Modeling the Standard Brussels Position Paper

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Yesterday a friend asked me to look at a position paper to review from someone I don’t know. I thought it was the skeleton outline. I was assured this was the real deal. I cried for a bit. Some poor souls in the Commission, EP and Perm Reps were soon going to go through the same painful experience of reading nothingness that I just endured.
I went and read some more position papers by people I don’t know. They were more or less the same. I think someone has created an AI instruction to create these position papers.
The 5 position papers I used for the model below are not by any organisation or company that I know. They are from across sectors. The similarities are stunning.
If you want to send me your position paper for a public review I’ll be happy to.
I want to provide a model of the Standard Brussels Position Paper and then provide a short gap analysis and sketch out what to put in a good position paper.
Why write a good position paper
Good position papers are important. They serve as the best means of communicating public policy solutions to many people quickly.
I know of one organisation who turned around the quality of their public policy inputs. What once came across evidence free, unclear and melodramatic is now used as the reference memo for reform. Now they are listened to and their ideas are taken on board.
Putting your ideas down on paper also helps you identify if you have a strong case. A position paper is not meant to be a group regression therapy session that simply channels the cries for help into a external position paper. If your position paper has 10 points of which only 2 are strong, delete 8, and leave 2. If you don’t, the 8 unhinged, emotional and evidence free, will drown the two good ideas that would have flourished.
Bundling one or two good points in a hay stack of gibberish will make it harder for your allies in the Commission, EP or Council to support you. As soon as anyone else reads what you really want they will run away from you.
A Standard  Model for The Standard Brussels Position Paper
  1. An uplifting Title
  1. We welcome the initiative/proposal/revision.
  1. We support the idea of the initiative/proposal/revision.
  1. Did you know, we are very regulated.
  1. Did you know, outside Europe, things are less regulated.
  1. We are very important.
  1. We love Europe
  1. [Selectively] pick from an evaluation on what changes you want, or just pick some or all of the points below:
    1. We want things that are Simpler
    2. We went less Less regulatory/legislative Burdens
    3. We want rules that Promote Innovation
    4. We want rules that Promote Competitiveness
    5. We need certainty.
    6. We want less reporting
    7. The measures that the law has required to be taken have delivered on their stated goals, but that makes things difficult for us.
    8. The law led to everyone leaving Europe
    9. Mention ‘unintended consequences’.
    10. Mention China or somewhere else as easier to do business in.
    11. The law does not recogise our ‘sector specific’/’company specific’ situation
    12. Administrative burdens are heavy.
    13. There is no level playing field.
    14. Science based approach not followed.
    15. Europe’s approach is not used outside Europe.
    16. You need to re-do the Impact Assessment.
    17. We need (really) longer time-lines to comply.
    18. Regulators/Officials need to attend our ‘education’ sessions to understand things.
    19. Add in science based approach again.
    20. We need international harmonisation before acting at the EU. Have you seen what exciting things are happening in the USA.
    21. This is very complex. Do you really want to change?
Conclusion
  1. We support the intentions of the reform.
  2. We love Europe.
Gap Analysis
Position papers of this ilk don’t provide data or evidence to support the points being raised.
There is not even cross referencing to studies commissioned by the Academy of Tobacco Studies from Professor Dr. Erhardt Von Grupten Mundt.
There is no hint to the specific provisions in the existing legislation/regulatory rule book that is causing the real or imagined problems.
Indeed, you have to read half a page to find out about the proposal/initiative they are concerned about. It is not in the title or first paragraph.
Often demonstrate a basic lack of understanding of the current law/proposal/regulatory rule book.
Suggest that the writer has amnesia as they hint the proposal is a surprise without recognizing the initiative has been on the table for 4 years.
Don’t provide links to their studies or submissions to previous public consultations.
The points raised can endlessly be recycled into any policy area. Just delete the name of initiative and add in a new one for the week after.
What to Put in A Good Position Paper
The title of the position paper will be clear about the proposal/initiative/measure the paper is about.
A good position paper will start will summarise their case and solution at the start.
It will be constructive and provide workable policy solutions.
Links to any studies or previous consultation submissions.
Each main point will clearly indicated.
The language will be clear.
Logical flow between the points is nice.
Evidence will be used to support each main point. Data will be used when relevant and presented in a visually clear way. The data will be available. Supporting studies from reputable experts will be cited. Examples will be substantiated and verifiable.
It will anticipate points that the reader will ask themselves and provide the answer.
The position paper will be written for the reader – the Commission official, Commissioner’s Cabinet, Rapporteur/Shadows etc – and not themselves.
NGOs have their own version of the poor position paper. The Standards Brussels Position Paper afflicts too many.

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