The case for using real evidence in your public consultation responses

From time to time I am asked about what type of information you need to bring to the table during public consultations for Impact Assessments.

Each time, I give more or less the same response.

The exercise is an information-gathering exercise to help the College of Commissioners have an objective picture of the evidence for action. If this is new to you, it’s been going on since after the Santer Commission.

The information that you should submit is evidence that influences decisions.  It is not an exercise to make your feel good. That evidence comes down to:

  • objective data
  • relevant data
  • authoritative studies
  • anecdotal evidence

This evidence can show support for a policy option, show that there is no evidence for action, or show that an alternative policy approach is the better solution.

I’ve found hiring the expert’s expert to do this fact-finding for you is a good way to go. It helps get over any bias you may have because of any interests you may have in the matter (and it is likely that you will).

 

What to do

My personal approach is to list the questions you have something useful to the table. You don’t need to answer all questions.

 

My checklist

All you need to do is to put down on a piece of paper all your issues on a piece of paper. For each point you want to make all you need to do is:

  • State your position – in plain English.
  • Bring a solution to the table/ a preferred approach/policy option.
  • Bring real evidence to support your study. That can be a study, data, anecdotal evidence that is in the public domain that supports your position.

You are going to find that don’t have evidence to support some of your positions. Drop them.

At the start, it is going to look like a partially regurgitated meal vomited up by your dog.  Your job is to sort out what is useful and has real evidence to support your position.

Don’t do

There are some simple things you should not do, including:

  • Avoid selective citation.
  • Submissions that amount to statements of belief or political diatribes. They are just ignored and anything useful mentioned in the splurge of emotional words is lost.
  • Masquerade as expert evidence when the study has been written by you and signed off by the expert without them having read it.
  • Avoid bringing any evidence to the table in the public response.
  • Not making the evidence public.
  • Misrepresent the views of others, in particular an expert. The official reviewing the feedback likely did their post-doc with the expert you are mentioning.

If you want to influence the policy decisions of the College, the path is an easy one to take. It’s not a well-trodden path.