Juncker’s State of the Union 2017

European Commission President Juncker presented his 2017 State of the Union address on 13 September. This outlines the priority actions for the remainder of the Juncker Commission.

 

At the same as President Junker delivered his speech to the European Parliament, he transmitted a Letter of Intent to the Parliament and Council (here). More importantly, the College of Commissioners adopted 41 proposals. You can see the proposals here and in the Annex.

The Letter of Intent outlines 10 priorities; each priority itself divided in two separate groups.

The first group are initiatives to be launched and/or completed by the end of 2018. The intention is that all proposals to be adopted under this Commission will be adopted by May 2018.  In practice, this means that all proposals will be adopted by the College by  1st quarter 2018.  This will allow them to secure political adoption by the end of this Commission’s mandate.  Some key files like the budget will need to be adopted.

The second group are a set of initiatives to be launched with ‘ a 2025 perspective’. The Commission have a strict line on “political discontinuity”. The intention for the second group is to launch reviews of current legislation.
The Commission corridors post May 2018 will be lonely places. As the Commission found out when started to look at the habitats and nature directive, there are few prizes for opening up sacred crowds.

This will work in tandem with the “subsidiarity and proportionality” task force led by 1st Vice-President Timmermans. This Task Force will be something to watch.  It will give an opportunity for interests who want to encourage reflection for revision of existing legislation to develop evidence to support their case and bring this material to the table.

Some of the proposals, like the Task Force, caught even the Commissioner by surprise.

 

 

 

STATE OF THE UNION 2017

Letter of Intent to President Antonio Tajani and to Prime Minister Jüri Ratas

 

Roadmap for a More United, Stronger and More Democratic Union

 

Priority 1: A new boost for jobs, growth and investment

Initiatives to be launched and/or completed by end 2018

Circular Economy package to boost innovation, jobs and growth, including:

  • a strategy on plastics working towards all plastic packaging on the EU market being recyclable by 2030
  • a proposal for a Regulation on Waste Water Reuse;
  • a revision of the Drinking Water Directive;
  • and a monitoring framework for the Circular Economy.

 

Initiatives to be launched with a 2025 perspective

  • Reflection Paper ‘Towards a Sustainable Europe by 2030’ on the follow-up to the UN Sustainable Development Goals, including on the Paris Agreement on Climate Change.

 

Priority 3: A resilient Energy Union with a forward-looking climate change policy

Initiatives to be launched and/or completed by end 2018

Swift adoption by the co-legislators of the Commission proposals to implement the Energy Union and Climate Change policy, including:

  • the Clean Energy for all Europeans package;
  • the Climate package;
  • and the Europe on the Move package.

Mobility and Climate Change package, including legislative proposals on:

  • clean vehicles;
  • common rules for combined transport of goods;
  • CO2 standards for cars and vans;
  • fuel-efficiency and CO2 standards for lorries, buses and coaches;
  • and an initiative to accelerate the delivery of the alternative fuels infrastructure.

 

 

Initiatives to be launched with a 2025 perspective

  • Communication on the future of EU energy and climate policy, including on the future of the Euratom Treaty (taking account of Declaration No 54 of five Member States added to the Final Act of the Lisbon Treaty) and on the possible use of Article 192(2), second subparagraph TFEU

 

Priority 4:  A Deeper and fairer internal market with a strengthened industrial base

Initiatives to be launched/and/or completed by 2018

  • A renewed EU Industrial Policy Strategy to foster industrial competitiveness, innovation and technological leadership for fair and good-quality jobs in industry and to make use of the potential of digital technologies across all industrial sectors.

 

Priority 6: Trade: a balanced and progressive trade policy to harness globalisation

Initiatives to be launched and/or completed by end 2018

Trade package, including:

  • a Communication on an upgraded, values-based, sustainable and transparent trade policy that helps harnessing globalisation and ensures a balanced approach on open and fair trade agreement;
  • draft mandates for launching negotiations with Australia and New Zealand;
  • a draft mandate for a new Multilateral Investment Court System;
  • a European framework for the screening of foreign direct investment in the EU on grounds of public order and security.

Swift adoption by the co-legislators of the proposals to modernise the EU trade defence instruments and amend its anti-dumping methodology, and the amended proposal concerning an International Procurement Instrument.

