A checklist for position papers and public consultations

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If you want to persuade people in Brussels, you need to persuade them in writing. A lot of time and energy in Brussels goes into preparing written submissions.  Far less interest is given to whether all this work lands up persuading officials and politicians or changing policy.

There are some useful books on writing good public policy.  Catherine F. Smith and Richard N. Haas are worth reading.

My own checklist will be heresy for many.  Clear and concise writing is a lot harder to produce than complex and long writing. If you want to persuade officials or politicians, you’ll find clarity and brevity win. On this view, the evidence suggests I am in a small minority.

 

 

Position Paper  Checklist

 

  1. No more than two pages.
  2. A  clear and concise document, in plain English.
  3. Font 12. They need to read it, not to squint at the paper.
  4. Reader: Accessible to a non-expert.
  5. Put forward real solutions.
  6. Provide a brief summary of the key messages, research findings
  7. Outline key (1-5) policy implications/recommendations. Table real solutions.
  8. Links to further information: studies, websites.
  9. Provide contact details for more information.
  10. 1-2 side boxes with supporting material: graphs, compelling facts & figures, illustrative example, case study.
  11. Infographic. An infographic can often tell your story effectively
  12. Use headings. Don’t use bold or colour the text. A point won’t stand out because of it.
  13. Use short paragraphs.
  14. Be sober, objective and apolitical.
  15. Realise that real people may read this in the press.
  16. Put any added technical information in an Annex.
  17. Be timely. You want it to persuade people to take a decision in your favour, not leave a historical record that you turned up late in the game,

 

 

 

 

 

Responding to a Public Consultation – Checklist

 

The European Commission runs many public consultations.  They give you a good chance to make your case in writing and influence policymaking.

  1. Prepare the evidence you need to support your case in advance.
  2. Prepare your submission in advance. The questions that are asked are listed in the Better Regulation Handbook (link,p.75). Preparing the likely answers helps make sure you are not pushed for time.
  3. The key issues to be considered include:
  • The problem to be tackled
  • The issue of subsidiarity and the EU dimension to the problem
  • The available policy options
  • When modifying existing interventions, the scope for efficiency improvement (regulatory cost reduction) and simplification measures not affecting the achievement of objectives
  • The impacts of the policy options.
  • Effectiveness of the intervention
  • The efficiency of the intervention in relation to resources used (including the existence of unnecessary costs and legal complexities from the point of view of the achievement of the objectives);
  • The relevance of the intervention in relation to the identified needs/problem it aims to address
  • Coherence of the intervention with other interventions which share common objectives;
  • The EU added value resulting from the intervention compared to what could be achieved by Member State action only.

 

  1. Respond to the public consultation. Don’t sit it out. You need to put your concerns on the record.
  2. Bring new insights, views and solutions to the table.
  3. Support your case by bringing evidence to the table. The evidence can be real-life examples, anecdotes, studies, and data.
  4. Avoid bland statements, posturing, and few/no concrete examples.
  5. Highlight unintended and second-order consequences.
  6. Use simple and precise language and avoid jargon.
  7. If the public consultation does not raise a question you want to answer, you can. You are not bound to follow the questionnaire blindly.
  8. Bring alternative solutions to the table. This is a fact-finding exercise.
  9. Put your evidence on the public record. If you ask for the information to be treated confidentially, it is likely to be given less weight.
  10. Avoid politics and partisanship from your submission.
  11. Be polite in your input.
  12. Be sure about your facts. There is no better way to discredit your case.
  13. Note the limitations under which the Commission act. If the Commission is dealing with secondary legislation, the Commission’s margin for manoeuvre is limited.