Situation analysis

Define objectives

Build coalitions and alliances

Define key audiences, messages and determine channels of communication

Impact measurement

ANNEX

The public affairs plan: Seven steps to success rooted in science and practice, November 2020, with Iskander De Bruycker

How to Work with the EU Institutions: A Practical Guide to Successful Public Affairs in the EU, Ed. Alan Hardacre, John Harper Publishing, 2020

What is in a name? The Regulation of Electrical and Electronic Products, European Environmental Law Review, Volume 14, Issue 10 (2005) pp. 252 – 264

“Beyond the Market: The EU and National Social Policy” (State & the European Union), June 1998, Ed. David Hine and Hussein Kassim., chapter on EC Action and Initiatives in Environmental Protection with David Freestone

The Role of Public Authorities in Integrated Product Policy, Belgian Science Policy, Pallemaerts et al. February 2006

Practitioner Session: The Lobby Plan. ECPR. Maastricht University.

9 July 2025

Today, I’m going to talk about the ‘Lobby Plan’. It goes by other names – a campaign plan.

It is on a topic that I teach every year at Maastricht’s MA in European Public Affairs.

You have access to the article that Professor De Byrcker and I wrote back in 2020.

Background

I’m not an academic. I left that world in 1996 – a PhD dropout on the evergreen topic of non-enforcement of EU environmental legislation – and had a brief interlude at the IES-VUB for three years, researching and consulting on environmental product regulation. A list of my academic publications appears in the notes. For the last few years, I have visited the EUI’s Executive training on ‘on-boxing the European Commission’.

Since 1996, I’ve been working at the coal face of law-making, political campaigning, and lobbying.

In a sequential order:

For two British Labour MEPs, one on passing fisheries rules, and another on air pollution
Two spells in the European Commission’s Environment Department, focusing on the implementation of air pollution legislation and the adoption of Electronic legislation.
I have worked for the fantastic political campaigning NGO, IFAW. I headed WWF’s European Marine Programme, based in Brussels.
For the last 15 years, I have worked at Fleishman-Hillard in Brussels, supporting a diverse range of Clients, Including Foundations, Trade Associations, and companies, in their lobbying efforts.
I was seconded to the European Chemical Industry’s trade association, Cefic, to lead their Public Affairs work for approximately four years.
Finally, for the last 15 years, in my spare time, I write some practical insights into the practice of lobbying in an imaginatively titled blog ‘www.aaronmcloughlin.com’.

What does a lobbyist do

So, I have a ‘strange’ mixture of legislative, campaigning and lobbying experience.

Today, I stand before you as a professional lobbyist. I suspect it is one of the least understood and written-about professions.

This may be because, unlike lawyers, there is no professional certification required. I hope one day that will change.

I have a very small circle of competence. I work only on:

EU Ordinary legislation
EU Secondary legislation (Delegated acts, implementing acts, and RPS measures)
And three areas: chemicals, Environmental policy (with a focus on air and waste in particular), and fisheries.

A local game

The way lobbying is done in Berlin, Paris, London, and Rome differs significantly from how it is done in Brussels, let alone as compared to Washington, D.C. The rules of the game in each political capital vary.

I’ve seen how things work in DC and in London. It taught me a useful lesson: don’t play the game on others’ turf. When playing there, use an experienced player. That will be the end of any football metaphors today.

What is Universal

What is universal is the need to have a ‘plan’ that is written down.

I will cite with approval the great political campaign manager Karl Rove.

This is the man who got President Bush Jnr elected twice.

“Answering those questions and all the other things that go into a campaign and committing them to paper is an exercise that causes campaigns to be better simply by doing that. If you don’t do it, however, you’re going to bounce around and be driven more by the moment. I love to run against people who don’t seemingly have a good idea of what they’re trying to do and when they’re going to do it. I like being on the offence. And by having a plan, you’re more likely to be on the offense.”

Source: David Axelrod and Karl Rove, Master Class on Campaign Strategy and Messaging.

I agree with him.

The plan is one of the key tools a lobbyist needs.

Other tools for the craftsman include:

Position Paper
Policy Memo
Communications Grid
Op-Ed
Speaking notes
Issue Tracker
Public Consultation Submission
Policy Presentation
Elevator Presentation
Letter to an official/politician
Amendment and Justification
4-column document
Shadow Impact Assessment

There is little written about these vital tools.

