiative. This variation is the reflection of different conceptions of the role of the state vis-àvis civil society and the market in the provision of public goods and ensuring equality between citizens. At the same time, the differential degree of state intervention in the implementation of a language regime remains consistent with the differences observed during the establishment of a monolingual language regime at the end of the 19 th century described above: while in France monolingualism was enforced by the state on a linguistically 18

19 heterogeneous population, in Germany social interactions between civil society groups had led to linguistic homogenization of the population even before German was institutionalized as national language by the state. In France, the implementation of a monolingual language regime in the 19 th century operated through a top down mechanism with a central impetus coming from the state, which imposed French on the more or less reluctant citizens. The imposition of one official language was seen in French Republican thought as one of the means ensuring equality between citizens and often confused with the notion of homogeneity. This principle of equality remains important in the shift from a monolingual to a multilingual language regime and is invoked as one of the reasons why the state should play a central role in providing foreign language skills to all citizens. A national education inspector general thus qualifies the fact that all pupils in the education system have access to the learning of two foreign languages as peculiarity of the foreign language teaching system in France linked to the principle of equality between pupils of the different education tracks, including vocational training 2. All interviewed state actors underline the role model played by France in the implementation of the European Barcelona objectives of multilingualism adopted in 2002 by the European Council. An education official of the Directorate for European and International Relations underlines that France was one of the countries which implemented the most rapidly programs and a legislation imposing two foreign languages at school, for a long time 3. More generally, the vision according to which the state should play a central role in the realization of the objective of multilingualism is presented as corresponding the most closely to the Barcelona decision and as shared by a majority of European countries. This central role of the state is however not self-evident but it is linked to the responsibility mix dimension of the French citizenship regime: implementing a multilingual language regime is seen as part of the schools public service mission and delegating this mission to the private market or life-long learning initiatives is not considered a desirable option. Different teachers unions defend national diplomas awarded by public schools and recognizing of foreign language skills as means of ensuring equality between pupils and criticize private language certifications (SNES 2011). In the French citizenship regime, the state holds more largely a monopoly in the transmission of knowledge and education which is fundamentally 2 Interview with a National Education Inspector General of the Inspectorate s Coordination of European and International Affaires conducted in Paris on February 1, Interview with an education official from the Directorate for European and International Relations (DREIC) of the Ministry for Education, conducted in Paris on October 24,

20 different from the German situation: a comparative analysis of both education systems thus shows that the only learnt competences socially recognized in France are those realized in school, ( ) whereas in Germany school is one location of acquiring competences among others. Competences acquired through non-school practices are more easily valued and socially recognized, which positions school differently (Wallenhorst 2013, 177, my translation). In Germany the role of the state is less central in the realization of the objective of multilingualism, which is seen as a broader goal to be reached through a joint effort of the state, civil society actors and individual initiative. This policy orientation is clearly expressed by the Federal Ministry for Education and Research: language learning cannot be limited to the learning time spent inside the institutionalized education system: ( ) language learning is one of the substantial challenges facing society, education systems and the individual with the mission of lifelong learning (Bundesministerium für Bildung und Forschung 2001, my translation). The fact that Germany adopted the mother-tongue plus two Barcelona objectives is not seen as standing in contradiction with education policies providing competences in two foreign languages only to a minority of pupils: according to certain authors the idea of multilingualism is applied much more consistently in adult education than in the education system (Quetz 2010, 171, my translation). The inter-sectorial character of the objective of multilingualism is used as an argument by education officials at the level of the Länder to justify why only one foreign language is compulsory for all pupils: school programs for Brandenburg thus state that the development and the promotion of individual multilingualism are (hence) one of the important tasks of schools in the Land of Brandenburg, a comprehensive task for school and society (Ministerium für Bildung, Jugend und Sport des Landes Brandenburg 2008, 16, my translation). At the same time, substantial differences exist between the sixteen Länder: while language education policies in Brandenburg follow the minimum standards defined through the Standing Conference of the Ministers of Education and Cultural Affairs of the Länder (Kultusministerkonferenz), other Länder have a more strong-willed and pro-active language policy. In North-Rhine-Westphalia, the learning of a second foreign language has for instance been extended to pupils in the vocational track. According to the official in charge of foreign language education this measure is a conscious political decision and the Land is ready to support the costs as naturally, school cannot 20