Have Your Say is a useful tool for the Commission to get feedback on new initiatives.
It misses one opportunity for interests and the public to provide useful feedback. That is providing feedback on the draft Impact Assessment just before it is sent to the Regulatory Scrutiny Board.
Now the only chance you get to provide feedback on the evidence to support the proposal is in the post-adoption feedback.
All it would take is a public consultation 2 weeks before the RSB receive the draft Impact Assessment.Then the RSB’s secretariat can screen any submissions, and provide a summary to RSB before they first sit down to consider the Impact Assessment.
A final evidence sanity check.
I doubt letting will block many, because:
- 99% of interests won’t have have valid data to bring to the table. Back of a fag packet data is unlikely going to make the grade.
- Maybe the Commission’s cost assumptions are off the mark by a factor of 100. But, you’d only know the costing errors if you had specific expertise based on working in the sector. Paper based reviews may get things wrong.
- It will filter out errors in the Commission’s reasoning like 1+1=111.
- It will help identify a few cases of “I’m not sure we meant to do that”, that stakeholders can flag on the real life impacts. Maybe the RSB experts are unaware of those specific impacts.
Some Side Benefits
- It would have the added benefit of providing an evidence rich document for the Cabinets to review. They can use the feedback to screen that nothing politically embarrassing is coming out the Commission’s proposal pipeline. This may be useful if the officials doing the political screening are new to the area or know little about it.
- It would be helpful to have for secondary legislation, where accidentally a measure may have some inadvertent side effects, like the de-Industrialization of Europe over night.
- And, it would have the added benefit of keeping quiet those interests who wake up after the proposal is made and complain they did not know about the initiative.