Richard N. Haas wrote the Bureaucratic Entrepreneur because “This is my attempt to write the book I sought but could not find’(p.xiv).

In a similar vein, the purple book. “How to Work with the EU Institutions. Ed. Alan Hardacre, which contains a few chapters by me, is my attempt to write the book I wished had existed at the start of my career as a lobbyist.

Why do Academics miss this out

It is something that is not often written about.

It is looked at by practitioner texts:

Chris Rose, How to Win Campaigns, Chapter 5

Catherine Shaw, The Campaign Manager

The public affairs plan: Seven steps to success rooted in science and practice, November 2020, Iskander De Bruycker & Aaron McLoughlin

I follow a few academics, but not many: John Kingdon, Tullock, Hussein, and Culley.

Most academic writing is too difficult for me to understand. Clear and direct writing seems to be a sin.

Sadly, many graduates need to have the long-winded writing de-programmed when they start work. I note that the master’s students from Maastricht have learned the joys of plain writing.

At the end of this document are some books that I find useful on this issue.

The Lobby Plan Template

One universal thing is that you need to have the plan written down on paper.

I can predict the chances of success of any organization by just looking at its plan.

If they don’t have one, or it is of poor quality, the writing is on the wall. A re-start can remedy a poor start.

Continuing without anything on paper is a recipe for disaster. It helps explain why success is so rare.

Each year, at this very University, students produce a lobby plan that is as good as, and in many cases, better than nearly any lobby plan I’d see from a consultancy in Brussels.

It is something I’ve used in various guises from IFAW, WWF and Cefic.

It is not wizardry.

Let’s look at some of the sections.

See PPT/end.

Why would you not prepare a Lobby Plan

There are some very good reasons why you would not put pen to paper and put your thoughts down on paper.

On paper, your ideas take on a new form. What you may be suggesting comes across as demented.
It may reveal what in your heart of hearts you already know that what you are asking for is ‘impossible’.Maybe, all you are asking for is a simple Treaty change, and hope nobody notices!
You or your client (commercial interest or an NGO) may have a cognitive inability to perform the necessary actions.
A plan may reveal that you don’t have the necessary evidence, objective data, studies, solution, or resources to win. Maybe denying reality is easier, and you have a bout of amnesia or a blackout, until the fateful day when you lose.

An aside

You may be dealing with an interest that comes from the ‘evangelical’ tradition of lobbying. This group believes that they have the power of tongues, and all they need to do to persuade someone to believe in the chosen path is to hear them speak. When decision makers – officials and politicians – hear their ‘word’, they’ll recant their false beliefs and instantly throw away their positions and proposals. After 28 years, I’ve never seen it happen.

When you persuade someone on your side to act against you

There are a few total reversals of positions I’ve heard about.

I learned from the former British Environment Minister, John Gummer, two good examples.

At a British Cabinet Meeting discussion on a ban on the aerial spraying of pesticides, the then Chancellor, Nigel Lawson, switched his position to support the ban after he and his family were sprayed on at their weekend residence.

Another was when the CEO of an American company demanded that the British PM, Margaret Thatcher, fire her Environment Minister, Mr. Gummer, because of a position he held. She called him in, told him what had happened, and said the job was his for as long as he wanted it.

Indeed, I have too many examples of when the ‘persuasive skills’ of lobbyists have led officials and politicians who were initially on board to switch their position after their intervention.

What does successful lobbying look like

Successful lobbying only comes down to a few things:

Engaging constructively at the right time, with the right people, with the right values (the decision-makers, not yours)
Have the right evidence, data, studies, solutions, legislative text/amendments, that are clearly and considerately presented.
Have someone who can sell your case/message.
Have the resources to deliver on the lobby plan.

It is not much to ask. It is a hard combination to pull off.

Things you should never put down in your lobby plan

There are many common tactics that you should never see in a lobby plan. I’ll list some of them:

Stalking decision makers – waiting for them outside their work and accosting them.
Follow decision-makers into the public toilets at an event, even if they are from the opposite sex.
Shouting at them in meetings/online.
Lying about the evidence you are using to support your case.
Lying in general looks bad.
Turning up very late in the process.
Misunderstand the process and get the voting thresholds wrong.

