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Policy Stakeholder Analysis and Position Map

Send the issue and the parties, get each one's position with the filing or testimony behind it and where the coalition is soft.

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River builds the map from documents rather than reputations. For every party it looks for something on the record: a comment filed in the docket, testimony given at a hearing, a brief filed in litigation, a lobbying disclosure naming the bill, or a dated public statement. Each position cell carries the source it came from. Where a party is widely described as holding a position and has put nothing on the record, the cell says so instead of recording the attribution as a fact.

Search this and you get grids. A power-interest matrix, a four-quadrant influence chart, a stakeholder register template with a column headed position and nothing about where the entry came from. The grid is not the hard part. Filling it honestly is, because most of what circulates about who is opposed comes from third parties, and the parties themselves have usually said something narrower, later, or with a condition attached. A filed comment is different in kind, because the statute invites written data, views, or arguments from the party itself, dated.

Written for the analyst deciding who to approach first, the advocate testing whether a coalition is real, and the researcher who needs positions that can be cited. It pairs with the docket clustered into the arguments an agency must answer, which reads submissions by content while this one reads them by party. Once positions are mapped, costing the rule by affected group usually explains them, and a brief carrying its own evidence is where they land.

Four of nine coalition members filed nothing

Thirty four organisations are described in coverage and press releases as holding a position on one bill. Twenty nine have something on the record and five have nothing at all, which is 14.7 per cent of the list. The record sources overlap, since a group can both file and testify: 21 filed a comment, 8 testified, 5 filed in the litigation, 17 named the bill in a lobbying disclosure, and 6 have only a dated public statement. Those 6 are usable, and they are labelled differently.

Sorting by what the record actually says gives a different picture than a tally of supporters and opponents. Eleven oppose unconditionally on the record and eight support unconditionally, so 19 of 34 positions are clean, 55.9 per cent. Seven support with a stated carve-out written into their own filing. Three have a position on the record narrower than the one attributed to them. That is 10 organisations, 29.4 per cent, whose apparent position is softer than any headline count of sides would suggest.

The coalition check is where it earns its keep. A trade association filed in support on behalf of 46 members. Twenty two of those members, 47.8 per cent, have a filing or a disclosure of their own, and 5 of the 22 took a position inconsistent with the association's, which is 22.7 per cent of the checkable ones. Separately, the support coalition's press release names 9 organisations, and 4 of the 9 have nothing on the record under their own name.

How it works

  1. Assemble the record

    Docket comments, hearing testimony, litigation filings, lobbying disclosures, and any dated statement under the party's own name.

  2. Attribute each position

    One party per row, the position, and the specific document it was taken from.

  3. Test the coalitions

    An association's filed position checked against whatever its individual members put on the record themselves.

  4. Mark the gaps

    Parties with nothing on the record, and positions narrower than the ones attributed to them.

What you get

  • Every position sourced to a filing, transcript, disclosure or dated statement you can open
  • Parties widely described as opposed who have put nothing on the record, named as such
  • Conditional support separated from unconditional, with the carve-out quoted from the filing
  • A coalition integrity check comparing an association's filing against its members' own
  • Position drift over time, since a group's earliest filing often differs from its current line
  • A position map you can put in a briefing, with the evidence column intact

Common questions

Why insist on a document for every position?

Because a position taken from coverage or from a coalition press release is a claim by somebody else about a third party, and it is wrong often enough to matter. A filed comment is the party's own words, dated, and admissible in an argument. When you tell a legislator that a group opposes something, being able to open the filing is the whole difference.

What counts as the record?

Anything the party itself put its name to: a comment in the docket, hearing testimony, a brief or declaration in litigation, a quarterly lobbying disclosure, a regulatory or securities filing, or a dated statement on its own site. Third-party characterisations are recorded as attributions, kept in a separate column, and never promoted into the position field. Where the record exists only inside an agency's files, a records request surfaces it.

How does the coalition check work?

An association files on behalf of its members, so its filing is evidence about the association. The check looks for each member's own filings and disclosures and compares. In the worked example five of the twenty two checkable members took a position inconsistent with their association's, which tells you where the coalition will not hold under pressure.

Where do lobbying disclosures fit?

They establish activity even when a party has never issued a statement. A quarterly report must list the specific issues upon which a lobbyist engaged in lobbying activities, including a list of bill numbers and references to executive branch actions. So a filing that names your bill puts the client in the fight, on the record, whichever way they lean.

What about a party that has genuinely said nothing?

It gets a row with the position field marked unestablished, which is more useful than it sounds. Silence from a party everyone expects to be loud is itself a finding, and it is frequently the party worth approaching first. The map distinguishes silence from opposition rather than treating the two as equivalent.

Does it handle positions that changed?

Yes, and the change is usually the most interesting row on the map. Each position carries the date of the document it came from, so an early comment supporting a proposal and a later one opposing an amended version both appear, in order. A group whose position moved is a group whose position can move again.

What comes back?

A Sheet with one row per party carrying the position, the evidence, the document date and an influence assessment with its basis. A Doc describing the coalition structure and where positions are softer than they appear. A diagram placing parties by position and influence, drawn from the sheet rather than by hand.

Policy Stakeholder Analysis and Position Map

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