  • Finalising agreements with Japan, Singapore and Vietnam;
  • Pursuing negotiations with Mexico and Mercosur.

 

Priority 10: A Union of democratic change

Swift agreement by the co-legislators on the proposed amendments to the Comitology Regulation.

Initiatives to be launched with a 2025 perspective

  • Communication on further enhancing subsidiarity;
  • Proportionality and better regulation in the daily operation of the European Union.

 

 

Detailed Annex

The proposals in the State of Union adopted yesterday were:
DG – Title

 

CNECT:  framework for the free flow of non-personal data in the European UnionPDF (English)
SG Communication: welcoming Foreign Direct Investment while Protecting Essential Interests

TRADE

PDF (English)
Trade Recommendation for a COUNCIL DECISION authorising the opening of negotiations for a Convention establishing a multilateral court for the settlement of investment disputesPDF (English)
Trade  Communication  A Balanced and Progressive Trade Policy to Harness GlobalisationPDF (English)
Trade Report on the Implementation of the Trade Policy Strategy Trade for All Delivering a Progressive Trade Policy to Harness GlobalisationPDF (English)
Trade Proposal for a Regulation: establishing a framework for screening of foreign direct investments into the European UnionPDF (English)
GROW Communication: the 2017 list of Critical Raw Materials for the EUPDF (English)
HOME:  Proposal for a Council on combating fraud and counterfeiting of non-cash means of payment and replacing Council Framework DecisionPDF (English)
SG Proposal for a Regulation on the European citizens’ initiativePDF (English)

 

 

SG Proposal for a statute and funding of European political parties and European political foundations

SG Communication  Investing in a smart, innovative and sustainable Industry: A renewed EU Industrial Policy StrategyPDF (English)

PDF (other languages)

CNECT  the evaluation of the European Union Agency for Network and Information Security (ENISA)PDF (English)
CNECT Proposal for a Regulation on ENISA, the “EU Cybersecurity Agency”, and repealing Regulation (EU) 526/2013, and on Information and Communication Technology cybersecurity certification (”Cybersecurity Act”)PDF (English)
CNECT Communication Making the most of NIS – towards the effective implementation of Directive (EU) 2016/1148 concerning measures for a high common level of security of network and information systems across the UnionPDF (English)
HOME Report from the Commission assessing the extent to which the Member States have taken the necessary measures in order to comply with Directive 2013/40/EU on attacks against information systems and replacing Council Framework Decision 2005/222/JHAPDF (English)

PDF (other languages)

            DG TRADE
TRADE Recommendation for a Decision authorising the opening of negotiations for a Free Trade Agreement with AustraliaPDF (English)

PDF (other languages)

TRADE Recommendation for a Decision authorising the opening of negotiations for a Free Trade Agreement with New ZealandPDF (English)

PDF (other languages)

DG RESEARCH INNOVATION

RTD Commission implementing Decision on the award of grant(s) under Horizon 2020 – the Framework Programme for Research and Innovation (2014-2020)

Document request
RTD Commission implementing Decision

COMMISSION IMPLEMENTING DECISION on the award of grant(s) under Horizon 2020 – the Framework Programme for Research and Innovation (2014-2020)

Document request
 

RTD Commission implementing Decision

COMMISSION IMPLEMENTING DECISION on the award of grant(s) under Horizon 2020 – the Framework Programme for Research and Innovation (2014-2020)

LS Commission Decision

DÉCISION DE LA COMMISSION portant approbation de pouvoirs dans des affaires contentieuses devant la Cour de justice et le Tribunal

Document request
MARE Decision (letter)

Lettre au ministre des Affaires étrangères du Royaume Uni

Document request
JRC Commission Decision

COMMISSION DECISION regarding the distribution of the software Invasive Alien Species Europe (EASIN)

Document request
HOME Commission implementing Decision

COMMISSION IMPLEMENTING DECISION amending Commission Implementing Decision C(2015) 8913 approving the national programme of Sweden for support from the Internal Security Fund for the period from 2014 to 2020

Document request
TRADE Commission Decision

COMMISSION DECISION setting up the Group of Experts on EU Trade Agreements

Document request
CNECT Commission Recommendation on Coordinated Response to Large Scale Cybersecurity Incidents and CrisesDocument request
DG REGIONAL AND URBAN POLICY