I have encountered some who are reluctant to put their plan on paper for fear of being held accountable for erroneous advice.

If you are a telepath with a photographic memory, there is no need for a written plan.

If you see any of these things happening, I’d recommend hibernating.

Campaigning and lobbying are different.

Political Campaigners take an issue and give the appearance that the public is interested/supportive of action. This leads to politicians and officials responding to the pressure to act.

See a lobbyist as a keyhole surgeon, involved in one small but vital step of the process. Lobbyists step in to get the public policy request, law, or regulation adopted through the machinery of government and Parliament, and onto the statute book.

Too many campaigns raise awareness of an issue, but lack the ability to translate their ideas into law or policy. This often leads to their goals being blocked at the final hurdle.
Raising awareness is not often enough. If you can’t change things, it is all for nothing. And, structural change often needs new law/policies.

Some Simple Steps

Every policy, law, and regulatory measure in every country or jurisdiction undergoes a process for its adoption.

There will be many steps.

There are certain steps that if you fail to ‘turn up’, you’ll miss the pivotal opportunity to promote your client’s interests.

The challenge is that many of the vital steps are not public.

You’ll need to rely on your network of decision makers: Political advisors, politicians, officials, Ministers/Commissioners, and Party advisors, to inform you.

It is like a game of snakes and ladders. If you miss one of the key steps, you will be sent back to the beginning.

For a moment, let’s examine how this process appears for a piece of legislation passing through the EU.

This ladder has a Snakes and Ladders vibe.

For each country, recreate a process map of how laws are passed.

See PPT

Conclusion

Your lobby plan will indicate an accurate map of the journey.

If your map-reading skills are as poor as mine, you will likely be dependent on your car’s GPS or iPhone.

It helps provide a constant update to take into delays in the legislative journey.

This simple tool – the lobby plan – will increase your likelihood of success by 1,000 times.

Would you do any of these things without a detailed plan?

Build a new house
Go through a delicate medical procedure
Go on an extended holiday

The answer is no.

To get from where you are to where you want to be, when seeking to influence a law, policy or regulation, you’ll need a plan.

Recommended Reading

Imogen Bayley, Jakov Bojovic, Policy Communications: How to Write an Effective Policy Brief

Bryceson’s Political Checklist (link)

Alan Hardacre, How to Work with the EU Institutions

John. W. Kingdon, Agendas, Alternatives and Public Policies

Barbara Minto, the Minto Pyramid Principle

Richard N.Haas, The Power to Persuade

Chris Rose, How to Win Campaigns, especially Chapter 5

Catherine Shaw, the Campaign Manager

Aaron Wildavsky, Speaking Truth to Power: Art and Craft of Policy Analysis

Des Wilson. Pressure: The A to Z of Campaigning in Britain.

Aaron’s Academic Work

Karl Rove full extract

A lot of the campaign is going to depend on the message … But after you settle on what that message is and what the theme is, you then need to sit down and write out a plan…. But you need to take the elements of the campaign and reduce them to writing and numbers. And to spread them over a calendar so you have a concrete idea of what it is that you’re going to do and when you’re going to do it and how much it is going to cost. Campaigns that plan tend to be campaigns that have a greater propensity to win because it means that they’ve made conscious decisions about what’s necessary to do, and when to do it, and to make sure that have the resources in order to execute that plan. So it starts with the message and the theme …. And you need to take those ideas, what is it that you want to talk about, and plan them out when you’re going to talk about them and how you’re going to to talk about them. The win is relatively easy. It requires some, you know, sort of thinking it through. How long do we want to talk about that issue? When do we want to introduce this facet of the candidate’s background? When do we want to emphasise this particular theme? You can have a robust discussion about that and plan it out. But the how gets to be really problematic, because the how involves spending money. It is not just simply now, we’re going to send our candidate out and talk about it this week. But we’re going to have to back that up with whatever kind of media is available to you…. That means you are going to have the full range of communications available to you – television, cable, radio, digital, mail. And, again, you’re going to need, again, plan. What do we need? How of that do we need in order to win? And then, it’s an iterative process. Are we able to put that money together? You then need to think about volunteers and your ground game, which we’re going to talk about later. But how do you go about mobilizing people who will then communicate with and focus on the target voters that you’ve agreed upon in order to persuade them and then get them out to vote? All this needs to be done at the beginning of the campaign and agreed upon and committed to paper and then reduced to numbers. That is to say, you need to have a budget spread over time that shows, for each one of those activities, how much you’re going to need to spend, what you’re going to need to spend it on, and how it shows up across the budget. And, then carefully check it against the fundraisers.

