My guestimate is that the single largest amount of time any organisation in Brussels spends is on preparing position papers.
If all this time is well spent is a question you’ll know the answer to. If it is spent with a view to influencing public policy and political decisions, it is time well spent.
Recently, I’ve written about the internal mechanics for doing the drafting, and a checklist on what to put in the position paper.
A more granular approach is something along these lines. If you follow this, your position paper will be shorter and have more influence
What to put down on position paper
For each of your asks you’d follow what amounts to a max of 2-3 short paragraphs.
- Be clear about the issue in each section. Add a title that the reader can look for. For example, is your issue around alignment with other legislation. The title can be something like ” Misalignment between Article x name of Directive] and [Article Number] in Commission’s proposal.”
- State what the issue is, e.g. they don’t align and the explanatory memorandum says they are meant to align. Add the footnotes to page and paragraph number.
- Be clear what article is at play in the Commission’s text – it is what they will look for when they read reading/skimming the paper.
- Explain your reasons and reasoning for your position. Make it clear, concise and in plain English.
- Provide evidence for your position. Real evidence, please.
- Cross reference anything relevant from the Impact Assessment and the opinion of the RSB. Don’t selectively cite.
- Offer a clear solution. Provide the public policy reasoning for a particular policy option. Provide the legal text for the alternative policy option. The solutions and text can be fleshed out in an Annex.
Some Challenges
This approach raises challenges.
First, if you don’t have evidence to support your position, you’ll not have much to go forward on.
Second, if you don’t have a real solution, you don’t much to go forward with.
Third, if the Commission’s proposal is clear, evidence rich, and reasoned, you may well have a harder job pointing out any problematic issues.
Fourth, going through 1-3 will likely filter out a lot of what you initially wanted to write down. Ditch anything that does not pass 1,2 and 3, and put the rest down in your final paper. If you put down points that fail 1-3, you are playing only to an internal audience, and your position paper’s influence will be weakened because of it. I know of one organisation whose papers are often not read because the first 3/4 of points are considered partisan and evidence-free. I find this is a shame because buried at the end is some useful approach and solution, but realise few people will ever have the patience to read to end.
Finally, it forces you to put down in clear and concise plain English, an alternative approach (solution).