REGIO Commission implementing Decision 3083 approving certain elements of the operational programme “Environment” for support from the European Regional Development Fund and the Cohesion Fund under the Investment for growth and jobs goal in the Czech Republic CCI 2014CZ16M1OP002

Document request
EEAS Draft decision EEA Joint Committee

DRAFT DECISION OF THE EEA JOINT COMMITTEE No …/… amending Annex I (Veterinary and phytosanitary matters) to the EEA Agreement

Document request
EEAS Draft decision EEA Joint Committee

DRAFT DECISION OF THE EEA JOINT COMMITTEE No …/… amending Annex I (Veterinary and phytosanitary matters) to the EEA Agreement

Document request
EEAS Draft decision EEA Joint Committee

DRAFT DECISION OF THE EEA JOINT COMMITTEE No …/… amending Annex I (Veterinary and phytosanitary matters) to the EEA Agreement

SECRETARIAT-GENERAL

Communication from the Commission to the Institutions

Sec-Gen Communication Resilience, Deterrence and Defence: Building strong cybersecurity for the EU

Document request
SERVICE FOR FOREIGN POLICY INSTRUMENTS

Joint Proposal for a Council Regulation on restrictive measures in view of the situation in Mali

Document request
CNET – COMMUNICATINS NETWORKS, CONTENT & TECHNOLOGY

Staff working document

on the evaluation of the European Union Agency for Network and Information Security (ENISA) Accompanying the document Proposal for a regulation on ENISA, the “EU Cybersecurity Agency”, and repealing Regulation (EU) 526/2013, and on Information and Communication Technology cybersecurity certification (”Cybersecurity Act”)

Document request
CNECT Impact Assessment Summary Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ENISA, the “EU Cybersecurity Agency”, and repealing Regulation (EU) 526/2013, and on Information and Communication Technology cybersecurity certification (”Cybersecurity Act”)PDF (English)
CNET Impact Assessment

COMMISSION STAFF WORKING DOCUMENT Accompanying the document REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ENISA, the “EU Cybersecurity Agency”, and repealing Regulation (EU) 526/2013, and on Information and Communication Technology cybersecurity certification

PDF (English)
Impact Assessment Summary

Executive Summary of the IA

PDF (English)
Impact Assessment

Impact Assessment

PDF (English)
TRADE

Impact Assessment Summary

Commission Staff Working Document Executive Summary of the Impact Assessment Accompanying the document Recommendation for a Council Decision authorising the opening of negotiations for a Convention establishing a multilateral court for the settlement of investment disputes

PDF (English)
Impact Assessment

Commission Staff Working Document Impact Assessment Multilateral reform of investment dispute resolution Accompanying the document Recommendation for a Council Decision authorising the opening of negotiations for a Convention establishing a multilateral court for the settlement of investment disputes

PDF (English)
DG MIGRATION AND HOME AFFAIRS

Impact Assessment Summary

Executive summary of the impact assessment

Impact Assessment

Proposition de directive du Parlement européen et du Conseil concernant la lutte contre la fraude et la contrefaçon des moyens de paiement autres que les espèces et remplaçant la décision-cadre 2001/413/JAI du Conseil

PDF (English)
DG TRADE

Staff working document

Commission Staff Working Document Accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing a framework for screening of foreign direct investments in the European Union

Document request
DG COMMUNICATIONS NETWORKS, CONTENT TECHNOLOGY

Staff working document

Assessment of the EU 2013 cybersecurity strategy

Document request
Staff working document

Commission Staff Working Document accompanying the Proposal for a Regulation on the European citizens’ initiative

Document request
DG TRADE

Impact Assessment

Commission Staff Working Document Impact Accessment Accompanying the document Recommendation for a Council Decision authorising the opening of negotiations for a Free Trade Agreement with Australia

PDF (English)
Impact Assessment Summary

Commission Staff Working Document Executive Summary of the Impact Assessment Accompanying the document Recommendation for a Council Decision authorising the opening of negotiations for a Free Trade Agreement with Australia

PDF (English)

PDF (other languages)

Impact Assessment Summary

Commission Staff Working Document Executive Summary of the Impact Assessment Accompanying the document Recommendation for a Council Decision authorising the opening of negotiations for a Free Trade Agreement with New Zealand

PDF (English)

PDF (other languages)

Impact Assessment

Commission Staff Working Document Impact Assessment Accompanying the document Recommendation for a Council Decision authorising the opening of negotiations for a Free Trade Agreement with New Zealand

EU Better Regulation in 10 easy Charts & Checklists

 

The current guidelines, 19.5.2015, are here. They are 91 pages long.  They are supported by a Toolbox (here) of 414 pages. This rule book has been updated. It has been transmitted to the European Parliament and Council. It is now  90 pages of detailed guidelines and supported by a 500 page Toolbox.