You have to follow through and evolve.

Over the years, I’ve seen, more often, that people fail in a campaign because they don’t have a plan than they do have a plan and don’t execute it. There is some – there’s a discipline about putting this all down, putting the working assumptions about who is it that’s going to vote for us? Who’s not going to vote for us? Where are we going to get our votes? What’s our message going to be? What are the strengths of our candidate? What are we going to make the race about? Answering those questions and all the other things that go into a campaign and committing them to paper is an exercise that causes campaigns to be better simply by doing that. If you don’t do it, however, you’re going to bounce around and be driven more by the moment. I love to run against people who don’t seemingly have a good idea of what they’re trying to do and when they’re going to do it. I like being on the offense. And by having a plan, you’re more likely to be on the offense. Look, you can’t plan 12 months in advance or 16 months in advance or nine months in advance of a campaign what’s going to be happening in the final stages of the campaign. But you can have some working assumptions and then modify those working assumptions as you go along by saying, we’re going to have a process and a group of people who are going to examine what we’re doing and decide whether we ought to keep doing it or ought to change. …. So in our plan, we built targets for what we wanted the registration pictures to look like in big states. And we also, then, mapped out our program for identifying supporters and doing the things necessary to get them to the polls – calling them on the phone, knocking on their doors, send them mail pieces. And we could then monitor them. We had, literally, a set of numbers. Every Monday morning, for almost a year and a half, I would get a document that showed me how we were doing in every battleground country in every battleground state on registration. So when we began to show shortfalls, we could redirect resources to those states. Similarly, during the summer and fall of 2004, I got regular reports that showed how we were doing in terms of battleground counties, battleground states. How many doors were being knocked on against our target? How many phones were being rung against our target? How many volunteers were being recruited against our targets? And any time we showed up with serious shortfalls, everybody in the system knew that we’ve got to solve that. So that’s why a plan is so important. And that’s why having mechanisms in place led by a group, but also involving – today, technology makes it so easy to monitor so many of these things in a campaign…. But you can’t do that unless you have a plan and mechanism to monitor.

David Axelrod and Karl Rove give a Master Class on Campaign Strategy and Messaging.

Lobby plan template

This template was developed by Aaron McLoughlin and the course coordinator. It provides a structure, guiding questions and instructions to develop your lobby plan. You are asked to build a lobbying strategy for a specific legislative issue and a specific client as if you are a public affairs consultancy firm. You do not have to address all the guiding questions, nor should you address them in their order of appearance. You can rely on the readings, the slides, the material discussed in the lectures and your own research for adequately completing this assignment. To ultimately decide what to include in the plan and how, you are advised to consult the assessment form. You can find the assessment form for this assignment on CANVAS. The lobby plan should be between 20 to 30 pages. You are free to decide on font, line-spacing, paragraphing, layout and structure, but the document should be clear, accessible and readable. Please remove the instructions before submitting the assignment on CANVAS.

Summarize relevant information about the policy context of the issue you work on, the institutional context, and the relevance for your client. What is at stake for your client? What is the current policy situation? Who are the key decision makers and stakeholders? At which level(s) of government is the policy process taking place? Will you perform additional research? Which data sources did or will you use? How salient is the issue and how could this evolve? Who are your potential allies and opponents? Do you have public opinion on your side? How complex/technical is the issue?

