With the Work Programme coming out on 11 February 2025, the mist of what it is going to be on the policy and regulatory agenda for the year ahead, and indeed the next five years ahead, will soon be lifted.
I’ve given a clear tracker checklist to see where your issue is on the EU agenda here.
I don’t think there is any reason why most people will be surprised that an issue they work on comes up in a legislative or regulatory proposal. There are exceptions. Some people suffer from amnesia. Others are stuck in internal meetings, and don’t have time to look outside and see what is happening. More than a few are afflicted with denialism.
What Can You Do On 11 February, 2025
So, what can you do when you read that your proposal is in the Work Programme for 2025.
I go through two simple steps.
First, I list the next actions and when to step in to influence the preparation of a proposal. And, more or less at the same time, and maybe if stretched, just after, work out and be clear what your position is.
If the item you wanted to be in is not, you can be patient and wait another year. If there is an item you did not want to be in, you can either deny the words on the page of the work programme, or follow the steps below.
Step 1: Next Actions
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Identify: The Task Force, Inter Service Steering Group(ISSG), and ISC (Cabinets)
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Look at the planning for the adoption. If you want to get an idea of the steps involved have a look at the case study for the adoption of the CLP Regulation here.
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Keep a track of the following events and meetings. The key windows of opportunity in bold.
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Decide entry
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Launch of studies
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Meetings of the ISSG
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Public Consultation
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Targeted Consultation Updates to the Expert group
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Check in with Cabinets
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Bilateral between the Services Upstream meeting of the RSB
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Submission of the Impact Assessment to the RSB
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Meeting of the RSB
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Exchange of Views of the College
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Launch of drafting of proposal
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Validation for launch of ISC
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Launch of ISC (10 days or shorter)
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Meeting of Chef de Fiche
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Meeting of HEBDO
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Meeting of Cabinet for adoption (note maybe an A Point)
When to Step In
As a rule of thumb, I’ve only met about two people over 27 years who are so persuasive to change a proposal on the spot. So, if you want to make an impact, you will need to step in about 3 weeks (at the latest) before one of the key decision points. They are indicated in bold. This gives time for your brilliant ideas to filter down and be taken up and persuade key decision makers and influencers in the Commission.
Step 2: The Cornerstone
But, before any of this, you need a persuasive position to put on the table.
You can, as many do, sit out the whole exercise, and wait until the Commission table their proposal. Then you have about 8 weeks to digest the Commission’s proposal, get your amendments ready, before the EP Committee and Council Working Group start firming up their positions. If you wait much longer, your ideas will miss the firming up of ideas in the Committee and Working Group.
There is one weakness in this approach. The Commission’s proposal often survives more or less in tact. If you don’t get what you want in the Commission’s proposal, you’ll be on an uphill struggle for the remainder of the legislative journey.
A Simple Technique that Works
This is a simple technique I stumbled across decades ago for getting clarity on your position.
Take the table below and fill it in.
List the Issues of Relevance to you in the proposal/Initiative
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What’s is the proposal on the table/likely proposal
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What’s your reaction to the proposal
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What’s your preferred solution to the issue
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What’s the evidence to support your position
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What does this look like when you put it down on paper
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Issue 1
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Issue 2
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Issue 3
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Issue 4
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Issue 5
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Let’s look at each step.
First list the issues of relevance to you. I like the number 5 because I think it is hard to keep more than 5 points in your head at one time, and having more than 5 priorities seems a lot. I have met many people who are able to have 30 priority issues. They are very smart. I’ve not worked out how they manage it.
After you have listed the issues that are of importance to you, list out what you know/believe the Commission are going to put forward. This is usually well signposted through the whole consultation process and through bilateral conversations. I don’t know many proposals when people were surprised at what had been tabled.
Then the hard work starts. I recommend locking yourself away for a few hours before embarking on the next step. Have a supply of good coffee and chocolate.
For each issue and policy/legislative proposal from the Commission, you list the following: your reaction/response, your preferred policy/legislative solution, and the evidence to support your position.
I recommend putting this all down on paper. Write it as basis for a script that you would use in meetings, reasoning for your amendments, and public response.
This seems to be a lot harder than you’d think.
You may find that the only reason you don’t like the proposal is that you don’t want any change because you don’t like change.
It helps to put down your preferred solution down on paper. You are going to be asked for it. You don’t want to make it up on the spot!
You may find that you have little or no evidence to support your position. Or you don’t want to put that evidence in the public domain. If you don’t, it is going to be regarded as lacking credibility.
The hardest and the most important step is to put it down on paper. This is essential. It is not just a practical step. Unless you have a photographic memory and the power of telepathy, the only way you can communicate your position is in writing, via: amendments and justifications, briefing documents, 1 pagers, and maybe a persuasive position paper.
But, the real benefit of putting this all down on paper is that a written position ahas a mystical power of doing one three things:
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Show that your position is understandable to no-one but you and your close inner circle, impenetrable to any of the key officials and politicians who will decide the political fate of the file.
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Shows that your position is self promoting, lacking substance, and is an exercise in profiteering, ego management, or delusion.
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In the cold light of day, show that your client/organization will be politically embarrassed and ridiculed for the ideas and solutions they are calling for.
Putting it down on ridiculed helps people more detached and senior in an organisation look at words and see if that is what they want to be associated with.
If you don’t have a solution to an issue, and don’t have credible evidence to support your position, and if you do, it looks politically insane, I’d remove it. I find this tends to remove the amount of issues you want to take forward.
Over 3 decades, I’ve seen copy from NGOs and industry that failed 1, 2, and 3, and often all 3 in combination. It is something you don’t want to do.
And, a golden rule, the earlier you start, and the more you are trusted by key decision makers, the more likely your solutions are going to be co-opted. If the first time you appear is a letter to the College of Commissioners on the day they meet for an A Point agenda item, you will be disappointed in the outcome.
If this all seems like too much hard work, maybe lobbying is not for you.