In a recent conversation with a high-ranking COM official some interesting views on the COM as actor in the policy discourse came across:
Policy proposals are developed with all relevant actors in a particular field. The participation of experts in the process is necessary to create a common ground for the COM proposal, but the process itself also contributes to the implementation of a policy later in the policy process. Experts who are included in the early stages of the development eventually regard themselves as stakeholders of the proposal which they helped to create with their own ideas.
Lobbying is essentially a self reflecting system where lobbyists first sell their own problem perception with regard to a policy proposal to their customers in order to be able to offer solutions for those problems. A rule of thumb is: “a good lobbyist drafted the bill, a bad one fights it”.
If a proposal is published by the COM, it has the ability to emphasize according to national sensibilities different aspects of it in different MS. Since by that time, relevant experts are already familiar with the proposal, ensuing debates are among second order experts and can be used to judge the political room of manoeuvre with respect to sensible topics.
To develop a successful proposal, political steering is a condition sine qua non. It is therefore important to have political staff that brings in expertise from their MS. Necessary is a political impact assessment, prior to the decision to engage in a policy area. Political support from MS and stakeholders is a precondition for COM activities, if the circumstances change the poison of the COM changes accordingly.