Checklist situation analysis

Include a short description of the issue.
Why is it important for you (e.g. policy impact, financial impact)?
What priority is this issue?
Background on the development of the file. What is driving the issue? Where is the file in the policy cycle?
What type of legislation is it? Ordinary or secondary legislation (Regulatory Procedure with Scrutiny, Delegated Act, Implementing Act).
What is the schedule for adoption of the file (e.g. initial debate in Committee, schedule of Council Working Group discussions, EP Draft report, deadline for amendments, deadline for compromises, vote in Committee, vote in plenary)?
How many votes do you need to win? What are the implications of previous or similar votes? Look at VoteWatch.
Who is your public affairs team leading work on the issue? What are their roles?
Who is paying for the work?
Who are your opponents? What are their positions? What are they saying about you/ your positions? List their contact details.
Identify key journalists, academics, think tanks and issue experts on your file. List them, their position and contact details.
Who are the key decision makers working on the file? List them, their position and contact details.
Key decision makers in the Commission: Drafting or negotiating team, Inter-Service Steering Group, Inter-Service Group (service and cabinet).
Key decision makers in the Council: Council Working Group, COREPER, Member State issue expert.
Key decision makers in the EP: Lead Committee – members, substitutes, and political advisers, coordinators for Groups and national groups, Committee officials, Opinion Committee – Rapporteurs and Shadows.

1.1 Cover Sheet

Short Title:

A short descriptive name for the issue

Proposal Development Background

Legislative process: Type (Ordinary/co-decision, delegated (RPS, Delegated act, implementing act)

Stage: (e.g. 1^st/2^nd reading, conciliation)

Priority:

A statement of the “value” of the issue

Governance:

Ownership

Team

1.2 Issue sheet

Policy objective:

A statement of the general policy area and objective

Implications and past votes

· What is the reasonable worst-case scenario if we do nothing in terms of € to our members

· Has a similar vote happened recently? What was the outcome/lessons learned?

1.3. Potential allies & opposition

Allies

Position/contact

Opponents

Position

1.4 Relevant contacts

See annex 1

1.5 Power analysis

Policy change objective	Who are the key decision makers? What is their current position on the issue: Champions, Swingers, Blockers	Who can influence them	What will influence the decision makers	Who are the key allies or partners on this issue? What is their influence and position? What role can they play	What are the particular decisions made? Are the opportunities closed or open	Implications? What advocacy strategies and activities will be best effective given this analysis

European Commission
Actors – Lead DG: hierarchy (Unit, Director, DG) – Interservice DGs: (Unit ) – Interservice Steering Group – Cabinets
Date	*Current Status*
Date	*Key decision points – eg* – Green paper published – Consultation dates – Impact Assessment – Draft proposals – Interservice – Adoption

Council
Actors – Lead Council (Working Group) / Ministries – Permanent Representations (WG level, COREPER) – Member State national lead
Date	*Current Status*
Date	*Key decision points – eg* – Working Group Meetings – COREPER – Council Meetings – debates & conclusions – Council Meetings – adoption

European Parliament
Actors – Lead Committee (members & substitutes & political advisors) – Co-ordinators – Rapporteurs & shadows – Group Advisers – Committee officials – Opinion Committees (Rapporteurs & Shadows)
Date	*Current Status*
Date	*Key decision points – eg* – Initiation – Draft Report – Deadline for amendments – Compromises – Votes

Define what you want to achieve with your campaign. Determine to what extent and how you will involve your own supporters and constituents in the campaign.

Checklist for defining objectives:

What are your SMART objectives?
What are the short-term, mid-term and long-term objectives?
Are these acceptable to members or clients?
What are major risks to achieving campaign goals. How to mitigate against them?

2.1 Advocacy goals:

What will this plan specifically achieve? It is important that this is not about building up a new Programme or work stream. Instead, the goals should be

Smart
Measurable
Achievable (in particular, possible majorities in EP and Council)
Relevant
Time Bound

2.2 Risks and contingency plans

There are always major risks to achieving campaign goals. It is helpful to describe what they are in advance and take steps in advance to mitigate against them.

Checklist for building coalitions and alliances:

Will you lobby alone or in a coalition? What are the costs and benefits? Who to include?
Will you take a leading role in the coalition?
How will you mobilize your allies?
How will you leverage your network?

Define who you will target, when and why. Which political arenas and levels of government will you target and when? Which party families will you prioritize and why? Will you target allies or opponents only or both?

Define your main message. Which information and frames will you convey, to whom, when and why?

Define which channels of communication you will use. Who will you target via which channels and with which message? Will you go public with the campaign? Why (not)? When? What are the potential risks of (not) going public?

