A Mechanistic Approach for Preparing Position Papers

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A lot of time and resources are spent preparing position papers in Brussels.
The process of preparing a position paper can be time-consuming and difficult. Too many internal meetings, producing angst and headaches. Often the final document does not deliver on its goal: persuading decision makers to take on board your position.
It does not have to be this way.
A Mechanistic Approach 
This is my mechanical approach to developing powerful position papers. I don’t think it is the only way or the best way. It is the way that I find reduces a lot of time and pain out the process of creating a position paper and tends to make the final product more persuasive. I’d like to hear of better ways. See it as a Standard Operation Procedure (SOP) that can be tweaked and improved.
This should work for large and small organisations, both for and not-for-profit, companies, trade associations, coalitions and NGOs. It is designed for organisations that want to influence EU public policy-making.
I have sought to remove any drama from preparing position papers. It can be a smooth exercise, following some clear steps. This process removes most, if not all, of the toing and froing between groups involved in developing the position paper.
1. Some Basic Principles
These are some simple points that guide my approach:
  1. You write to be understood by the reader.
  2. Your reader is a specific official or politician or group of officials or politicians. You can identify them in your mind’s eye or, even better, stick a picture of them on your office wall.
  3. You write to positively influences an aspect of public policy making, e.g. a proposed law or regulation, a policy decision, or a political outcome.
  4. Good writing reflects clear thinking. Your writing will reflect clear and coherent public policy thinking and put forward credible and workable public policy solutions.
  5. You have a credible and persuasive position that you are prepared and able to make public on time.
I don’t think position papers should be:
  1. An exercise of internal validation. If you just want to produce your internal views on a proposal, you don’t need to go through this. There are more effective means of influencing public policy making than a position paper.
  2. Recitations of statements of belief. If you want to write out your version of the catechism, you need to realise that the reader is at best an agnostic and more likely an atheist. Your words will fall on fallow ground.
  3. An evidence-free zone. If you don’t have credible and objective evidence to bring to the table, you may want to sit this out. If your experts remind people of Dr Erhardt Von Grupten Mundt (from Thank you for Smoking), who contends that gravity does not exist, you will harm your case.
  4. You need to bring solutions to the table. Your reader is looking for a workable solution. It is best to provide it to them. Provide more details in an Annex of how your solution is the most effective. Make sure your evidence or messenger does not come across as a proverbial climate change denier. If you do, you will be shut out from all polite public policy society.
  5. It is not a moment for the weeping or gnashing of teeth in public. Keep that for private sessions.
2. What should your position paper look like 
This is what I have found to work well:
  1. Use Font 12, black text on a white page. Many of your intended readers will strain to read anything smaller.
  2. Have a clear heading. For example, a response to the Public Consultation title or the title of the proposal.
  3. Use Bold for Headings. Avoid random bolding of text.
  4. An ideal is one A4 page. That is around 400 to 500 words. 5 officials working on legislation identified that as the ideal length.
  5. How many points should you have in the position paper? An ideal number is one main point. It should be no more than 3-5 points. The reader won’t take them on board.
  6. The writing is clear and concise. Plain English is a good way to go. There is some good software you can use to check.
  7. Use short sentences. Get to the point.
  8. Deal with an issue in one paragraph. The paragraph will contain sentences dealing with:
    1. The core point your want to address
    2. Outline your reasons and reasoning to support your point
    3. Provide the objective evidence to support your view
    4. If useful, and it often is,  an appropriate analogy or metaphor to assist in the reader’s understanding.
    5. Your preferred public policy approach/ solution.
  9. The evidence can be objective studies, data, and even anecdotal evidence.
  10. If there are weak points in your position/ evidence, acknowledge them, and provide reasons and reasoning to distinguish your position.
  11. Use visual cues to help the reader, like charts, diagrams and infographics. A good image is often more persuasive than your words.
  12. Use Annex(s) when needed. You can provide legislative language, relevant data, studies, and technical or scientific evidence.
  13. Add the name and email of the person responsible for the position paper. People may have questions about it. Position papers are public.
