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consultations and timing August 20, 2019

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The UK’s Department for Environment, Food and Rural Affairs is consulting on a National Food Strategy. The Terms of Reference state:

The National Food Strategy will build on the work underway in the Agriculture Bill, the Environment Bill, the Fisheries Bill, the Industrial Strategy and the Childhood Obesity Plan. It is intended to be an overarching strategy for government, designed to ensure that our food system:

But the stated closing date for submission of evidence is October 25th, before the UK looks to be crashing out of the EU. And the Terms of Reference do say that “the strategy will consider our relationships with the devolved administrations, the European Union and our other trading partners.” As with every other policy issue the UK faces at the moment the details of the future relationship of the UK with the EU, and of the various components of the UK with each other matter enormously.  Access to high quality and affordable food is one of the issues the Call for Evidence is interested in,  so having some idea how Brexit actually affects access to food is surely important. Asking people about these issues now to make policy to be implemented in an uncertain future makes no sense at all.

why did the link to “your voice in europe” disappear from the eu commission’s front page? August 24, 2016

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The EU Commission’s front page changes from time to time, and recently there was one change I dislike: there used to be a link right on the front page to a page with the title Your Voice in Europe with links to open consultations being carried out by the Commission. I don’t think all of the Commission’s consultations in fact appeared on this page. I mostly pay attention to what is going on in financial regulation, but every now and then I would come across a consultation that didn’t seem to be shown on the Your Voice in Europe page or at least showed up there after it was initiated. Anyway, the page is still there, but it isn’t linked to directly from the front page. There is a link for Commission at Work which shows a list of “popular links” which include a link to the Your Voice in Europe page, as well as to a separate Contribute to EU Law-Making page (which has links to other pages including the Your Voice in Europe page), a page on Citizens Initiatives.

Obviously business stakeholders and others who are highly motivated will find out what consultations are relevant to their interests – for them it doesn’t really matter if you have to search around a bit to find out what is going on. But for others it does matter. The Commission should be doing more to figure out how to encourage citizens to participate in the policy process. A recent article (Epstein, Dmitry and Leshed, Gilly (2016) “The Magic Sauce: Practices of Facilitation in Online Policy Deliberation,” Journal of Public Deliberation: Vol. 12: Iss. 1, Article 4. Available at: http://www.publicdeliberation.net/jpd/vol12/iss1/art4) states:

Online policy deliberation spaces have higher barriers to entry for the public than the popular discourse would like us to believe… Interfacing with bureaucratic policymaking institutions, policy deliberation is constrained by structures, regulations, procedures, practices, and processes that require a very particular kind of participatory literacy. Effective participation in policy deliberations requires a certain level of subject matter expertise as well as reason-giving and, where possible, evidence-based substantiation of one’s opinions on specific issues… Novice participants, however, often default to voting-like behaviors of registering their preferences or unsubstantiated sentiment expression. Lacking depth and reasoning, mass online civic participation (e.g., online petitions) is often viewed as disappointing in its usefulness to decision-makers.”

For the authors facilitation by moderators is key. But figuring out how to get citizens engaged in general in the policy development process is also important.

online reviews and endorsements – consultation February 27, 2015

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The UK Competition and Markets Authority is “inviting views from consumers, businesses and other interested parties on the use of online reviews and endorsements.” The Call for Information states that the concern which motivates the review relates to the trustworthiness and impartiality of some information in reviews and endorsements and says:

This is a fact-finding exercise to increase our knowledge and understanding. It will look at a range of online reviews and endorsements that are accessed by UK consumers, including those on web blogs, video blogs, social media, specialist review sites, trusted trader sites, retail platforms, and retailers’ own websites. It will also look at the roles that media companies, online reputation managers and search engine optimisers play in helping businesses to promote their products/services and manage their reputations in relation to these sites.

There are a number of different forms for submission of views. Bloggers are asked to use the blogger form and members of the public are asked to respond via a Respond online link or using the consumer form. I guess bloggers aren’t members of the public.

eu consultation on evaluation November 12, 2013

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The EU Commission seeks input on its consultation on evaluation by February 25, 2014. The document explains that a part of the purpose of evaluation is about transparency:

EU stakeholders and citizens have a right to ask the Commission to give an account of what was done and achieved, not least because tax payers’ money is being used to develop and fund the various interventions. This entitles citizens, stakeholders and parliamentarians to hold the administration to account and to see more clearly whether previous promises have materialised and if not what the likely reasons were and what aspects deserve special attention. Transparency can also help to increase trust, as institutions that are transparent and self-critical tend to be more trusted than institutions which do not produce realistic and objective, detailed and full assessments of the performance of their actions. By publishing evaluation findings, the Commission is publicly taking responsibility for its actions, acknowledging how an intervention is performing and inviting further feedback.