Checklist:

What are your key messages?
What is the evidence to support your key messages?
What policy alternatives will be proposed?
What are your key materials (one pager, key messages, Q&A, amendments, standard letters, emails, evidence, studies, data)?
Who will be targeted when and why?
How to balance targeting friends and foes?
Which content will be sent to whom, when and how?
Identify your plan of action: Which channels will be used to contact whom, when, with what content and for achieving what goal? Include this in a timetable or flowchart.
Make an overview of the cost of each item in your plan of action.
Adjust your plan of action in light of your available budget.

4.1 Key messages and materials

Key messages:

· Bullets setting out what we propose to argue in order to secure those goals

Rejoinders:

What others might say in response

Challenges:

· What opponents are saying

Rebuttals:

Our answers.

Materials:

Advocacy Documents

	y/n
Narrative
One-pager, leave behind
Key messages
Q&A
Amendments
Letters, e-mails etc

Supporting evidence

	y/n
Data request
Data received
Study commissioned

4.2 Advocacy – direct contacts (inside lobbying) ), e.g. lunches, virtual meetings, expert committees, email, phone, etc.

Commission (who)	By whom	When	What	How
Lead DG, Unit
Sec-Gen lead(s)
Interservice DGs
Commissioner(s)
Cabinets
Lead official(s) desk officer
Legislative team
Council (who)
Presidency
Permanent Representations
National issue lead
Council officials
Parliament (who)
Rapporteur(s)
Shadows
Committee Group coordinators
National Group coordinators
Shadows
Advisors to MEPs
Group Advisors
Committee officials
Key influencer(s) MEPs
Key influencer(s) Officials
Key Influencer(s) Staff

4.2 Advocacy – indirect contacts (outside lobbying), e.g. events, news, political press, social media, think tanks , etc.

Short Term action (one month)
Commission (who)	By whom	When	What	How
Lead DG, Unit
Sec-Gen lead(s)
Interservice DGs
Commissioner(s)
Cabinets
Lead official(s) desk officer

Council (who)
Presidency
Permanent Representations
National issue lead
Parliament (who)
Co-ordinators, rapporteurs, shadows
Letters to Committee members & substitutes & advisors

4.3 Resources

Note to students: No need to be very precise and detailed here. For this assignment you can rely on informed guestimates.

Budget summary

Action	When	Cost	Signed off
Report x	10 September	10K
30% of X time issue lead
20% of Y advocacy lead

How will you monitor your impact? What are the advantages and disadvantages of your approach? How is your impact measurement integrated in the overall campaign? How will you interpret your impact measures? How will you use your impact measures for future campaigns?

Checklist for impact monitoring:

Establish pre-mortem, continuously, and post-evaluation impact assessments.
Where the SMART objectives achieved?
Was the achievement of a SMART objective the result of your campaign?
How do internal and external stakeholders assess your campaign’s impact?
What lessons can be drawn for future campaigns? Communicate these.

Risk’s impact on campaign

Probability of happening

Very likely 4, 3, likely 2, unlikely 1, very unlikely 0

Potential impact

Very High: would prevent goals from being achieved 3

Mitigation Strategy

Who is responsible

ANNEX 1 Relevant contacts

Note to students: No need to mention all contacts. Ensure to list the most relevant contacts and at least three relevant contacts in each of the major institutions.

EUROPEAN COMMISSION

LEAD DG:

Name	e-mail	Tel
Desk Officer
Head of Unit
Director
Director-General
Cabinet
Commissioner

Interservice Group DGs:

Name	e-mail	Tel
DG
Desk Officer
Head of Unit
DG
Desk Officer
Head of Unit
etc
Sec-Gen
Desk Officer
Head of Unit

Cabinets:

Cabinet	Name	e-mail	Tel

COUNCIL / MEMBER STATES – EU 28 (soon 27)

Member State		Name(s)	e-mail & tel:
	Ministry
	Perm. Rep.
	Minister(s)
	Political Advisor
	Perm. Rep.
etc

PARLIAMENT

Committee
	Name	Group	e-mail	Tel
Member
Substitute
Rapporteur(s)
Shadows
Committee Group coordinators
National Group coordinators
Advisors to MEPs
Group Advisors
Committee officials
Key influencer(s) MEPs
Key influencer(s) Officials
Key Influencer(s) Staff

PRESS/MEDIA – Brussels and NATIONAL

Name	Organisation	e-mail	Tel