  14. I’d recommend getting a good visual designer to tidy up the position paper.
 A good rule of thumb to test your position paper is:  Can your intended reader understand your paper after one read-through on a Friday at 7 pm and prepare a response? Will your intended reader understand it and see it as a fair position, even if they don’t agree with it? If the reader does, you have hit the baseline.
I’d recommend your position paper not reflect the points below:
  1. No clear point of view or having no point of view at all.
  2. Sentences of 300 words, hidden in a 30-page document.
  3.  Needless filler words.
  4. No headings to guide the reader through your position.
  5. Font 11 or lower in hard-to-read text. If you want to get more words onto a page by making the text smaller, you ensure it is not read.
  6. Random bolding of text used with neither rhyme nor reason. It seems popular.
  7. The use of archaic and technical language that the reader won’t understand. If you want to use Latin, go to a Latin Mass.
  8. No name and email contact details for people to follow up with questions.
  9. Presenting no objective evidence to support your case, or worse, alluding to it but providing no real-life evidence.
  10. Bundling up position, evidence, and legislative language, all in one long document, with no division between the sections.
You can use these two sets of points as a checklist for reviewing the draft position paper.
3. The Process to  Prepare the Position Paper
I divide the process of preparing a position paper into six steps. The steps are distinct. This helps ensure that scarce people and resources are not stuck in needless meetings and delays.
The process involves a few people:
The Issue Lead – is the person who steers the position paper through your organisation’s adoption of the position paper.
The Drafter –  is the person who gets to write up the position paper into a clear, persuasive and powerful document. They stay out of the preparation of the positions.
Issue Experts – are the group of experts who provide the organisation’s position and evidence to support the position.
Getting involved is not for the faint-hearted. It takes a real commitment of time, resources and expertise. It is not a place for observers.
  1. Step 1. Planning
Here are some simple questions you need to  have the answer for at the very start:
    1. How long do you have to prepare for the position? You don’t want to adopt your position just as the Parliament and the Council come to a first reading agreement.
    2. Why are you preparing a position paper: to influence a proposal going through public consultation, drafting, or legislative adoption; put your organisation’s views down on paper to influence future policy dialogue? You need to be very clear about this.
    3. Who are the key people delivering on the project: Identify the Issue lead, the Drafter, and the Issue experts. This is a lot of work to turn around in a short period. There is no space for hangers-on and pedestrian observers. Do they have the time to work on this?
    4. Signing off: Who needs to sign off the drafts and final positions before it is made public
    5. Who is the intended audience? – Create an image of the official/politician in your mind’s eye or even a picture of them. What do they want to know? Have you spoken with them to find out what is really driving the issue?
    6. The issue lead should keep excellent records of all the meetings and feedback. You don’t want to find out that just before the position paper is published, someone’s view was not taken into account.
The issue lead will prepare a short note answering these questions.
Step 2: Developing the Case
    1. The Issue lead prepares a summary note of the issue: existing positions, why the position paper needs to be prepared, e.g. a response to legislative proposals, and the questions that need to be answered.
    2. The Issue team meet. They will have prepared and pre-read the summary note of the issue and any supporting material, e.g. public consultation from the Commission. In advance of the meeting, a timetable for the provisional work plan, no later than 48 hours before, each expert will send their key points and supporting evidence (data, studies, anecdotal examples) for that point. When the group meets, they will agree: on the provisional timetable, the main point they want to make in the position paper, the supporting point(s) they want to make in the position paper, and their preferred public policy response/solution. For each of the points. they’ll provide evidence to support those points. The Issue Lead will circulate early the next day a summary note detailing: the agreed timetable, any agreed main points, preferred policy response/solution, and points they want to make.
    3. They will develop a chart summarising the draft main points they want to make, divided by for example:
          1. Issue 1: Point of View. Reasoning. Evidence Source. Solution.
          2. Issue 2: Point of View: Reasoning, Evidence Source. Solution.
          3. Issue 3: Point of View: Reasoning. Evidence to be found. The solution to be found.
          4. Issue 5: No clear Point of View
    4. The Issue Lead and Experts consolidate the material and evidence for Issues 1-5.
    5. The Issue Lead prepares a draft position paper with the material that’s been provided. The issue lead can divide the points to be made into want to make the following groups:
        1. Points with evidence and a solution
        2. Points with evidence and no solution
        3. Points with no evidence and no solution
        4. Annexes for supporting legislative language, studies, data, scientific evidence
        5. An Annex for supporting charts, visuals and infographics to support the position paper
    6. Experts meet. Issue Lead sends a week before the meeting. Experts pre-read all material. Experts need to confirm all points 1. For Points with no solution or evidence and no solution, they need to provide the evidence or decide to park those points. Points with no evidence should be put in an Annex.