There’s a caution in the document about relying on stakeholder views:

It is important to understand that evaluation should not be based only on stakeholder views. It always implies a careful analysis of stakeholders’ arguments and a double-checking against the arguments of other stakeholder groups and, where possible, against information from independent third parties or official statistics. To capture the “end-user perspective” in an evaluation, it needs to be carefully checked whether to rely on data and arguments by organised stakeholder groups at national or European level is sufficient, or whether it would be better to reach out directly to final beneficiaries or end-users (by interviewing a representative sample of individuals – consumers, farmers, travellers, students, business owners, etc.) which we hoped would benefit from a policy or have had to bear its cost. Likewise, quantitative data should always be complemented with and double-checked against qualitative information from other sources (interviews, etc.). This means for instance that an evaluation should not just present an econometric model, its results and limitations, but should always seek to get further confirmation by asking stakeholders in how far and why the results make sense to them.

more calls for evidence for the balance of competences review October 30, 2013

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After October 21’s mass request for evidence across a range of different areas, today’s call is for evidence about social and employment policy (responses due by January 17, 2014), and last week it was for evidence about energy policy (responses due by January 15, 2014). As Mark Easton wrote the other day, the Government does not always pay much attention to views expressed in response to consultations. But perhaps to the extent that these calls for evidence generate factual examples which confirm the views of the Government these exercises will be a bit different.

sec crowdfunding proposals October 23, 2013

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All 585 pages of them are here. Public comments may be submitted via this page. The SEC notes:

We understand that these proposed rules, if adopted, could significantly affect the viability of crowdfunding as a capital-raising method for startups and small businesses. Rules that are unduly burdensome could discourage participation in crowdfunding. Rules that are too permissive, however, may increase the risks for individual investors, thereby undermining the facilitation of capital raising for startups and small businesses.

improved consultations October 3, 2013

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Two examples of what I would like to see more of in consultations: from the EU’s crowdfunding consultation, and the UK Financial Conduct Authority (FCA) consultation on the regulation of consumer credit. Although comments can currently be submitted to the EU crowdfunding consultation in English only the web page suggests that it will soon be possible to submit comments in German, Spanish, French, Italian, and Polish. The consultation landing page seems to be available only in English French and German, and right now it seems that the consultation document is only available in English. So there is some improvement in terms of openness to comments from people who don’t write English (who presumably will rely on online sources and newspapers for information about the consultation). Increasing the amount of translation would enhance transparency further.

The FCA’s consumer credit consultation explicitly invites comments from regular people:

The majority of adults in the UK are customers, or potential customers, of financial services firms. So anyone may be interested in commenting on how we propose to regulate consumer credit firms.

And there’s an outline of the proposals in addition to the 193 page consultation document and 429 pages of appendices. But although the FCA seems to be trying to communicate with people and not just with regulated firms, this article in the Guardian which describes some aspects of the proposals does not encourage people to comment on them but rather seems to present the proposed new rules as a done deal. The Independent takes a similar approach, although an article on the Express website states that “a consultation is open until December 3 and the FCA will publish its final rules and guidance in February.” Which? announced that it is collecting consumers’ stories of their experiences with the credit industry to share them with the FCA.

basel committee summer consultations June 28, 2013

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On the revised Basel III leverage ratio framework and disclosure requirements (deadline 20 September); and three consultations with a deadline of 27 September: on the sound management of risks related to money laundering and financing of terrorism; and on derivatives-related reforms to capital adequacy framework: capitalising counterparty credit risk exposures and capital requirements relating to bank exposures to central counterparties.

summer consultations in the uk June 27, 2013

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The Department of Business, Innovation and Skills is consulting (well, issued a “call for views”) on corporate responsibility (responses due by 27 September). Some of the issues raised in the document relate to responsible supply chain management. And the document asks:

Should corporate responsibility be recognised as a profession?

Meanwhile, there is a Call for Evidence on the Integrity and Assurance of Food Supply Networks (responses due by 7 August). Some received a letter inviting evidence with a list of questions, such as:

Do consumers fully understand the way industry describes the composition and quality of the products on sale?..Has the consumer developed unrealistic expectations of the food industry and if so, what role is there for the food industry and government in doing something about it?

Given that “value” products sold in the UK recently turned out to be products made with ingredients (such as horsemeat) different from those listed on the packaging it does seem that consumers didn’t understand the descriptions fully and that their expectations were unrealistic.

And there is a consultation on the draft action plan for open government (comments due 19 September). Here’s a taste:

With regards to our Open Data objectives going forward, our default position is for data to become open where it represents value for money for taxpayers, unless there are robust legal (including Freedom of Information (FoI) Act), security, or financial complexities. We will be enriching this plan with further commitments from the Cabinet Office Transparency Team and from other government departments. Our relentless focus will be on maximising the amount of data released in this way. In the relatively few areas where public open data publication is not possible there can still be benefits to sharing this information under strict conditions, a subject on which the Administrative Data Taskforce has recently reported.

A “relentless focus” on making data “open” where it “represents value for money for taxpayers”? There’s some material in the paper on public participation in policy-making, but it is rather amorphous.

sec asks for information on broker-dealer and investment adviser regulation March 3, 2013

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There’s a long document explaining the background to the notice, which has not yet been published in the Federal Register. The press release states:

Specifically, the SEC is requesting data and other information from the public and interested parties about the benefits and costs of the current standards of conduct for broker-dealers and investment advisers when providing advice to retail customers, as well as alternative approaches to the standards of conduct.
While the SEC is particularly interested in receiving empirical and quantitative data and other information, all interested parties are encouraged to submit comments, including qualitative and descriptive analysis of the benefits and costs of potential approaches and guidance.
The SEC recognizes that retail investors are unlikely to have significant empirical and quantitative information, and welcomes any information they would like to provide. Commenters should only submit information that they wish to make publicly available.