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You’ve been given a policy proposal from somewhere else to comment on. It might be from elsewhere in your organisation. It might be from another agency. It could be a draft in its early stages. But then it could also be a Cabinet Minute, fully shaped up and with very short deadlines.

How do you think about providing effective policy comment?

Commenting is your opportunity to influence a policy outcome. The framing and clarity of your response are critical. Some hints on preparing good advice:

Keep an ear out
If you know another branch or agency is working on a proposal do some preparatory work internally. This makes it easier to meet short turnaround times.
What’s the purpose?
Identify the core intent of the proposal.
  • what are the key 2-3 things that the proposal is trying to achieve?
Think strategically
Do you have any strategic concern with these proposals?
That is do the proposals get in the way of your agency meeting its objectives?
  • If yes work out those concerns. Be very clear in those objections and back them with evidence.
No concerns
Let’s assume you don’t have a strategic concern with the proposals.
  • You should clearly say that you either support or don’t object to the overall thrust of the proposal.
Real concerns
Work out if there are issues that your agency cannot live with. That is the content is at cross purposes with your strategic objectives or imposes unacceptable resource requirements on your organisation.
  • If so these issues must be raised now. It is too late after Cabinet has agreed and you have a part interest in the implementation of a proposal that you don’t support. You must clearly set out what the issues are and why they are a concern in your response.
  • If you can call the contact person and explore your issue with them to make sure you have the right take on the issue. They might not have been aware of the impact on your area. Calling gives the lead a chance to amend their take on the issue.
Furthering your objectives
Identify if there are any areas where your agency’s strategic aims intersect with this proposal.
  • Does this proposal support your strategic goals? If so be clear where and how so those aspects don’t get amended.
  • Can you propose anything that would further your agency’s goals that would enhance the proposal?
Materiality
Don’t be tempted to comment on the detail of every section—only raise concerns about issues that are genuine concerns for your agency.
  • If you have minor but still legitimate concerns distinguish them from the major concerns.
In your briefing to your Executive Director or equivalent, outline the issues you have considered and disregarded and why. A table often helps with this. This will satisfy your ED that you have considered all the relevant issues and will mean that your briefing will get signed off faster.

And finally, don’t be surprised or put out when you are given two days to turn around comments on a major new initiative. This happens; it’s not great practice, but it is part of the fabric of policy work. Make the best of it that you can, particularly if you can find a way of furthering your organisation’s goals. And remember how annoying it is when this happens so you can avoid doing it to other agencies when it’s your turn.

Want to know more about the art of public policy? Ask us about our Public Policy Masterclass.