    7. Only once the experts have approved the draft working document for the points to be raised can it go to the drafting stage.
Step 3: Drafting the case
    1. The draft position paper should be handed over to someone outside the immediate circle of the issue lead or experts. Few technical/issue experts can write for non-expert audiences.
    2. Ideally, the drafter is someone who can write plain English, understands what the intended reader needs to know, and has real experience in drafting clear policy position papers. I realise that is a small group.
    3. The drafter needs to set aside around three days straight to take what has been written down and convert it into words that the intended audience will understand. The drafter’s role is to convert the text into a clear and persuasive 1-page position paper. I don’t think there is any way around this. It means dropping the other commitments. It is best to get it done in a short burst. Don’t leave the exercise hanging around.
    4. The drafter and the issue lead should sit down at the start and have the issue, and draft text explained. Record this meeting to play back any explanations. Otter.ai is a useful tool for this.
    5. Once the focused drafting session is finished, the drafter and issue lead should sit down and review the text. The review should focus on:
      1. Which points/ argumentation are not persuasive or are weak?
      2. What points are strong and persuasive?
      3. Check if what is being asked for is legal. Are you asking for the Treaty to be changed?
      4. Check if what is being asked for is politically credible. If you are speaking only to one political group that doesn’t have the votes, and by accident or design, you have entered the political mad hatter’s world.
      5. Check if what is being asked for comes across as an unreformed climate change denier. I call this the bonkers test.
      6. Check if what is being asked for is what your organisation is mandated to ask for. Issue experts can often go rogue and ignore the request.
      7. It can be useful for a good reviewer to go through the text one final time.
Step 3: Sign off by the experts
    1. After any changes are made, the text is sent to the Issue Experts to review.
    2. The Issue Experts need to check for factual errors, technical errors, or misrepresentations of positions. It is not the time to re-open positions they agreed to in Step 2.
    3. The Issue experts should confirm all supporting evidence points. These should all be documented (study, page, paragraph). If they can’t provide the evidence, consider dropping the point.
    4. If there are points that don’t have real evidence, the group needs to make a choice. Do you include the point with no evidence and risk the rest of the position being weakened, or leave it in. Friends in the Commission have shown me wonderful examples of long papers claiming problems about an area without mentioning one specific  real example. Unsurprisingly, those lengthy documents were read and ignored.
    5.  For these points, You can drop it, put it in, or put in an  Annex with the heading “My Statement of Faith – This is What I Believe, and I Don’t Think Evidence Matters”. The only challenge is that audience is going to be at best agnostics and, more likely, atheists.
    6. Issue experts must not get involved in editing. Few technical experts are good editors. And, given the various linguistic traditions of Europe, even fewer are good at writing plain English.
Step 4: Internal Sign off
  1. All organisations have an internal sign-off procedure. Follow them.
  2. The procedures are necessary. They help stop bonkers positions going out the door.
  3. Consider that what you write will be read, and if it can be unfairly misrepresented, it will be.
Step 5: Getting it out the door
  1. Publish it and make it available. You did not do all this work to sit in a filing cabinet or online.
  2. Send it to the people whom you want to read your position.
  3. Go and see the key decision makers and influencers. What do they think? Do they buy into what you are proposing?
  4. Is it getting positive coverage in the opinion-forming media?

Step 6: Lessons Learned
  1. Report back. Has the position paper landed?  Are your positions and solutions being co-opted? If yes, great news.
  2. If it has fallen flat, find out why.
  3. Produce a short lessons learned report in the whole exercise. What went well, not so well, and how many hours/resources were spent?
  4. Ask yourself, “If I had to do this again today, what would I do differently?”
  5. Provide the Lessons Learned Report to your organisation’s leadership, the issue expert team, and drafter, and keep it filled away so others can use it when they need to go through a similar exercise.