I would recommend that you read this Manual. But, in case you don’t want to, I have listed some of the most useful checklists and charts.

In Praise of Better Regulation 

I have been an isolated supporter of ‘Better Regulation’. I think it is the most revolutionary and positive action of the Juncker Commission.

There is a virtue in the certainty in the preparation and development of policy and law. Bruno Leoni, in Freedom and the Law, writes about the importance of officials discretion being limited by clear rules..

The Guidelines provide a clear set of rules that any official can follow. The Guidelines are so clearly written so there should be no reason why they are not followed.

I welcome two main aspects of the Guidelines.

First, by codifying good practice it limits administrative discretion in developing new rules. It places weaker restraints on the exercise of political discretion by Commissioners, and very few on elected MEPs or Member States. Politicians and governments, as a broad class, are reluctant to have their hands tied, let alone follow basic good practice.

Second, it opens up European law making to public scrutiny. Now there is a lot of scrutiny. I am not sure how many people login into to it. I check it out every week. You can find it here.

 

Better Regulation is about ‘designing EU policies and laws so that they achieve their objects at minimum costs. …. It is a way of working to ensure that political decisions are prepared in an open, tranpsranet manner, informed by the best available evidence and backed by the comprehensive involvement of stakeholders’. Why anyone could be against this is beyond me, but there are many who are.

 

When to follow and not

Officials have to follow the steps laid out in the Guidelines.  The Toolbox provides additional guidance.  The Toolbox is only binding if “expressly stated”.

There are times when the Guidelines may be by-passed. These include:

  •  social partner agreements (see Art.155 Treaty),
  • a political imperative to move ahead quickly,
  • an emergeny,
  • specific deadlines in legislation, or
  • a need to respect security related or confidential information

If officials want to apply an exception they need to ask for this at:

  1. When the initiative is getting political validation
  2. Permission frm the Secretary-General and First Vice-President

 

The Guidelines are meant to be read by all ‘officials involved in regulatory activities.’ It would be interesting to know how many have.

The greatest weakness to Better Regulation is political will and time at the very highest levels of the Commission to follow and implement it. A First Vice-President who is clearly so busy and active must have little time to pick political fights with his fellow Commissioners and high ranking officials who would rather pre-determine the policy outcome from the very start than go through an exercise that may deliver results they do not like.

 

Key Checklists and Charts

Below I have gone through the new Guidelines and Toolbox and pulled out the 10 most useful charts and checklists.

 

  1. When is Political Validation Required?

See: Box 2. Scoping, political validation and interservice work

• Political validation is required to move beyond the informal consideration of a

possible initiative and to start the substantive prepatory work including engagement

with stakeholders.

• The level of political validation depends on the nature and importance of the inititiave.

“Major initiatives” should, in principle, be entered into Decide at least 12 months

prior to adoption by the College. They must be validated by the lead Commissioner,

relevant Vice-President and the First Vice-President before being accepted to be

included into the Commissions’ planning. “Other initiatives” should be validated by

the lead Commissioner or by the Director-General of the lead DG as appropriate.

• Political validation must be understood as giving the green light to start the

substantive preparatory work. It should not be interpreted as a decision on a particular

initiative or course of action that prejudges the outcome of any impact assessment

process, stakeholder consultation or later political discussion in the College.

• For major initiatives and for evaluations (including fitness checks), once political

validation is granted, roadmaps or inception impact assessments must be finalised

and published as quickly as possible. They explain to external stakeholders what the

Commission is considering and allow them to provide early feedback.

• Roadmaps are used for initiatives which do not require an impact assessment. The

reasons justifying the absence of an impact assessment will be included.

• Inception impact assessments are used for initiatives subject to an impact

assessment. These set out in greater detail the description of the problem, issues

related to subsidiarity, the policy objectives and options as well as the likely impacts

of each option.

• A roadmap is prepared for each evaluation or fitness check. This specifies the

context, scope and purpose of the evaluation and outlines the proposed approach.

• All roadmaps (including for evaluations and fitness checks) and inception impact

assessments are published by the Secretariat-General on the Commission’s website12

so that citizens and stakeholders are informed and can provide initial feedback

(including data and information they may possess) on all aspects of the intended

initiative and where applicable its impact assessment.

• Evaluations, impact assessments, stakeholder consultations, policy proposals and

implementation plans must be discussed collectively by the services13 within an

interservice group. It is important that all services with an interest participate

actively in the interservice work from the outset, particularly those DGs with specific

expertise (e.g. competitiveness and innovation, SME impacts, economic, social

impacts, environmental impacts and scientific/analytical methods).

• The launch of the interservice consultation must be agreed politically (in a similar way

to the validation of new initiatives). In addition, where an initiative is supported by an

impact assessment, a positive opinion of the Regulatory Scrutiny Board is required in

order for the initiative to be presented to the Commission for decision.

2. Who validates for what & the  implications 

 

3. The Planning and Validation Process – A schedule 

 

4.  The Key Questions an Evaluation Must Answer

 

1. What is the current situation?

2. How effective has the EU intervention been?

3. How efficient has the EU intervention been?

4. How relevant is the EU intervention?

5. How coherent is the EU intervention internally and with other (EU) actions?

 

5. Key Timelines for Public Consultation

 

6. What documents go to the Regulatory Scrutiny Board?

 

6.1 Impact Assessment

What?

Note signed by the Director General of the lead DG addressed to the chair of the RSB.

 Draft IA report (SWD).

 IA summary sheet accompanying the IA report (SWD).

 Minutes of the meeting of interservice group that has been preparing the IA report immediately prior to submission of the IA report to the RSB.

 Links to where important underlying reports or studies can be found which underpin the IA report.

 Underlying evaluation SWD, if this evaluation has not been scrutinised separately by the RSB.

 

When

 The lead DG should reserve a slot at a future meeting of the RSB at which the IA report will be discussed. In general, the slot should be reserved at least 3 months before the RSB meeting.

 This slot should reflect the envisaged timing of the political initiative, the time needed to adapt the IA report in light of the Board’s opinion(s) and the time needed to complete a formal interservice consultation and formal adoption by the College.

 The draft IA report should be submitted to the RSB at least 4 weeks before the RSB meeting where the draft IA report will be discussed.

 In a few exceptional cases, the RSB may decide that the draft impact assessment report does not need to be discussed at a formal meeting of the Board but can be dealt with via written procedure. This can only be decided on a case-by-case basis once the draft IA report has been submitted to the RSB and will depend on the quality and lack of complexity of the case at hand.

 

Re-Submissions

 Where the RSB issues a negative opinion, the lead DG will have to incorporate the Board’s recommendations into a revised IA report, to discuss those changes with the ISG and to submit a revised report to the RSB.

 The RSB will aim to issue a revised opinion within 4 weeks following resubmission. In most cases, the opinion will be issued following a written procedure. However, the RSB may wish to hear the lead DG again in a meeting. In such cases, the RSB secretariat will organise an appropriate slot in consultation with the lead DG.

 

7.  Fitness Checks and Evaulations Secletced for Scrutiny by the RSB

What?

Note signed by the Director General of the lead DG addressed to the Chair of the RSB.

 Draft evaluation SWD/fitness check report (SWD).

 Executive summary of the evaluation SWD or fitness check report.

 Minutes of the meeting of interservice group that has been preparing the evaluation report immediately prior to submission of the draft evaluation report to the RSB.

 Quality assessment discussed and agreed by the ISG.

 Any report prepared by consultants (where relevant).

 

When?

The lead DG should reserve a slot at a future meeting of the RSB at which the evaluation/fitness check report will be discussed. In general, the slot should be reserved at least 3 months before the RSB meeting.

 In line with the “evaluate first” principle, the fitness check report or evaluation SWD should usually be reviewed by the RSB ahead of the submission of the corresponding impact assessment.

 The draft evaluation/fitness check report should be submitted to the RSB at least 4 weeks before the RSB meeting that will discuss the draft evaluation SWD or fitness check report.

 In a few exceptional cases, the RSB may decide that the draft evaluation report does not need to be discussed at a formal meeting of the Board but can be dealt with via written procedure. This can only be decided on a case-by-case basis once the draft evaluation SWD or fitness check report has been submitted to the RSB and will depend on the quality and lack of complexity of the case at hand.

 

Follow up

The lead DG is expected to incorporate the Board’s recommendations into a revised fitness check report or evaluation SWD and to discuss the changes with the relevant ISG.

 A negative opinion does not prevent the launch of an interservice consultation on the fitness check report or evaluation SWD. However, the lead DG may wish to submit a revised SWD or report to the RSB. In such cases, the Board will aim to issue an opinion within 4 weeks usually by written procedure. In some cases, the lead DG may be invited to a meeting with the RSB which will be

 

8. Initiatives for which the need for an IA should be assessed

  1. New legal acts
Revision of existing legal acts
Recasts of existing legal acts
Non-technical repeal of existing legal acts77
Delegated acts (Art. 290 TFEU)
Implementation measures (Art. 291 TFEU)
Transposition of international agreement into EU law78
White papers
Policy communications
Action Plans
Recommendations
Recommendations for the negotiation of international agreements.
Social partner agreements pursuant to Articles 154-155 TFEU79.
Financial programmes (i.e. all basic acts for spending programmes and financial instruments)

 

9. Initiatives for which no automatic need for an Impact Assessment

 

 

9.2. Do you need an Impact Assessment when an EU Agency is Involved?

 

10.  Key Steps ad Requirements for an Impact Assessment

 

 

10.2. Process Chart for the the typical Impact Assessment

 

Observations on the neonicotinoids challenge

Observations on the neonicotinoids implementing act challenge

 On 7th April 2017, Julie Girdling (UK/ECR) submitted three objections to restrictions on 3 neonicotinoid pesticides: active substance coinciding; imidacloprid; ethiamethoxam.

Neonicotinoids  are a group of pesticides that mimic nicotine.  They have been subject to EU restrictions because questions of impacting bees.

The grounds put forward to objecting to the 3 draft implementing acts were that the Commission had exceeded the implementing powers provided for in the basic act.  Please go the bottom of the post for the 3 objections.

As is normal, after a discussion in the Environment Committee on 21 June, the Committee voted the next day.

On 22 June, the European Parliament rejected the move.

The amendments were defeated. 8 MEPs backed the challenged and 43 voted against.

As there is no automatic roll call vote, it is not possible to identify how individual MEPs voted.

I understand it was supported by some ECR MEPs and some classical liberals in the ALDE Group.

 

Observations

 

  • The trend for motions being put forward by a single group being defeated continues.
  • The focus of challenges to be directed towards sensitive issues – pesticides, GMOs, baby food – continues.
  • Anything that does not have broad cross party support, in particular from the Social Democrats, is unlikely to succeed.
  • At times, it seems like a theoretical possibility that the EP will support a challenge against a restriction on some substances.
  • As with delegated legislation in general, and implementing acts in particular, the key stage to influence the outcome is to influence the Commission’s proposal. Whatever the Commission is, in all likelihood, going to be adopted.

s_2014_2019_plmrep_COMMITTEES_ENVI_DV_2017_06-21_1127403EN

Better Regulation & Ordinary Legislation in one easy chart

I wanted to put down in one easy chart how the Commission adopts ordinary legislation. This is the chart I came up with.

The advantage of the Better Regulation rules is that the process for adopting a legislative proposal is quite straightforward.

First, you have to go through the Better Regulation guidelines and toolbox.  If you don’t want to go through that, I have added a process chart.

Second, you need know who is involved in the Inter-service Steering Group and the Inter-Service Consultation at the Services and Cabinet level. You are going to need to know max around 50 people. That’s a lot less than 200 +  people you need to know when it goes to the ordinary legislation stage

Third, around a year after the political validation for the work to start, and the first road map/inception impact assessment, you are likely to see a legislative proposal being adopted.

Fourth, to be honest, the smoke signals that regulation in your area is likely to be seen many months and years before political validation. The only excuse for not seeing the signs is long term hospitalisation or political hibernation. After 25 years I  have not yet encountered a piece of legislative action that “came out of the blue”. As soon as the smoke signals are seen, and hopefully before, your work developing your case and story will start.

Finally, that gives you a few months to get your facts and story in a line to persuade 50 people that your solutions are the best and get them to back your side of the story.